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Shedding Light on Foggy CDL Requirements

Reprinted with Permission from the May/June 2018 issue of Tracks, the official publication of NATM (National Association of Trailer Manufacturers).
By Kim Mann, General Counsel to NATM, Scopelitis, Garvin, Light, Hanson & Feary
NATM headquarters receives frequent calls from trailer manufacturing members asking why the local police are insisting on commercial driver’s licenses (CDLs) for drivers operating tow vehicles pulling their trailers. They then describe their particular set of circumstances. Prompting these questions are complaints the members have received from their customers and dealers about state troopers and local enforcement officers pulling over drivers towing their trailers they thought did not require CDLs and their customers had purchased with that same understanding. So, what’s going on here? Overly-aggressive law enforcement at work? Dealers and/or customers ill-informed about CDL laws? A combination of both?

What appears to be behind these inquiries is the vagueness of the CDL laws and the general confusion and disagreement this vagueness naturally generates. So, let’s try to clear up some of this confusion. Starting at the beginning, Congress has charged the U.S. DOT’s Federal Motor Carrier Safety Administration (FMCSA) with responsibility for implementing the federal CDL laws through federal regulations and has directed the states to issue CDLs in conformity with these regulations. The FMCSA’s CDL regulations appear in the Code of Federal Regulations, 49 C.F.R. Part 383. The FMCSA requires drivers to have a CDL – either a Class A, a Class B, or Class C (for transporting passengers or hazardous materials) – in order to operate defined types of commercial motor vehicles (CMVs) in interstate, intrastate, or foreign commerce.

CDL Requirements

FMCSA’s graphic illustrating the various vehicle configurations constituting the groups of CMVs requiring a Class A or Class B CDL (Click to enlarge)

To clarify its regulations, the FMCSA publishes a graphic illustrating the various vehicle configurations constituting the groups of CMVs requiring a Class A or Class B CDL. That graphic can be found to the right. State and local law enforcement often refer to it for guidance.

The FMCSA requires drivers to have a CDL to operate a motor vehicle if that vehicle meets the FMCSA definition of a “commercial motor vehicle” and is used in “commerce.” The FMCSA defines both terms in 49 C.F.R. § 383.5. The great misunderstanding out there, within the trailer industry and probably within the law enforcement community, about the CDL requirements springs from those two definitions, particularly of “commerce.”
The FMCSA defines a “commercial motor vehicle” as a motor vehicle, or a combination of motor vehicles, in certain GVWR-based configurations, when used in “commerce” to transport “property or passengers.” The physical configuration component of the CMV definition is very mechanical, very objective. When dealing with a tow vehicle-trailer combination, you look at the gross combination weight rating (GCWR) of the tow vehicle if the tow-vehicle manufacturer has assigned it a GCWR and displays it on its cert label. With regard to the familiar combination, a tow vehicle (whether truck, automobile, or tractor) towing a trailer, the driver needs a CDL if the tow-vehicle manufacturer’s assigned GCWR exceeds 26,000 lbs. (as shown on its cert label) and the trailer’s GVWR exceeds 10,000 lbs. If there is no assigned GCWR, the FMCSA requires a CDL only if the sum of the GVWRs of the tow vehicle and the trailer together exceeds 26,000 lbs. and the trailer’s GVWR exceeds 10,000 lbs. In either case, the driver will need a Class A CDL.
With regard to a single vehicle, the FMCSA requires the driver to have a Class B CDL to operate that truck, bus, van, or automobile if that vehicle has a GVWR of more than 26,000 lbs. It is required even if that truck, automobile, or van is towing a trailer and that trailer has a GVWR of 10,000 lbs. or less (If the trailer’s GVWR exceeds 10,0000 lbs., a Class A CDL is needed).

The second component of the CDL requirement, and of the CMV definition, is much more troubling, much more subjective, and the primary source of the confusion. To qualify as a CMV requiring a CDL, that vehicle, even in a qualifying GCWR/GVWR configuration, must be used in “commerce.” “Commerce” has its own separate definition in § 385.3 of the FMCSA’s regulations. The FMCSA defines it broadly as any trade, traffic, or transportation between points in one state and points in another state or any trade, traffic, or transportation that “affects” trade, traffic, or transportation in the U.S. between points in one state and points in another. Not exactly an enlightening definition, to say the least. How this “use” assessment turns out often varies depending upon who is doing the assessing. And that is often the law enforcement officer on the scene.

