US DOT Numbers: What Tow Operators Must Know

It seems like the towing industry faces new regulations daily, and while that is an exaggeration, there are some regulations that get fresh scrutiny after something happens to trigger a renewed interest from regulators. The US DOT number is one such item facing renewed interest due to a sharp rise in fraud related to fake motor carriers or legitimate motor carriers having their id stolen by bad actors.

What is a US DOT number?

Any business that uses commercial motor vehicles to engage in interstate commerce, meaning their trucks with a Gross Vehicle Weight Rating (GVWR) greater than 10,000 pounds, or the freight they haul (including cars), crosses a state or international border is required to register with the Federal Motor Carrier Safety Administration, which in turn issues a unique identification number that is then required to be displayed on all their power units used in interstate commerce. Many states also require anybody that operates a commercial motor vehicle to obtain a US DOT number even if they only operate intrastate, meaning their trucks, nor the freight they haul, ever cross a state or international border.

Do I Really Need One?

For most towing companies the answer is yes. This is because most of the tow trucks on the road today are at least 14,500 GVWR, with many well over that, and we routinely tow vehicles that are coming from out of state, will be going out of state after they are repaired, or we cross state lines ourselves. This is known as “interstate commerce” and, as such, requires at least a US DOT registration number.

Just because the vehicles are wrecked or disabled does not relieve the towing company of its obligation to register with the US DOT before engaging in interstate commerce. While wrecked or disabled vehicles, when towed from their primary point of disablement (where they first broke down or were wrecked) are exempt commodities, that exemption only applies to the operating authority portion of the federal regulations and some specific hours of service rules when towed at the request of law enforcement.

Types of US DOT Numbers

There are three classes of US DOT registration that apply to towing operations.

-- Private Motor Carrier of Property – Is exclusively for companies that only haul their own cargo or vehicles, i.e., if a product manufacturer owned trucks and hauled exclusively their own products, they would be a private motor carrier.

-- Exempt For-Hire Motor Carrier of Property – Hauls exclusively exempt commodities, which can include wrecked or disabled motor vehicles when only hauled form the place where they first broke down or were first wrecked.

-- Authorized For-Hire Motor Carrier of Property – Hauls stuff that is not exempt and belongs to other for compensation. This would include toolboxes, machinery, vehicles to the auction or other transport work.

What About Motor Carrier Authority?

If you haul anything other than exempt commodities, which are usually low value or unprocessed stuff like waste, rocks, dirt, etc., you will most likely need to obtain operating authority. Moving toolboxes, construction equipment, forklifts, sheds or even wrecked cars to the salvage auction usually requires operating authority in addition to a valid US DOT number.

There are two types of authority to investigate, interstate and intrastate. If the stuff you haul is coming from out of state, or going out of state, then you probably need for-hire interstate motor carrier of property authority from the FMCSA. This is commonly called an MC number, and can be obtained by applying to the FMCSA and obtaining the required insurance filings.

If your trucks, and the stuff they haul, never leave the state or country, and the final destination is not out of state or the country, then you are most likely an intrastate motor carrier of property. Each state regulates this differently, but most control this work through the Public Utility Commission or the Department of Motor Vehicles. Check with your state to see what, if any, registration and authority documents may be needed.

Why is Auto Transport Almost Always Interstate Commerce?

Those of you that haul for the auto auctions such as Adesa, Manheim, Copart or IAA may have noticed a recent trend is requiring you to have a US DOT number and/or interstate operating authority to renew or keep your contracts.

Vehicles going to or coming from the auctions are usually interstate in nature because of how the auctions market these vehicles to buyers globally. As such, the intent of their marketing effort is to sell the vehicle to any buyer, local or foreign, and as such, the intent of the shipment of the vehicle to or from the auction can be considered interstate in nature. This means; to legally provide transport services to these auctions, you must be registered as a for-hire interstate motor carrier of property.

The FMCSA is very clear in their guidance that automobiles, including wrecked and disabled vehicles going to or from an auction, are not exempt commodities. The companies that haul these vehicles must be fully qualified interstate motor carriers if the movement is interstate in nature.

It is a best practice for these auctions to require all transporters to be fully qualified interstate motor carriers since the nature of each vehicle hauled can vary and it would be a logistical nightmare to figure out if each vehicle was part of an interstate or intrastate regulated shipment before selecting a contractor to dispatch it to. They are simply staying on the side of caution to avoid any regulatory issues they may face by dispatching unqualified transporters.