The 2022 membership renewals are hitting inboxes, which makes this the perfect time for the Association to reflect on how membership dues are critical in supporting the actions, services, and educational programming that NATM provides for its members and the light- and medium-duty trailer industry. NATM is constantly evaluating costs and benefits to ensure your annual membership investment is being met with valuable returns.
 
In 2021, membership dues allowed NATM to:

• Welcome Tow Vehicle OEM Members to the Association as a new membership type.
• Continue the Association’s 2019-2021 Strategic Plan focusing on industry growth, increasing brand awareness, and continuously improving the NATM Compliance Verification Program.
• Host a record-breaking number of educational webinars and presentations.
• Grow the reach of the fourth annual Trailer Safety Week, including the introduction of strategic partnerships and access to additional resources.
• Devote resources to marketing the NATM Compliance Verification Program and benefits of the Association to the industry as well as end-users to grow value of the NATM Compliance Decal.
• Educate members of Congress during the annual Regulatory Roundup and Capitol Hill Visits.
• Update the 2021 Guidelines for Recommended Minimum Manufacturing Practices for Light- and-Medium Duty Trailers, also known as the Guidelines.
• Host the 2021 Workforce Development Summit to assist members with their skilled worker shortage.
• Adapt the NATM Compliance Verification Program to navigate travel restrictions and protect the health and safety of members and staff, while also continuing to help member companies ensure their compliance with applicable federal regulation and industry standards.
• Continue offering the Association Health Plan (AHP) for most NATM member companies.
• Continue offering the NATM Association Retirement Plan for member companies to offer their employees.
• Launch a new online store for NATM members.

NATM’s commitment is to its members and ultimately to trailer safety. Supporting NATM members’ ability to grow and prosper, while also contributing to the safety of the nation’s roadways, is what drives the Association’s work. Your support of this mission and your integral feedback along the way is vital to NATM’s success. NATM looks forward to continuing this important work in the coming year!

2022 NATM Membership Dues
Your 2022 NATM membership renewal notice was mailed to the attention of your accounts payable department in November. For international members, invoices were emailed.

For 2022, Membership Dues are:

• Regular Members (Trailer Manufacturers): $995
• Branch Regular Members (Trailer Manufacturers): $325
• Associate Membership (Suppliers/Service Providers): $860
• Tow Vehicle OEM Membership (Automotive Manufacturers): $860
• Branch Associate Membership (Suppliers/Service Providers): $150
• Trailer Dealer Affiliates: $150

You have the option to renew your membership online at www.NATM.com. Log into the Members Only section to view and pay the invoice. Should you decide to pay online, please advise accounts payable to disregard the notice. Your membership login credentials are below.

Membership dues must be paid no later than January 31, 2022. Any dues not received by Jan. 31, 2022 will be considered delinquent, and all membership benefits will be terminated until paid per the NATM Bylaws.

For Trade Show Exhibitors, it is important to note that NATM DUES MUST BE PAID BY DEC. 31, 2021 to maintain the member rate for booths at the February 2022 Convention & Trade Show in Tampa, Fla. 
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Thank you for your continued support of the Association. Please don’t hesitate to contact Meghan Ryan, NATM Assistant Director, at (785) 272-4433 Meghan.Ryan@natm.com if you have any questions or concerns.

Membership renewal forms will begin to be mailed and delivered to members in November. In order to avoid a membership lapse, 2022 dues are to be paid by Jan. 31, 2022. Any dues not received by Jan. 31, 2022 will be considered delinquent and all membership benefits will be terminated until paid per the NATM Bylaws.

For trade show exhibitors, it is important to note that NATM DUES MUST BE PAID BY DEC. 31, 2021 to maintain the member rate for booths at the February 2022 Convention & Trade Show in Tampa, Fla.  

Membership dues for 2022 are as follows:  $860 for Associate (Supplier) members, $150 for Associate Branch members, $995 for Regular and International Regular (Trailer Manufacturer) members and $325 for Regular Branch members. If you joined between February and October of 2021, your 2022 dues will be prorated accordingly.