As a starting point, the proper inquiry, then, is whether this questionable CMV is transporting property (across state lines) for some commercial purpose, as opposed to for the personal use of the owner, driver, or some other person. What the trailer owner considers his or her own “personal use” may, upon close examination, in fact turn out to be for a “commercial purpose” when viewed through the critical eyes of the state or local law enforcement officer. Let’s examine several tricky examples:

  • The trailer owner is towing his own horses to a horse show or his livestock to the state fair where monetary prizes are awarded. That familiar scenario is likely to be seen as a commercial undertaking or commercial purpose from the vantage point of the diligent state trooper who pulls the driver over looking for that CDL.
  • Suppose instead those horses belong to a stable whose owner charges the public by the hour to ride them. Another commercial purpose according to a strict interpretation of the term. It does not matter that no business name or logo is displayed on the side of the truck or trailer towing these horses.
  • Now suppose it is a college student behind the wheel of Dad’s 16,000 lbs. GVWR truck towing his family’s lawn mower around the neighborhood in Dad’s utility trailer to earn a few bucks mowing lawns to off-set that college tuition. He may need a Class A CDL if that trailer’s GVWR exceeds 10,000 lbs.

Complicating the question of whether a CDL is necessary could be a hodge-podge of state CDL laws at variance with the federal law. States are not prohibited from enacting their own state CDL laws, applying them to non-interstate movements (i.e. the trailer does not cross the state line), if those state laws are stricter than the federal law. In theory, the state law of State A might require its residents to have a different class of CDL, perhaps designated as a “Class D,” to tow a 26,000-lbs. GVWR trailer when used for personal use.

State A must, however, honor the out-of-state license issued by State B to its residents: for example, if State B does not require a CDL for its residents to operate a vehicle for personal use, then State A may not require State B residents to have a CDL while operating a vehicle for personal use in State A even if State A requires its own residents to have a “Class D” CDL for this purpose.

The “CDL” complaints that NATM fields typically revolve around the smaller trailers (between 10,000 lbs. and 26,000 lbs. GVWR) and the debate over personal vs. commercial use. In sum, assuming commercial use, when the GVWR of the truck exceeds 26,000 lbs., a CDL is required, regardless of the GVWR of the trailer, and when the GVWR of the truck is less than 26,000 lbs., a CDL is required only if that truck’s GVWR and the trailer’s GVWR, added together, exceed 26,000 lbs. and the trailer’s GVWR exceeds 10,000 lbs.

View the Original article “Shedding Light on Foggy CDL Requirements” in NATM’s Tracks Magazine here.

Learn more about Felling Trailers’ full line of trailers for commercial, construction, government, utility use and more.



  1. I have a class B with air brakes endorsement already. I want to get a Class A. When I take the driving test, do I have to have a trailer with air brakes as well to get the endorsement on my class A license.

    • Felling Trailers says

      Hello Mac,

      For accurate detail of what you will need on test day, we suggest contacting your local department of motor vehicle.

      Best of luck on your test,
      Felling Trailers

      • I know this is a older post so I have a quick question we have a t40 bucket truck with a gvw of 25900 pounds so my understanding of the Ohio rules a class d driver license can drive but with a trailer under 10001 gvw a class d can drive as long the truck and trailer is not overloaded and if the trailer is over 10001 gvw now you will need a class a license

        • Good Morning Troy,
          The way I interpret the law is that a class D driver’s license is good for any vehicle combination up to 26,000 lbs. A class B license is good for single vehicles with a GVWR of over 26,000 lbs, or a combination whereas the trailer GVWR is under 10,000 lbs. It is possible that there is an exception for when the single-vehicle is under 26,000 and the towed trailer is less than 10k that would make this legal for a Non-CDL driver, (even with gross combination over 26k) but I cannot confirm this holds true for all areas. You will want to confirm with your local highway dept.

          Hope this helps,
          Felling Trailers

          • mr douglas landry says

            class D – a motor vehicle exceeding 11,000 kg (24,000 lb) gross weight or registered gross weight–note exceeding being the operative word///do not post information if you do not know what you are talking about…the last thing people need is more uneducated information being post in the forum.

