A. ELD compliance is tied primarily to the activities of the driver. If the drivers of these vehicles are already required to prepare a record of duty status (RODS) using a paper logbook and drive more than 8 days during a 30-day period, then it is highly likely that you will have to equip these vehicles with an ELD.
However, if the drivers of these vehicles are not currently required to prepare a RODS and/or have to prepare a RODS but drive less than 8 days during a 30-day period, then they may be exempt under the new ELD rule and you will likely not have to equip the vehicles with an ELD.
In addition, the vehicles may be exempted from the rule if they are older than model-year 2000.
Since your question is related to ELD compliance, your best course of action is to contact the FMCSA directly or consult your company’s legal department. As this question illustrates, ELD compliance has numerous complexities that often require expert legal advice to answer fully.