​If you have questions, including username and password information for the “Members Only” site, contact Catie Rutkowski, NATM Administrative Assistant, at (785) 272-4433 or Catie.Rutkowski@natm.com. 

​Fall is the time when members can volunteer for committee assignments for the upcoming year. Interest indicators are now available to all NATM Members are due back Dec. 15. The number of volunteers has grown every year and unfortunately, there are usually more volunteers for some committees than can be accommodated. All the committees meet by conference call, varying from monthly to quarterly.

If you want to get more involved and support the industry, please consider volunteering for a committee. NATM Committees are responsible for steering the work of the Association, guided by NATM’s mission and strategic plan. Committee members play a critical role in ensuring programming, benefits, and resources remain valuable to NATM members. Contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm.com for more information. Sign up before Dec. 15 to participate!

Click here to access the 2022 NATM Committee interest indicator. 
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Click here to access the 2022 Trailer Dealer Committee interest indicator.

NATM Committees & Objectives
Finance: The purpose of the finance committee is to plan and monitor the Association finances. Primary responsibilities include monitoring the annual budget and NATM investments, making recommendations as needed for change in revenue sources, and reviewing Finance Policies.
 
Membership: The purpose of the membership committee is to recruit, qualify and approve applicants for membership, ensure ongoing member satisfaction and continuously find methods of engagement with members.
 
Trailer Dealer: The purpose of the trailer dealer committee is to review and make improvements to the NATM Dealer Affiliate program and associated benefits.
 
Education: The purpose of the education committee is to develop annual educational programming to be delivered to NATM members through a variety of mediums including Convention workshops and webinars. The committee will recommend presenters and topics based on member needs and industry trends.
 
Convention: The purpose of the convention committee is to plan and oversee all activities of the Annual NATM Convention & Trade Show. The committee recommends speakers, workshop topics, and other events for consideration as well as develops plans to increase attendance and when needed, adopts policies governing the convention. 

Government Affairs: The purpose of the government affairs committee is to raise NATM's visibility among key government decision-makers and to advance NATM's position in order to proactively shape federal laws and regulations that may have a material impact on the light- and medium-duty trailer industry. The committee advocates these initiatives to members to recruit their assistance in educating and building relationships with Members of Congress. 
 
Technical: The purpose of the technical committee is to review, clarify and interpret technical and regulatory issues impacting the light- and medium-duty trailer industry. 
 
Technology: The purpose of the technology committee is to coordinate and serve as a forum for communication between tow vehicle manufacturers, component manufacturers, and trailer manufacturers, to better ensure that the technologies implemented are functional across vehicle types, makes, and models, for all parties involved as new technologies evolve and enter the market.
 
Compliance: The purpose of the Compliance committee is to oversee the general outline and enforcement policies of NATM’s Compliance Verification Program and review the Guidelines and recommend updates as required.

 Supply chain disruptions, material and component availability, and workforce shortages have caused the light- and medium duty trailer industry continued headaches. NATM recognizes the challenges and is curating the 2022 Convention & Trade Show to assist the industry’s success. The NATM Convention & Trade Show is the perfect one-stop shop for trailer manufacturers and dealers to meet with suppliers and service providers as they exhibit on the trade show floor. Looking for a new chain supplier? Interested in checking out new light options? Shopping around for new software to make life easier? If so, plan to walk the trade show floor and meet directly with suppliers and service providers in the industry! Educational events relevant to suppliers, trailer manufacturers, and dealers alike will be featured, including government affairs updates, a trade/tariff workshop, and information about addressing the workforce shortage. Stay tuned to the NATM Insider for updates about workshop topics. To sign up for the NATM Convention eNewsletter, visit www.NATM.com/convention.