          • Hello Douglas,
            I believe this confusion is created as Canada and the U.S. have different driver’s license classifications.
            A Class D. in Canada is similar to a Class B in the U.S.

            A class D in the U.S. is similar to that of a Class G Canadian.
            Here is how it is defined on “Class D License – All single-unit vehicles (cars and pickup trucks), except those with a gross vehicle weight of more than 26,000 pounds, vehicles designed to carry more than 15 passengers (including the driver), and vehicles that carry hazardous materials.”

            Hope this helps,
            Felling Trailers

        • Is it legal to de rate a trailer from 14000 to 12000 if you just purchased it and haven’t registered it yet in south Dakota

      • I have a Dually that weighs 7500 pounds , have a trailer with a gvwr of 14000 lbs do I need a cdl

        • Good Morning Tee,
          CDL requirements will be determined by Gross Combination Weight Rating, not net weight. You will have to look for the GVWR of your truck, not the actual weight. The total combination rating needs to be under 26,000 lbs. for a class D license.

          Hope this helps,
          Felling Trailers

      • On a CDL trailer does my registration need to be attached to the trailer?

        • Hello Drew,
          I don’t believe anything about your CDL needs to be attached to the trailer. I would contact your local DMV, or State Troopers office and verify.

          Hope this helps,
          Felling Trailers

  2. I have an f-450 GVW 16,000
    With a trailer GVW 21,000
    Which I use to tow my own personal race cars to amateur vintage races that I pay to enter for my own pleasure were no prize money can be won.
    I live in Illinois
    Do I need a class A license?

    • Good Morning George,
      Class A: a combination of 2 or more vehicles, including a trailer(s) in excess of 10,000 lbs., articulated buses with a Gross Vehicle Weight Rating (GVWR) exceeding 26,000 lbs., and all vehicles authorized to be driven under Class B and C, or with a regular driver’s license, Class D.

      To further break this down, your current Gross Combination weight rating is 16,000+21,000= 37,000 lbs., which would require a Class A license. A Class D License is only good for vehicle combinations up to 26,000 lbs. I would recommend contacting the Illinois Highway patrol for further verification and explanation specific to your state.

      Hope this helps,
      Felling Trailers

      • I appreciate the advice.
        Thank you very much!

      • Usually nobody pays any attention til the vehicle has lettering/logos down the sides of trailer and Joe blows racing on the doors. Don’t put anything but a not for hire decal and you’re golden

    • Yes you need a class A license in Illinois. You will be fine with a class A non CDL license ( Illinois is one of a few states that have this) if you can convince a police officer that you never use your rig for commercial purposes, this may be the tricky part.

  3. We have a F-250 10,000lb and a 14,000lb tandem axle trailer. Owned personally but used to complete service work for our business. If we cross state line to work at a customer location do we need DOT? Do we need CDL simply because its being used commercially?

    • Felling Trailers says

      Hello Mike,

      It is our understanding in the state of Minnesota law, is that as long as the truck trailer is not for hire, a CDL is not required. This may vary state to state, so we do advise you to check with your local Department of Motor Vehicle.
      Thanks much,
      Felling Trailers

  4. John Steinberg says

    We have a GMC Sierra AT4 fro personal use. GVWR IS 29k plus. All use is for pulling our “less than 10k” travel trailer for RECREATIONAL use only.

    1- Do I now need to get a commercial cdl license?
    2- or NO, only applies to commercial/business/for profit use

    • Hello John,
      If the GVWR of the truck is over 26,000 lbs you will need a CDL license of some sort. Depending on the state you could obtain a class B license since the truck only is over 26k but would be limited to trailers to stay under 10k.
      A class A. Would allow you combinations over 26,000 and trailers over 10,000 lbs.

      Hope this helps,
      Felling Trailers

  5. Hi I have a small business and am currently looking for a larger equipment trailer, my trucks gvwr are all 12,500 or less, can i get a 14k trailer (gcwr will be under 26k) and not need a cdl? Or am I restricted to trailers 10k or less? Located in CT. Thanks

    • Hello Steve,
      As long as the GVWR of the truck + the GVWR of the trailer remains under 26,000 lbs, a CDL should not be required.

