Are you a cargo van operator or thinking of becoming one?
If yes, you need to make sure you are operating your cargo van business legally and in the right way.
That’s because there are a host of rules and regulations that you may be subject to if you operate your cargo van for commercial purposes. Many of these laws fall within the purview of the Federal Motor Carrier Safety Agency (FMCSA) and the Department of Transportation (DOT).
What We’ll Cover
I’ll go over some of the most significant laws and ordinances that apply to commercially operated cargo vans in this article.
I will be focusing, in particular, on rules issued by the DOT and FMCSA ( which is the division of the DOT in charge of lowering collisions, injuries, and fatalities involving heavy trucks and buses).
The Short Answer
If you are looking for a quick answer to what’s required, here is a summary of the DOT regulations you should be considering:
If you operate a cargo van for commercial purposes, some (or all) of the following regulations may apply to you:
- Commercial driver’s license (CDL)
- DOT operating authority (e.g., a US DOT number and motor carrier (MC) number)
- Medical Examiner’s Certificate (aka DOT medical card)
- BOC-3 (for service of process)
- Drug and alcohol testing
Many of these regulations depend on how heavy your cargo van (and associated freight) is, whether you are crossing state lines, and the type of freight you are transporting.
We’ll get into a lot more detail on all of that later.
Links to Each Section
To help you navigate the article, below is a list of topics we’ll address. If you have a burning question in a specific area, just click on the corresponding link below.
Operating Authority (US DOT Number and Motor Carrier (MC) Number)
We’ve got a lot to cover, so let’s get into it!
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1. Obtain Commercial Driver’s License (CDL)
Ok – one of the key questions you want to answer is whether you need a commercial driver’s license to operate a cargo van.
In most cases, the answer is going to be no. But there are exceptions.
According to the FMCSA, you will need a CDL if you meet the following:
You engage in interstate, intrastate, or foreign commerce and operate a vehicle that meets any of the following:
Class A: Any combination of vehicles which has a gross combination weight rating or gross combination weight of 26,001 pounds or more, inclusive of a towed unit(s) with a gross vehicle weight rating or gross vehicle weight of more than 10,000 pounds.
Class B: Any single vehicle which has a gross vehicle weight rating or gross vehicle weight of 26,001 pounds or more, or any such vehicle towing a vehicle with a gross vehicle weight rating or gross vehicle weight that does not exceed 10,000 pounds.
Class C: Any single vehicle, or combination of vehicles, that does not meet the definition of Class A or Class B, but is transporting material that has been designated as hazardous under federal law or designed to transport 16 or more passengers, including the driver.
Because most cargo vans are going to weigh far less than 26,000 lbs. (even including freight and towed units), the driver won’t need a CDL to operate it.
For example, the gross vehicle weight rating for a 2023 Ford Transit Cargo Van ranges between 8,670 lbs. to 11,000 lbs. and maximum payloads range from 3,060 to 5,110 lbs. Source: Ford
Notable exceptions to this general rule include if you are using a vehicle that is designed to transport passengers (not likely since we are talking about cargo vans here and not passenger vans) or are hauling freight that includes hazardous materials.
If you want more info on CDL requirements, check out the FMCSA page on the topic.
2. Obtain Trucking Authority from DOT
US DOT Number
According to the FMCSA, if you plan on engaging in interstate commerce (this generally means you are delivering across state lines) and your vehicle meets certain weight requirements (generally more than 10,000 lbs.) then you will need a USDOT Number.
But, even if you just want to operate in your state, certain jurisdictions still demand that you have a USDOT number, so you should research the regulations in your state on this.
A word of warning – unlike CDLs, you may be subject to this law because cargo vans can weigh more than the ten thousand pound limit (as we just demonstrated in our Ford Transit example).
So, if you don’t want to be subject to this law, you must ensure that your specific model of cargo van (as well as the loads you decide to transport) won’t result in its application.
You may also need what is called a Motor Carrier (or MC) number. This is only required if you plan on engaging in interstate commerce, you don’t own the freight you are moving, and you will be receiving a fee for transporting the freight.
To learn more about MC numbers, check out the FMCSA website on the topic.
Another critical component of getting your own authority is insurance. The FMCSA mandates specific insurance coverage if you are applying to obtain your own authority.
Here are the general requirements:
$750,000 – $5,000,000 of public liability insurance coverage for transporting freight, depending on the type of cargo that is being moved.