The 2022 Convention & Trade Show is headed to the Tampa Convention Center in Tampa, Fla. Feb. 1-3, 2022. Florida
continues to be a popular location for NATM’s Convention & Trade Show as it boasts sunny weather and great sites for dinners with customers, golf outings, shopping, and family-friendly vacation activities. This will be the first time that Tampa has been the host location for NATM’s event, but it’s sure to be a favorite.

New Attendee Promotion
Are you a new member trailer manufacturer? Are you a trailer manufacturer member whose company has not attended in the last five years? Are you a Trailer Dealer Affiliate? You may qualify for NATM’s New Attendee Promotion!

The New Attendee Promotion includes two complimentary full registrations, two complimentary spouse/partner registrations, and up to two complimentary hotel room nights at the host hotel per company. Those interested in participating should contact NATM Assistant Director Meghan Ryan soon—complimentary hotel rooms are on a first-come, first-served basis and will go fast.

Registration Costs for Trailer Manufacturers
Registration will open online Sept. 13. Pricing for trailer manufacturers is as follows:
• NATM Member: Full Registration—$300
• NATM Member: Trade Show Only Registration—$100
• NATM Member: Top Golf Ticket—$75
• NATM Member: Spouse Full Registration—Free
• Non-Member: Full Registration—$600
• Non-Member: Trade Show Only Registration—$150
• Non-Member: Top Golf Ticket—$75

Note: registration fees will increase $50 after Jan. 30, 2022. Sign up early to save!

Hotel Room Reservations
For 2022, the NATM host hotels are the Tampa Marriott Waterside Hotel & Marina and the Embassy Suites by Hilton
Tampa Downtown Convention Center. The Tampa Marriott is conveniently located directly across the street from the Tampa Convention Center and has an NATM room block rate of $289/ night.

The Embassy Suites is also conveniently located directly across the street from the Tampa Convention Center and features a second level walkway directly to the convention center and a complimentary happy hour reception. NATM has negotiated a room block rate of $279/night.

To make your reservations at either hotel, visit www.NATM.com/convention.

Unauthorized third parties have begun contacting NATM Convention attendees about hotel reservations for NATM’s
2022 Convention & Trade Show. NATM advises that you do not engage or make reservations with any third-party group!

Trailer Manufacturer Sponsorships
Sponsorship opportunities are now available for trailer manufacturers interested in supporting the trailer dealer events
and programming. Trailer manufacturers can sponsor the New Dealer Promotion to sponsor dealers to attend the week of
events, as well as the Dealer Education & Luncheon. 

Stay tuned for more information about NATM’s 2022 Convention & Trade Show at www.NATM.com. Questions about registration, show sponsorship opportunities, or exhibit space? Contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm.com or call (785) 272-4433.

In 2019, NATM launched its Dealer Affiliate Program, a natural next step to further the mission of the Association as well as a direct response to requests from the NHTSA Administrator and trailer dealers across the country. NATM has been committed  to the light- and medium-duty trailer industry for more than 30 years, with its focus on the manufacture of compliant trailers, the safety of the nation’s roadways, and the unification of the industry. The incorporation of dealers into the Association is vital to the continuance of these efforts. 

The Association took Dealer Affiliate involvement a step further with the creation of a Trailer Dealer Affiliate Committee. This will help ensure NATM continues to deliver value that aligns with dealer needs as well as manufacturer and supplier needs. The Dealer Affiliate Committee will help guide program expansion in the coming years and serves as another opportunity to unify the industry and improve trailer safety. 

NATM is looking for trailer dealers to participate on the NATM Trailer Dealer Affiliate Committee to better understand what
dealers want and need from their Association. The objectives of the committee include reviewing current benefits and making recommendations for improvement and expansion; review and submit content suggestions to the NATM Dealer Compendium; provide feedback on marketing and recruitment efforts of dealers; recommend educational programming; and participation in NATM’s annual Trailer Safety Week.

​NATM encourages all dealers to consider participating and have their voice heard. For more information regarding the Trailer Dealer Affiliate Committee, contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm.com or call (785) 272-4433.