      Hope this helps,
      Felling Trailers

      • Michael D Cruz says

        I have that same question I read a lot about this but the more I read the more im confused. You said trailer GVWR over 10,000 needs a cdl that one is GVWR 14,000 but he’s still under GCVWR of 26,000 so gow does that work in Texas as im a non-CDL hotshot

        • Good Morning Micheal,
          The standard Class D license allows the driver to operate vehicle combinations with a combined weight rating of up to 26,000 lbs.
          The Class B CDL allows you to do everything you can with the Class D, however, it also allows you to operate a single unit (non-combination) of more than 26,000 lbs. GVWR, and combine this larger single unit with a trailer of under 10k. To further explain on this, if your total Gross combined weight rating is over 26,000 lbs while your trailer is at 14,000 lbs, you will need a Class A, not a Class B license. While we do our best to interpret the law in your area, I Highly recommend consulting with local authorities to verify you are legal.

          Hope this helps,
          Felling Trailers

          • Sorry to drag this out. But…….. here’s our situation.
            Tow vehicle, 2007 Dodge 3500 dually, GVWR 11.5K, GCVWR 23,000
            Trailer, 18K GVWR
            Obviously if you add the two GVWR’s you get 29.5K. But since the truck has an official GCVWR below 26,000 are we good without a CDL?

          • Good Morning Sherman,
            A Class “A” Commercial vehicle license would be required. While we do our best to interpret the law in your area, I highly recommend consulting with local authorities to verify you are legal.

            Hope this Helps,
            Felling Trailers

        • Robert lash says

          I’m confused as well and they still didn’t answer the question it says if your trailer is over 10,000 pounds you need a cdl but long as you under 26,000 you don’t need one my truck gvwr is 11,400 my trailer gvwr is 14000 I’m under weight but my trailer is 14,000

          • Hello Robert,
            A standard (class D) driver’s license qualifies the driver to operate any combination up to 26,000 lbs combination weight rating.

            Anything larger than that requires a CDL. The Class B CDL license qualifies the holder to operate any single-unit vehicle of more than 26,000 lbs. and combinations of more than 26,000 lbs so long as the trailer is under 10,000 lbs.

            The Commercial Class A is required for combinations over 26,000 and the trailer is higher than 10,000 GVWR

            Hope this helps,
            Felling Trailers

  6. I’m in Oregon and building a house for myself. I haul building materials, heavy equipment, gravel, etc. My truck is a 2002 Chevy dually and the door tag says 11,400 pounds GVWR. The manual says the GCWR is 22,000 pounds. In addition, it says a 5th wheel weight distributing hitch is limited to 12,000 pounds.

    My gooseneck dump trailer tag says 15,680 pounds GVWR. Both axes at 7,000 pounds each. The grand total of truck and trailer is 27,080 pounds which is over the 26,000 pound threshold, not to mention exceding the manufactures recommendation for gross weights.

    My questions are the following:
    Is DOT looking at the total capacity potential(stickers on truck/trailer added together) or just what you actually weigh on the scales loaded?
    Do I need more truck to pull this trailer loaded?
    Does DOT care/know about the GCWR in the manual?
    At what point do I need a CDL?

    The 2020 Chevy diesel dually is boasting a 35,500 GCWR!

    Thank you,

    • Steve,
      I will do the best to address each question.
      The simplest form, a CDL is required if the Gross Combination Vehicle Rating is over 26,000 lbs. This is based on the posted weights of the GVWR of Truck + the GVWR of the trailer regardless of what the actual weight is. There are a few exceptions but are usually ag-related. From everything you have explained to me, a CDL would be required to operate your truck and trailer on public roads, even when empty.
      The gooseneck rating seems light at 12,000 lbs, as most are rated at a towing of 25,000 lbs. I would think you have more than enough truck for that trailer, but I better not speak on behalf of the truck manufacturer.
      As far as I know, I don’t think the DOT/ Highway patrol will be concerned with posted towing capacities. From what I have gathered they will look at the capacity of the license purchased and your driver’s license capabilities. They will also look at rated tire capacity and axle capacity.
      In order to get the best knowledge, I would recommend contacting your local DOT/ highway patrol for a more precise explanation of the requirements of your situation.

      Hope this helps,
      Felling Trailers

    • You would need a class A CDL because the trailer has a GVWR of 14k lbs even though the CGWR is under 26k lbs between your truck and trailer. I recommend checking with the local DMV or DOT for more information.