That goes down to $300,000 if you are moving non-hazardous freight in vehicles weighing under 10,001 lbs.
If you are moving household freight, you must have cargo insurance too ($5,000 per vehicle; $10,000 per occurrence.
Check out the FMCSA’s website on the topic here if you want to learn more.
Designate Agents For Service of Process (BOC-3)
If you are operating under your own authority, you will need to file a BOC-3. It basically lists out who may receive legal documents on your behalf (i.e., if you need to get served a complaint, etc.).
According to the DOT, an agent must be designated for each state in or through which the carrier operates. This is so that if a claim is made against the carrier, they can be served in that state, even if the carrier does not reside there.
Here’s a list of various process agents you can use to fill out your BOC-3 form, courtesy of the DOT. These process agents all have wide coverage, so no worries on that front.
3. Obtain DOT Medical Card
According to the FMCSA, all commercial drivers who operate vehicles in interstate commerce with a maximum gross vehicle weight rating of over 10,000 pounds are required to obtain and keep a current Medical Examiner’s Certificate (ME Certificate).
So you may need to get this if your cargo van meets these requirements.
Additional requirements may apply for CDL operators. Source.
If you are operating a CMV in this way, you will need to pass a Department of Transportation (DOT) physical and receive a medical card. This signifies that you are physically capable of handling the work required for this type of activity.
The exam must be conducted by a licensed medical examiner listed on the FMCSA National Registry. You can use this tool provided by the FMCSA to find a qualified medical examiner near you.
4. Comply With Hours of Service (HOS)
Most CMV drivers must comply with hours of service (HOS) requirements. Source: FMCSA,
This is for everyone’s safety – you don’t want exhausted truckers on the road.
In their Q&A’s, the FMCSA defined a CMV as a vehicle that is used as part of a business and is involved in interstate commerce and fits any of these descriptions (I have omitted categories that don’t apply to cargo van operators):
- Weighs 10,001 pounds or more
- Has a gross vehicle weight rating or gross combination weight rating of 10,001 pounds or more
- Is transporting hazardous materials in a quantity requiring placards
So, if your cargo van meets these thresholds, then you will need to comply with HOS standards. At a high level, the requirements are as follows:
- You can’t drive for more than 11 hours after 10 hours off duty,
- You get a 14 hour window for driving after 10 hours off duty,
- You must take a 30 minute driving break if you’ve driven for 8 straight hours
- You have a 60/70 hour limit in 7/8 consecutive days
The driver must also maintain a log book that tracks their status (driving, off duty, sleeper berth, on duty but not driving). Generally, you have to do this using an ELD (which stands for an Electronic Logging Device), but there are some exceptions. Source
Note: There is a short haul exemption to the HOS rule that may apply for certain operators doing shorter loads. A driver is exempt from certain HOS requirements if the driver operates within a 150 mile radius of the normal work reporting location and the driver does not exceed the maximum duty period of 14 hours.
Because cargo van truckers often operate exclusively within a small radius (i.e. urban areas) due to the vehicle’s easy maneuverability, this exception may apply to you.
If you want a more detailed description of Hours of Service requirements, check out the DOT’s summary of the topic here.
5. Driver Vehicle Inspection Reports (DVIRs)
The FMCSA requires that drivers conduct pre and post-trip inspections of their vehicles (again, your cargo van set up may not apply).
This includes inspections of things such as your service brakes, parking brake, lighting devices and reflectors, coupling devices, wheels and rims, steering systems, horn, wipers, mirrors, emergency equipment (e.g., fire extinguisher, fuses, flares, etc.) and so on.
For more details on what needs to be in the DVIR , check out the FMCSA rules here.
6. UCR Compliance
What is UCR?
The Unified Carrier Registration (or UCR) is a federal program that requires those involved in interstate travel to pay an annual registration fee based on the total number of vehicles in their fleet.
It replaces the old Single State Registration System (SSSR). Source.
Who is subject to UCR?
If you are a carrier operating a commercial vehicle that weighs more than 10,000 pounds, placarding amounts of hazardous materials, or transporting more than 10 passengers (including the driver) across interstate lines, then you will be subject to UCR.
Here’s a link to a decision tree provided by the UCR organization which can help you figure out if this applies to you.
How Do I Comply with UCR?
If you are subject to the UCR, you will need to register with them (and of course pay the applicable fee). You can start the process by going to the official UCR website here.
So there you have it – 7 key regulations that apply to you as a cargo van operator. Hope this has been helpful and happy trucking!