Do You Need a USDOT Number to Haul Your Own Property?

It’s one of the most common questions we hear from construction companies, landscapers, and other private businesses that utilize vehicles as part of their main operations:

"I only haul my own property and equipment. Do I really need a DOT number?"

The short answer is: It depends, but probably yes.

This is a major point of confusion for many businesses. They believe that because they aren't a "for-hire" trucking company, they are exempt from FMCSA (Federal Motor Carrier Safety Administration) rules, whether it be the DOT number itself, or any of the requirements that go along with operating under one.

This can be an expensive misunderstanding. If your business operates a commercial motor vehicle, you are a "motor carrier," even if you are only moving your own tools, equipment, or goods.

Let’s break it down.

The "Private Carrier" Myth

First, let's clear up the terminology.

• A "For-Hire" Carrier gets paid to transport other people's property (cargo) or passengers.

• A "Private Carrier" transports its own property (cargo) that is part of a business. The transportation itself is not the business.

If you are a construction company moving your own excavator to a job site, you are a private motor carrier of property. Same goes for landscapers hauling their equipment to and from different locations. This distinction is important because while there may be certain requirements that a for-hire carrier would need to be aware of that don’t apply to you as a private motor carrier, like an MC number, being a private motor carrier does not exempt you from many of the Federal Motor Carrier Safety Regulations.

The Two-Question Test for a USDOT Number

To know if you need a USDOT number, you can ask yourself two simple questions first:

1. Do You Operate in "Interstate Commerce"?

This is the part that trips up most businesses. "Interstate" does not just mean crossing state lines.

While driving from a job in Texas to one in Oklahoma is a clear example of interstate commerce, the definition is much broader. You are engaged in interstate commerce if your vehicle, its contents, or its driver are part of a trip that begins, ends, or passes through another state.

A good rule of thumb is that if your business activities in any way involve crossing state lines, the answer to this question is yes.

2. Does Your Vehicle Meet the Weight Threshold?

This is the second critical piece. A USDOT number is required if your vehicle (or combination of vehicles) meets any of the following:

• Has a Gross Vehicle Weight Rating (GVWR) or Gross Combination Weight Rating (GCWR) of 10,001 pounds or more.

• Is designed or used to transport more than 8 passengers (including the driver) for compensation.

• Is designed or used to transport more than 15 passengers (including the driver), not for compensation.

• Is used to transport Hazardous Materials in a quantity that requires placarding.

For construction companies, the 10,001-pound rule is the most important. Think about your setup. A heavy-duty pickup truck (like an F-250 or 2500-series) often has a GVWR of 10,000 pounds on its own.

Now, add a trailer.

• Truck GVWR: 10,000 lbs

• Trailer GVWR: 5,000 lbs

• Your Gross Combination Weight Rating (GCWR): 15,000 lbs

In this very common scenario, you are over the 10,001-pound limit. That pickup truck and trailer combination, when used for your business in interstate commerce, legally requires a USDOT number displayed on the vehicle, and is subject to many of the same regulations that a for-hire carrier would need to comply with to operate legally.

Keep in mind, GVWR/GCWR is the truck, trailer, and load capability. If your vehicle or combination is capable of weighing a total of 10,001lbs or more fully loaded, it makes no difference if you ever reach that weight or not - the deciding factor will always be how much it is capable of weighing.

What About "Intrastate" Operations?

"This is all great, but I know I only operate within my own state. So I'm safe, right?"

Not quite yet, no.

While the federal rules apply to interstate commerce, most states have adopted the federal safety regulations (or very similar ones) for intrastate carriers that only stay within the state.

As of today, nearly every state in the U.S. has adopted the federal regulations for intrastate carriers. For example, New York, Illinois, Michigan and Minnesota all require a DOT number for intrastate carriers starting at 10,001lbs GVWR/GCWR - while states like Florida, New Mexico, and North Carolina only require it if your GVWR/GCWR is 26,001lbs or more.

If you’re unfamiliar with your state’s requirements for intrastate DOT numbers, give us a call and we’ll walk you through what your state’s threshold is, what regulations they’ve adopted, and what needs to be done to keep your trucks legal & on the road.

So I Need a DOT Number. What’s Next?

If you haven’t yet obtained a DOT number, we’ll file it for you for free to ensure your application is filled out correctly the first time and help you avoid the overwhelming spam calls that new applicants get for weeks after filing.

Here’s another point of confusion:

Getting a DOT number is really just the first step in the process.

When you operate under a DOT number, that means you’re subject to any applicable safety regulations, even if you’re staying within your home state. While some states have altered the federal regulations when adopting them for intrastate-only carriers, many have copied the FMCSA’s federal requirements without amendments.

That means in many states:

• You’re required to maintain Driver Qualification Files for anyone who drives a vehicle with a GVWR/GCWR of 10,001lbs or more.

• You need to enroll any drivers who operate a CDL-required vehicle into a Random Drug & Alcohol Testing Program.

• You’ll need to register for the FMCSA Clearinghouse if you employ CDL drivers. You’ll also need to conduct Clearinghouse Queries to maintain compliance.

Lastly, several states also require some type of intrastate-only permit, often referred to as an “Intrastate Authority”. These are particularly important as civil fines for failing to register can reach into the tens of thousands depending on how long you operate without one.

Don't Risk It

At the end of the day, trucking is not the main function of your business, but it’s likely a core aspect of it. Failing to register for a DOT number, comply with safety regulations, or have a general understanding of your responsibilities when using commercial vehicles can lead to fines, vehicles being impounded, or worse; being placed out-of service.

That means even though trucking is not the core of your operation, it can easily be the sole reason your business comes to a screeching halt if you’re placed out-of-service.

The rules are simple: If you are a private company hauling your own property for your business, you very likely need a USDOT number. The requirement is triggered by your vehicle's weight and whether you operate in interstate commerce or in a state that requires it for vehicles like the ones you will be using.

To get a free consultation on whether you need a DOT number, what regulations may apply, and how to keep your business running smoothly without worrying about whether you’re doing what you’re supposed to, get in contact with us.

We’ve spent the last decade helping companies in your exact position understand what needs to be done, and help them get there as quickly as possible — we can help you too.