  7. Hello Felling Trailers,
    Thank you for this article. Sorry to ask the same question, though the more we go over the answer the better everyone’s understanding is of these laws.
    Here’s mine, CA registered dodge 2500 combined axle rating of truck is 10,934lbs and I’m pulling a 14k dump trailer for a total combined of 24,934lbs if correct. I am under the 26,001 but over 10,001 on trailer. Am I clear to run my current Non commercial class C or should I go for a Class A cdl. And if so any tips for negotiating with CHP should they choose to stop me to avoid a brow beating.
    Thank you

    • Good Afternoon Alex,
      A Standard Class D license is good for any vehicle combination up to 26,000 lbs. That being said your listed combination should be safe with a standard license. It is always best to contact the California Highway Patrol in case there are any local laws.

      Hope this helps,
      Felling Trailers

  8. William Seddon says

    What if i have a dually truck with a door sticker rating of 14,000 lbs and a trailer with a sticker rating of 14,000 lbs which would put me at a total of 28,000 lbs which would require cdl because its over 26,000 lbs. But what if i register my truck at a max combination weight of 25,500. Would that still require cdl? No matter what the manufacturers sticker states my registration forbids me to haul over 26,000.

    • Hello William,
      The law has been explained to me as any vehicle combination over 26,000 lbs will require a CDL. There are several exceptions, mostly for agriculture use.
      This remains true even if the truck and trailer combination is licensed for a lighter weight, the CDL requirement is still based on the Gross Combination Weight Rating, (GVWR Truck + GVWR Trailer).

      Hope this helps,
      Felling Trailers

  9. We have a truck trailer combination of 19,000 lbs with the trucks GVWR at 9,000 and the trailer at just over 10,000 lbs. So even though the combined weight is under 26,000 does this combination require a Class A license in California due to the trailers GVWR? This is a commercial (for hire) situation.

    • Hello James,
      The gross combination is under 26,000 lbs. and a Commercial Class A license should not be required.
      However, you will want to check with the local rules as a DOT health card may be required because it’s being used for commercial/ for hire applications.

      Hope this helps,
      Felling Trailers, Inc.

  10. Joshua Martin says

    Hi, I’m new the the HD truck world and looking to get a 2019 Dodge ram 2500 with the cummins I6 and pull an RV Toy Hauler TT that weights around 10k dry weight and travel around the U.S., would I need a CDL to do so? I heard that it might depend on the length of the trailer also? Thanks

    • Good Afternoon Joshua,
      The CDL is determined by the GVWR of the Truck + GVWR of Trailer, which has to be under 26,000 lbs. The 2,500 Ram and the toy hauler are likely 10,000 lbs, or less, each, which should keep the total combined under 26,000 lbs. The gross combination is under 26,000 lbs. and a Commercial Class A license should not be required.

      Hope this helps,
      Felling Trailers, Inc.

  11. Hello, my problem with this whole weight rating system for P/U and trailers is the GVWR. Because I operate 80,000 pound tractor trailer. That’s the max I can haul legally without permits. But if you go by GVWR on combination, it would be 132,000 pounds. So my point is how can Dot officer justify pulling over and giving a ticket to a p/u and trailer combo if he only base it GVWR??? Because that means that I should be ticketed also because my manufacturing GVWR exceeds 80,000 pounds. But as long as I scale 80,000 or less I am legal. So point is how is my rig based on actual weight but my ram 3500 and gooseneck is based on GVWR?? If I register combo at 26000 pounds and trailer weight doesn’t exceed 10001 pounds actual weight then my daughter should be able to drive truck without cdl. My Question is why is my peterbuilt based on actual weight, but my ram on manufacturing stamped weight?????

  12. We have a Chevy 4500 (Flat Bed, Cab and Chasis) GVWR of 16000 lbs pulling a Gooseneck Trailer GVWR of 20,000 lbs.
    Apportioned license for both at 40,000 lbs max. (Truck does not have state plate – Illinois)
    We know the driver needs CDL when pulling the trailer, but does a different driver only driving the truck by itself need a CDL? Do they need a medical card? Commercial – not for hire.