NATM is pleased to announce the launch of the NATM Online Store! In line with the Association’s mission and the 2019-2022 Strategic Plan, NATM is excited to provide members with relevant educational information that’s easily accessible.

*If you have already created a NATM Resource Library username and password simply login with the same credentials to gain access to the NATM Online Store.

 Since 1992, the National Association of Trailer Manufacturers (NATM) has annually published the Guidelines for Recommended Minimum Manufacturing Practices for Light- and Medium-Duty Trailers, otherwise known as the Guidelines. These updates are researched and compiled by NATM Staff, NATM Members, and NATM’s committees with approval by NATM Staff, and the NATM Compliance Committee. One drawback to the annual update process is only updating once a year. Members are required to wait until each new edition to gain any new or edited information. Starting this year, NATM will periodically update its membership on upcoming changes for the next edition of the Guidelines via Tracks magazine, social media, and NATM Tech Talk, a brand-new electronic newsletter keeping you up to date on all things technical and compliance. Sign up for this newsletter and more at www.NATM.com/email.

The intention of these general updates is not to provide an official new version of the Guidelines, provide a full context, or provide immediate changes, but to notify members of the upcoming changes so they may be prepared and take action if needed. Contact NATM Technical Director Terry Jones at Terry.Jones@natm.com or call (785) 272-4433 for more information.

Upcoming Changes

Section B11 – VIN / Data Plates and Manufacturer Information

The addition of:

• 49 CFR § 567.1 Purpose
• 49 CFR § 567.2 Application
• 49 CFR § 567.3 Definitions
• 49 CFR § 567.5 Requirements for manufacturers of vehicles manufactured in two or more stages.
• 49 CFR § 567.6 Requirements for persons who do not alter certified vehicles or do so with readily attachable components.
• 49 CFR § 567.7 Requirements for persons who alter certified vehicles.

Purpose:
Manufacturers may have additional requirements based on the type or stage of manufacturing they participate in, and the
addition of these regulations will assist in navigating these requirements.

Appendix 2 – Quick Guide and Checklist

The addition of:
Checklist question: 7.41 Underride properly labeled on the forward or rear of the underride, including the manufacturer’s
name and address, date of manufacture statement, and DOT marking.

Correlating Quick Guide information:

The addition of:
S5.3 Labeling. Each guard shall be permanently labeled with the information specified in S5.3 (a) through (c) of this section.  The information shall be in English and in letters that are at least 2.5mm high. The label shall be placed on the forward or rearward facing surface of the horizontal member of the guard, provided that the label does not interfere with the retroreflective sheeting required by S5.7.1.4.1(c) of FMVSS No. 108 (49 CFR 571.108), and is readily accessible for visual inspection.

• The guard manufacturer’s name and address.
• The statement: “Manufactured in ____” (inserting the month and year of guard manufacture).
• The letters “DOT”, constituting a certification by the guard manufacturer that the guard conforms to all requirements of this standard.

Purpose:
Information on rear underride labeling and enforcing existing federal regulation which requires specific labeling of the rear
underride guard and aligning the Compliance Verification Program with federal regulation.

For more information on these changes, the Guidelines, or any other technical or compliance issue, contact NATM Technical Director Terry Jones at Terry.Jones@natm.com or (785) 272-4433.

Supply chain disruptions, material and component availability, and workforce shortages have caused the light- and medium duty trailer industry continued headaches. NATM recognizes the challenges and is curating the 2022 Convention & Trade Show to assist its industry’s success. The NATM Convention & Trade Show is the perfect one-stop-shop for trailer manufacturers and dealers to meet with suppliers and service providers as they exhibit on the trade show floor.

