EXEMPT-COMMODITY HAULER — USDOT ONLY
Exempt-commodity carriers — what to do after getting your USDOT number
For-hire but hauling exempt goods — no MC authority needed. Because the commodities you haul are exempt, you do not need MC operating authority, a BOC-3, or FMCSA insurance on file — but you still register for UCR, run the full drug & alcohol compliance program, and register your vehicles (IRP/IFTA/2290).
Your checklist as a exempt-commodity hauler
These are the steps the engine includes for this authority type. Items marked “Vertical Identity” are handled by us when you enroll. Steps that don’t apply to this type are automatically left off.
Activate your authority
Register for UCR
UCR's site makes DIY easy — do it yourself there, or we'll handle it. Fees = official UCR schedule.
When:Annual; before interstate operation.
Source: 49 U.S.C. §14504a · reviewed 2026-06-14
Get compliant to operate
Join a drug & alcohol consortium (C/TPA)
Owner-operators MUST be in a consortium for random testing — you can't self-administer. We are your C/TPA.
When:Before any driver performs a safety-sensitive function.
Source: 49 CFR §382 · reviewed 2026-06-14
Pass a pre-employment drug test
The test must be passed — not just taken — before driving. We order it.
When:Negative result REQUIRED before the first dispatch.
Source: 49 CFR §382.301 · reviewed 2026-06-14
Register + query the FMCSA Clearinghouse
Login.gov steps are yours; we run the queries as your TPA.
When:Full query pre-employment; limited query annually.
Source: Clearinghouse final rule · reviewed 2026-06-14
Build your Driver Qualification File
Even a solo owner-operator needs a DQF on themselves. We manage it.
When:Before driving; MVR within 30 days of hire + annually.
Source: 49 CFR §391.51 · reviewed 2026-06-14
DOT medical card (physical)
Required to hold a CDL for interstate non-excepted driving. We perform the physical.
When:Valid up to 24 months — can be shorter. Renew before expiry.
Source: 49 CFR §391.41–.49 + §383.71 · reviewed 2026-06-14
Written drug & alcohol policy
A written policy is required. We provide one per DOT mode.
When:Provided to drivers before they drive.
Source: 49 CFR §382.601 · reviewed 2026-06-14
Supervisor reasonable-suspicion training
60 min drugs + 60 min alcohol for anyone making reasonable-suspicion calls. We train them.
When:Before the DER/supervisor supervises drivers.
Source: 49 CFR §382.603 · reviewed 2026-06-14
Register your truck
File IRS Form 2290 (HVUT)
Vehicles ≥55,000 lb. E-file returns a stamped Schedule 1 in minutes — do it yourself at IRS.gov.
When:Before plating (Schedule 1 required to register).
Source: IRS Form 2290 · reviewed 2026-06-14
Register IRP apportioned plates
Multi-state operation. File through your base state — link below for each state you picked. Apportioned plates are about the VEHICLE running interstate, not about holding MC authority — private and exempt-commodity carriers (USDOT-only, no MC) register IRP too.
When:After authority is active; needs your base state.
Source: IRP / base-state · reviewed 2026-06-14
Get your IFTA license + decals
Qualified vehicles in 2+ jurisdictions. Issued by your base state.
When:Before interstate operation; quarterly returns after.
Source: IFTA · reviewed 2026-06-14
Pass your New Entrant Audit
Pass your New Entrant Safety Audit
The #1 automatic failure is having no drug & alcohol program. Stay enrolled and you pass.
When:Within 12 months of starting operations.
Source: 49 CFR §385 subpart D · reviewed 2026-06-14
Core regulatory sources: 49 CFR §382 — drug & alcohol testing · 49 CFR §385 subpart D — New Entrant Safety Audit · last reviewed 2026-06-14
Frequently asked questions
What is an exempt-commodity carrier?
An exempt-commodity carrier hauls goods for hire that federal law exempts from economic regulation (for example certain unprocessed agricultural products). Because the commodity is exempt, the carrier needs a USDOT number but not MC operating authority. Whether your specific commodity qualifies as exempt should be verified with FMCSA.
Do exempt carriers still need a drug and alcohol program?
Yes. The drug and alcohol testing requirements under 49 CFR Part 382 apply based on operating a CMV with a CDL driver — not on whether the commodity is exempt. Owner-operators must enroll in a consortium and pass a pre-employment test before first dispatch.
Does the New Entrant Safety Audit apply to exempt carriers?
Yes. FMCSA audits new carriers within 12 months of starting operations under 49 CFR §385 Subpart D, regardless of whether the commodity is exempt. The most common automatic failure is not having a drug and alcohol testing program in place.
Stay audit-ready hauling exempt commodities
We run your drug & alcohol program, Clearinghouse queries, and driver qualification files.
Enroll in the consortiumThis is general guidance, not legal advice. Verify requirements with FMCSA and your state DOT.