    • Good afternoon Jeff,
      A person operating a single or combination vehicle under 26,000 lbs is not required to obtain a CDL.
      However, a person operating a vehicle interstate (across state lines) that has a Gross Vehicle Weight Rating or Gross combination weight rating above 10,000 lbs will require a DOT medical exam / Health card. For Intrastate (within the state the vehicle is licensed) the Medical card requirement varies per the state you are in. Most follow the same ruling as Federal. This is how we have interpreted the law, but I strongly recommend contacting the highway patrol in your area for a better explanation of the rule.

      Hope this helps,
      Felling Trailers

  13. I currently do not have a cdl, The answer is probably in this article and I’ve missed it, but is a cdl required to tow a 12,000 lbs trailer with a 3/4 ton truck? ( I can’t remember the gvwr, but it’s a Chevrolet 2500hd)

    • Good Afternoon Cody,

      You will want to look at the VIN tag on the truck (usually on the door) and verify the GVWR. I am assuming it is 10,000 lbs, which, when paired with a trailer that has a GVWR of 12,000 lbs., should not require a CDL.

      Hope this helps,
      Felling Trailers

  14. Michael J Luken says

    Hi, I own a F350 with GVWR 10600, We haul a 13000 pound boom lift on a gooseneck trailer 30000 GVWR, In Iowa for our painting business. My friend would like me to haul a 10000 pound equipment load for him to Florida. Will I need a CD L?

    • Good Morning Michael,
      Our interpretation is you would need a CDL for the current truck and trailer combination regardless of the actual weight placed on the trailer, or where you are going. A Class D license is only good for vehicle Gross combinations up to 26,000 lbs. This is how we have interpreted the law, but I strongly recommend contacting the highway patrol in your area for a better explanation of the rule. This is how we have interpreted the law, but I strongly recommend contacting the highway patrol in your area for a better explanation of the rule.

      Hope this helps,
      Felling Trailers

  15. Good afternoon Jeff,
    I have a C6500 flatbed with a GVWR of 29,950 and GCW 36,660 with non-commercial Idaho plates but WA licenses class D. The truck is used for recreational use only for moving personal items. I normally tow a camper or utility trailer with a GVWR under 10,000lb. When trying to use the trucks max GCW with a 9,950lb GVWR trailer will I need different class license as i’m over 26K?
    Thanks Bryant

    • Good Morning Bryant,
      A single-vehicle unit over 26,000 lbs. requires something more than a Class D license.
      A Class B will allow you to operate single unit vehicles over 26,000 GVWR and combination vehicles over 26,000 only if the trailer is under 10,000 lbs GVW.
      The Class A license will allow you to go combinations over 26,000 lbs. with no limitations on trailer GVWR.
      I know some states have exemptions from this ruling for Agriculture or other related industries. You should check with local authorities if you are uncertain.

      Hope this helps,
      Felling Trailers

  16. I haul livestock for personal use with a 3500 flatbed truck that is well under the stipulated weight limits requiring a CDL. I have been told that while I have a trailer (gooseneck) on the truck, regardless of GVWR, I will need a Class A and shall pull into weigh stations because of the flatbed trailer combo. What code or section applies to this situation and does is this information accurate? I was traveling with my husband and we stopped at a scale house and were advised by the DOT inspector that because of the bed modification (regardless of weight), I would need a CDL to tow anything

    • Good Morning KJ,

      The CDL, Class A is required for vehicle combinations over 26,000 lbs Gross vehicle weight. (GVWR of truck + GVWR of the trailer). This is true regardless of scaled weight. The one-ton truck and gooseneck combination likely does have a total combination weight rating of over 26,000 lbs., which would require a CDL. Some states do have exemptions for agriculture use, but these usually are restricted to intrastate and/or within a specified radius of home.
      I have never heard of a bed modification requiring a different driver’s license classification. You will want to check with local authorities to be certain.

      Hope this helps,
      Felling Trailers

  17. I am amazed at the amount of confusion out there about when to have CDL and when not to have CDL.
    With the use of any vehilce over 1000 pounds in a commercial venue we are probably going to need to be register with the FMCSA for DOT numbers and driver qualification paperwork and oh, did I mention hours of service.
    Your answer to the questions have been spot on. Keep up the good work.////John

  18. Tow vehicle Ram 2500 GVWR 10,000. Tow 14,000# two car trailer.

    I will be moving from CA to the east coast. I am planning on using a two car flatbed trailer carrying two of my cars (owned by me and registered to me).