​Looking for a new chain supplier? Interested in checking out new light options? Shopping around for new software to make life easier? If so, plan to walk the trade show floor and meet directly with suppliers and service providers in the industry! Educational events relevant to both suppliers and trailer manufacturers alike will be featured, including government affairs updates, a trade/tariff workshop , and information about addressing the workforce shortage. Stay tuned to www.NATM.com and the NATM Insider for updates about workshop topics.
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Host Location
The 2022 Convention & Trade Show is headed to the Tampa Convention Center in Tampa, Fla. Feb. 1-3, 2022. Florida continues to be a popular location for NATM’s Convention & Trade Show as it boasts sunny weather and great sites for dinners with customers, golf outings, shopping, and family-friendly vacation activities, but this will be the first time that Tampa has been the host location for NATM’s event.

The Tampa Convention Center is located along the Riverwalk in the heart of downtown and will serve as the site of educational workshops, networking events, and the trade show. Attendees of the show can access the NATM special room block rates at the Embassy Suites by Hilton Tampa Downtown Convention Center and the Marriott Tampa Waterside. More information will be provided via the NATM Insider newsletter and email. To sign up for the NATM Insider, contact NATM Marketing Director Savana Morrison at Savana.Morrison@natm.com.

Booth Selection
Trade show space opened to the 2020 Sponsors starting June 1. Following sponsors, companies that chose to roll their 2021 booth funds over to 2022 began to select their spaces July 6. The opportunity to select space for the general membership will begin Aug. 4, and non-members can select booths starting Aug. 18.

Sponsorships
As always, the NATM Convention & Trade Show would not be possible without the support of its generous sponsors. There are sponsorship opportunities available from $500 to $50,000 to fit any budget. Being a sponsor allows you to select your booth before previous exhibitors and the general membership, as well as provides a wide range of exposure, both electronically on NATM’s website and mobile app and in print on the convention program map and branded events. This creates name recognition which helps drive customers to your booth. Watch your email for sponsorship information coming in May.

New Attendee Promotion
Are you a new member trailer manufacturer? Are you a trailer manufacturer whose company has not attended in the last five years? Are you a Trailer Dealer Affiliate? You may qualify for NATM’s New Attendee Promotion! The New Attendee Promotion includes two complimentary full registrations and up to two complimentary hotel room nights at the host hotel for the convention. Those interested in participating should contact NATM Assistant Director Meghan Ryan soon— complimentary hotel rooms are on a first-come, first-served basis and will go fast.

Stay tuned for more information about NATM’s 2022 Convention & Trade Show at www.NATM.com. Questions about the show sponsorship opportunities or exhibit space? Contact Meghan Ryan at Meghan.Ryan@natm.com or call (785) 272-4433.

NATM is soliciting nominations for awards to be presented at the annual NATM Convention & Trade Show Feb. 1-3, 2022 at the Tampa Convention Center in Tampa, Fla. Please consider and nominate individuals who may be eligible candidates for the following awards.

The Outstanding Member Award is presented each year to an individual who has made a significant contribution to the trailer manufacturing industry. The nominee must be an employee of an NATM Regular (trailer manufacturer) Member. The nomination must include the name and address of the nominee and nominator along with a brief narrative about the
contributions the nominee has made to the trailer manufacturing industry.

The Pam O’Toole Trusdale Woman in Manufacturing Award is given to a woman from the manufacturing floor to the C-Suite in the light- and medium-duty trailer industry who has demonstrated excellence in their role. The award recognizes the contribution of the recipient to the success of their organization and/or industry. The nominee must be an employee of an NATM Member company.

The nomination must include the name and address of the nominee and nominator along with a brief narrative about the
accomplishments of the nominee.

The purpose of the Young Professional Award is to recognize the accomplishments of young individuals in the trailer
manufacturing industry. Nominees should be individuals under the age of 40, who have been innovative and successful in the trailer manufacturing industry. Both Associate and Regular member company employees are eligible for this award.

The nomination must include the name and address of the nominee and nominator along with a brief narrative about the
accomplishments of the nominee.

The Innovation Award is open to member companies that exemplify creativity and innovation in the areas of technological
advancement, green practices, or workforce development. Applicants for the award must submit a written description of the company’s innovative practices, including both qualitative and quantitative evidence of success. This award is open to all NATM Members and will include a charitable donation made in the company’s name.