    I assess this a personal use and not commercial use or commerce. My GCVWR would be 24,000# under the 26,000# CDL. Based on my understanding if these laws I would not require a CDL even though the trailer is greater than 10,000#, <26,000# and no commerce just my personal property.

    I found a rental company for the trailer and they state that they have reduced the capacity on the trailer from 14,000# to 9,999# so that CDL is not required. I do not believe that the trailer reduced to 9,999# will be able to carry my cars as they are 8,400# combined and the trailer has to weigh more than 1,599#.

    I will not try to convince them to change their policy as that is a waste of time. I will likely be better off buying a trailer then selling the trailer at my destination.

    Question: is my original assessment incorrect? Is a CDL required to pull a 14,000# trailer with personal property not for commercial use? Or are they just playing it safe and using CDL as an excuse?

    • Good morning Scott,
      Our interpretation of the law matches yours. A class D driver’s license is good for vehicle combinations up to 26,000 lbs. Since rental companies are commercial, they have a few other deciding factors when keeping trailers under 10K GVWR. Under 10K is safer for customers who show up with a vehicle that has a higher GVWR. It also allows them to avoid doing annual DOT inspections on the trailer. In your specific example, you should be good to move forward with your plan, but it wouldn’t hurt to contact a local office and double-check.

      Hope this helps,
      Felling Trailers

  19. We are in PA and are looking at a new lift for our tree service which will only be operated in state, the lift weighs 11,500 lbs. Could we legally pull it with a #14,000 lb trailer with a truck with a GVW of 10,000 lbs? Provided of course that the unladen weight of the trailer did not push us past the 14,000 limit for the trailer. We do have a USDOT number

    • Good afternoon Mandy,
      There is a lot to consider here in terms of “legally pulling” this trailer.
      In terms of CDL only, the GVWR of the truck and the GVWR of the trailer has to be under 26,000 lbs. Which in this instance, 10,000lbs + 14,000 lbs, should not require a CDL. There are a handful of other scenarios with this combination that could throw you outside of what is legal. It would be best to consult with some local highway patrol/ licensing offices to make sure everything stays legal.

      Hope this helps,
      Felling Trailer

  20. Question about CDL Class C

    Driver has CDL Class C with Endorsement X. Truck and trailer GCWR is under 26k. Truck is rated 11k GVWR, Trailer is rated 14K GVWR. Is he/she ok to pull a trailer over 10K with a class C if the combo weight is less than 26k?

    • Good Morning MJ,
      To the best of our knowledge, the Class C CDL has the same towing restrictions as a Class D, non-CDL license. Any combination of vehicles up to a total of 26,000 lbs GVWR.

      Hope this helps,
      Felling Trailers

  21. Brenden Lee says

    I am a hotshot company using a 3/4 ton pickup and a 14GN trailer. Dual axle single wheel trailer. My GVWR is under 26000 lbs. Am I required to hold a CDL? I used to hold a Class A as I was a truck driver for years but this seems to be a subject of some contention. Thanks.

    • Good Morning Brenden,
      I understand the rule as a class D license is valid for any vehicle combination under a gross combination weight rating of 26,000 lbs. because of the commercial nature of your driving, you may be required to have DOT #’s on the truck as well as a valid health card, but I am not sure about those requirements. You will want to contact the state to know for sure.

      Hope this helps,
      Felling Trailers

  22. Kimberly Marinelli says

    My horse trailer/camper combo is registered as an RV. Its GWVR is 19,680 lbs. With the truck it will be over 26,000 lbs. Would I need a CDL to travel from WI to AZ or other western states to camp and trail ride?
    Thank you!

    • Good afternoon Kimberly,
      I read the law that if the truck and trailer have a combined GVWR of over 26,000 lbs, you will need a CDL to drive on any road, for any distance. Some States have Agriculture exemptions, but they don’t cover recreation and usually are limited to within 100 miles from the farm.

      Hope this helps,
      Felling Trailers

  23. New Business Sneeker says

    Looking to start a business in AL towing and hauling heavy equipment. Can I use a F350 and 30ft Gooseneck trailer without a CDL?

  24. Donald Henderson says

    I do some part time work for a guy and have been hauling his equipment on a flat bed trailer , he has now bought a 30 ft gooseneck trailer to haul a bigger tractor , my question is can I use his GMC 3500 and his trailer for the driving test ? And my other question is do I have to get an air brake endorsement since the truck and trailer are not equipped with them ? Also I live in California.

    • Good Morning Donald,
      You will want to do more research specific with your state, however, it is legal to obtain a valid Class A with the below combination, however, it will not work if you also wanted to obtain an air brake endorsement. If your sole purpose of obtaining a CDL is to operate the 3500 and Gooseneck combo, it will work fine for the test and you will be able to avoid the air brake endorsement.

      Hope this helps,
      Felling Trailers

  25. Clarence Quinn says

    kimberly, this is a Texas Question
    We have a a truck that is GVW of 16000 and trailer at GVW of 14000. What class of driver license do we need for this combination We haul a mini excavator from job to job on the trailer


  26. Michael Burgess says

    You answered the situation which applies to me a couple of times – truck GVWR is 11,500# and a 14,000# gooseneck trailer which means the combined is under 26,000#. What I haven’t seen you respond to is when the 10,000# limit on the trailer comes into play. Do you only need a CDL when the combined weight exceeds 26,000# AND the trailer GVWR is over 10,000#? Can you address what your understanding is of that part of the DOT regs?

    • Good Morning Micheal,
      To the best of my understanding, there is an exception to the 26,000 lb combination rule if the towed unit is under 10,000 lb. GVW. (rated capacity and/or actual gross weight) If, however, your single unit tow vehicle is over 26,000 lbs GVW, you will still need a class B CDL at a minimum.

      Hope this helps,
      Felling Trailers

  27. Brian Schilling says

    Do I need a CDL for a triple axle 10k rated trailer EMPTY? I am willing to bet the trailer could be certified well over 10k but the placard says 10k. I had a guy say I needed a CDL due to the 3 axle set up.

  28. I live in pa I have a truck and van both are 2500 series and GVWR is 9200 lbs.i pull a dump that has GVWR 10,000 lbs. Am I required to have special license endorsements or DOT number?

    • Good Morning Larry,
      A CDL should not be required. However, depending on commercial status, you may be required to have a valid health card and/or an annual DOT inspection. You will want to check with local laws to know for certain.

      Hope this helps,
      Felling Trailers

  29. Austin Larocco says

    I have a Florida license. Can I do a truck with a gvwr of 11,700 and a 14k two car trailer with a class B license?

  30. Does the length of the trailer matter…. i have a CDL B and my unk ask me “can i drive with a 40ft alone?” Or is it just bout weight

    • Good Morning,
      The guidelines for CDL Requirements are based on weight.
      Class B allows you to go a single unit over 26,000 lbs, but if the combination is over 26,000 lbs the trailer has to be less than 10,000 lb. GVWR.
      While we do our best to interpret the law in your area, I highly recommend consulting with local authorities to verify you are legal.

      Hope this helps,
      Felling Trailers

  31. Question: we are confused and finding so much back and fourth. We have an F-350 that is somewhere between 9k-11k (depends which site we look at) and we just picked up a trailer that’s rated at 18k to tow our 8200lb excavator. Do we need a CDL for that or can we derate the trailer as we don’t need to load that muc on it? We have seen any trailer over 10k needs a CDL and others that say combo weight of 26k. We are in Maine and trying to figure out what’s needed. Thanks!!

    • Good Morning Sam,
      The best avenue to take is to talk to the Maine Highway department and get answers from the agency who will be enforcing these issues.
      Your F-350 should have a Gross Weight Rating on the tag inside the door. Single rear Wheel truck is usually around 11,000 lbs.
      If the GVWR on your trailer + the GVWR on your truck is less than 26,000 lbs. your Class D driver’s license should be sufficient.
      However, if for Commercial use, The state of Maine may require more.

      Hope this Helps,
      Felling Trailers

  32. kelly tuttle says

    hello, I have a question that I keep asking that gets different answers every time. We haul horses to different races/activities/trail rides etc. We are thinking about getting a semi tractor to pull the trailer, combined gvwr will be over 26K, closer to 37 or so. Do we a CDL to operate this? We’ve been told as long as it is “not for hire” or “personal use” which both applies, that we don’t need a CDL. Can we get some black/white clarification on this subject? Sorry if this has already been asked
    Kelly, AZ