Awards will be presented at the Annual Awards Luncheon on Tuesday, Feb. 1, 2022. To request the award nomination form, contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm or (785) 272-4433. Nominations are due by Nov. 30, 2021.

NATM headquarters receives frequent questions from trailer dealers and end-users about state troopers and local enforcement officers pulling over towed trailers the drivers thought did not require a commercial driver's license (CDL). Is this a result of overly-diligent law enforcement at work? Or a lack of awareness regarding CDL laws? Perhaps a combination of both?
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What appears to be behind these inquiries is the vagueness of the CDL laws and the general confusion and disagreement this vagueness naturally generates. So, let’s try to clear up some of this confusion. Congress has charged the U.S. Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) with responsibility for implementing the federal CDL laws through federal regulations and has directed the states to issue CDLs in conformity with these regulations. The FMCSA’s CDL regulations appear in the Code of Federal Regulations, 49 C.F.R. Part 383. The FMCSA requires drivers to have a CDL—either a Class A, Class B, or Class C (for transporting passengers or hazardous materials)—in order to operate defined types of commercial motor vehicles (CMVs) in interstate, intrastate, or foreign commerce.

To clarify its regulations, the FMCSA publishes a graphic illustrating the various vehicle configurations constituting the groups of CMVs requiring a Class A or Class B CDL. That graphic can be found to the left. State and local law enforcement often refer to it for guidance.

The FMCSA requires drivers to have a CDL to operate a motor vehicle if that vehicle meets the FMCSA definition of a “commercial motor vehicle” and is used in “commerce.” The FMCSA defines both terms in this two-part requirement in 49 C.F.R. § 383.5. The great misunderstanding out there, within the trailer industry and perhaps within the law enforcement community, about the CDL requirements springs from those two definitions, particularly the word “commerce.”

The FMCSA defines a “commercial motor vehicle” as a motor vehicle, or a combination of motor vehicles, in certain GVWR-based configurations, when used in “commerce” to transport “property or passengers.” The physical configuration component of the CMV definition is very mechanical, very objective. When dealing with a tow vehicle-trailer combination, you look at the gross combination weight rating (GCWR) of the tow vehicle if the tow-vehicle manufacturer has assigned it a GCWR and displays it on its certification label. With respect to the familiar combination, a tow vehicle (whether truck, automobile, or tractor) towing a trailer, the driver needs a CDL if the tow-vehicle manufacturer’s assigned GCWR exceeds 26,000 lbs. (as shown on its cert. label) and the trailer’s gross vehicle weight rating (GVWR) exceeds 10,000 lbs. If there is no assigned GCWR, the FMCSA regulations require the driver to have a CDL only if the sum of the GVWRs of the tow vehicle and the trailer together exceeds 26,000 lbs. and the trailer’s GVWR exceeds 10,000 lbs. In either scenario that satisfies the definition of “commercial motor vehicle,” the driver will need a Class A CDL, assuming the trailer’s use also satisfies the second component of the CDL requirement, “used in commerce,” as discussed below.

With respect to a single vehicle, the FMCSA requires the driver to have a Class B CDL to operate that truck, bus, van, or automobile in commerce if that vehicle has a GVWR of more than 26,000 lbs. It is required even if that vehicle is a power unit (truck, automobile, or van) and is towing a trailer with a GVWR of 10,000 lbs. or less. If the trailer’s GVWR exceeds 10,000 lbs., a Class A CDL is needed if its use also satisfies the second prong of the CDL requirement.

The second prong of the CDL requirement, and of the CMV definition, is much more troubling, much more subjective, and the primary source of the confusion. To qualify as a CMV requiring a CDL, that vehicle, even in a qualifying GCWR/GVWR configuration, must be used in “commerce.” “Commerce” has its own separate definition in § 385.3 of the FMCSA’s regulations. The FMCSA defines it broadly as any trade, traffic, or transportation between points in one state and points in another state or any trade, traffic, or transportation that “affects” trade, traffic, or transportation in the U.S. between points in one state and points in another. Not exactly an enlightening definition, to say the least. How this “use” assessment turns out often varies depending upon who is doing the assessing. And that is often the law enforcement officer on the scene.

As a starting point, the proper inquiry, then, is whether this questionable CMV is transporting property (across state lines) for some commercial purpose, as opposed to for the personal use of the owner, driver, or some other person. What the trailer owner considers his or her own “personal use” may in fact, upon close examination, turn out to be for a “commercial purpose” when viewed through the critical eyes of the state or local law enforcement officer. Let’s examine several tricky examples:

1. The trailer owner is towing his own horses to a horse show or his livestock to the state fair where monetary prizes are awarded. That familiar scenario is likely to be categorized as a commercial undertaking or commercial purpose from the vantage point of the diligent state trooper who pulls over the driver looking for that CDL.
2. Suppose instead those horses belong to a stable whose owner charges the public by the hour to ride them. Another commercial purpose according to a strict interpretation of the term. It does not matter that no business name or logo is displayed on the side of the truck or trailer towing these horses.
3. Now suppose it is a college student behind the wheel of Dad’s 16,000 lbs. GVWR truck towing his family’s lawn mower around the neighborhood in Dad’s utility trailer to earn a few bucks mowing lawns to off -set that college tuition. He is likely to need a Class A CDL if that trailer’s GVWR exceeds 10,000 lbs. Remember, this is in intrastate commerce—see below for discussion of further complication.

Complicating the question of whether a CDL is necessary are a hodge-podge of state CDL laws, many of which are at variance with the federal law that FMCSA has issued. States are not prohibited from enacting their own state CDL laws, applying them to non-interstate movements (i.e. the trailer does not cross the state line), if those state laws are stricter than the federal law. In theory, the state law of State A might require its residents to have a different class of CDL, perhaps designated as a “Class D,” to tow a 26,000-lbs. GVWR trailer when used for personal use. In the third “tricky example” above, even if the student does not need a CDL under federal law to haul his lawn mower (because the trailer’s GVWR is less than 10,000 lbs.), he may need one anyway because the state law of the state where he resides requires one even to pull a light-duty trailer.

State A must, however, honor the out-of-state driver’s license issued by State B to its residents: for example, if State B does not require a CDL for its residents to operate a vehicle for personal use, then State A may not require a State B resident to have a CDL while operating a vehicle for personal use in State A even if State A requires its own residents to have a “Class D” CDL for this purpose.

The CDL complaints that NATM fields typically revolve around the smaller, medium-duty trailers (between 10,000 lbs. and 26,000 lbs. GVWR) and the debate over personal use vs. commercial use. In sum, assuming commercial use, when the GVWR of the truck exceeds 26,000 lbs., a CDL is required, regardless of the GVWR of the trailer, and when the GVWR of the truck is less than 26,000 lbs., a CDL is required only if (1) that truck’s GVWR and the trailer’s GVWR, added together, exceed 26,000 lbs. and (2) the trailer’s GVWR exceeds 10,000 lbs.

Dealers should be prepared to provide that objective guidance about what tow vehicle-trailer configurations may need a CDL when asked by their customers, but they would be well advised to stay away from declaring, when asked, that the customer’s intended end-use of the trailer meets or does not meet the FMCSA definition of “used in commerce.” This precaution is especially warranted if the trailer’s intended use, as described by the owner, falls within the murky, gray area of personal vs. commercial use or the dealer is unsure about the niceties of the state CDL laws that might apply. It is also important for the dealer to keep in mind that a trailer’s use might be “personal” on one or more trips but “in commerce” on others. Better that the driver have that CDL and not need it than not to have one when stopped and forced to try to explain to the officer that this “trip” is really only a “one-off ,” a rare exception to his usual personal use.