Does the IRP Apply to Smaller, Commercial Vehicles?

Motor carriers that operate smaller commercial motor vehicles are subject to several areas of safety compliance. But are these same vehicles under the umbrella of operations requirements, such as the International Registration Plan (IRP)?

You may be surprised to learn the answer is “maybe.”

Carriers must differentiate between the International Fuel Tax Agreement (IFTA) and IRP since they are often grouped together. Fuel tax filing is not required for trucks with two axles weighing under 26,001 gross or registered gross weight.Registration requirements, on the other hand, are based on individual state rules.

Who is Subject to the IRP?

A qualified vehicle under the IRP is one that is used in interstate commerce and meets any one of these criteria:

• A vehicle that has two axles and a gross vehicle weight or registered gross vehicle weight exceeding 26,000 pounds (11,793.401 kilograms);
• A vehicle or power unit that has three or more axles regardless of its weight; or
• A combination when the weight of such combination exceeds 26,000 pounds (11,793.401 kilograms) gross vehicle weight.

Smaller Vehicles & the IRP

Carriers operating two-axle vehicles weighing less than the weights listed above may still choose to register their vehicles under the IRP but do not have to do so.

Why would a carrier register if not required?

Some states require trip permits for two-axle vehicles weighing 26,000 pounds or less to travel interstate or intrastate, but some do not.

However, keep in mind that if a vehicle has three or more axles counting axles on the power unit or truck only, it is subject to the IRP — regardless of its weight.

Trip Permits vs. IRP Registration

As mentioned earlier, some states may require trip permits to operate vehicles weighing 26,000 pounds or less in their states. Permits may be required for traveling through the state and/or if engaging in intrastate transportation within a state.

For example, Alabama does not require either intrastate or interstate permits. In contrast, Minnesota requires an intrastate permit but not an interstate permit, and Kansas requires a permit for both interstate or intrastate vehicles weighing over 12,000 pounds.

Your decision on registering with the IRP should be based on the states in which you operate and frequency of operation. If trips are infrequent, then trip permits may be best. However, if frequently operating in states that require trip permits, it may be best to obtain IRP credentials for your vehicles weighing 26,000 pounds or less.

What if You Register with IRP?

Motor carriers that register with the IRP are subject to specific recordkeeping that helps identify how many miles are traveled in each state. The IRP fund (from motor carrier fees) are distributed proportionally to states based on this information.

Carriers must capture individual vehicle mileage reports (IVMRs) using paper, an electronic logging device (ELD), or global positioning system (GPS).

Reports must identify the vehicle, trip dates, origin and destination, beginning and ending odometer readings, and total trip miles or kilometers by jurisdiction.When recording the mileage of an apportioned vehicle, all movement, interstate and intrastate, must be included and loaded, empty, dead-head and/or bobtail miles or kilometers.

Monthly, quarterly, and yearly summaries are prepared from the IVMR information. Computer summaries are not acceptable at face value and must always be supported by IVMRs or original ELD/GPS data during an audit.

Final Thoughts

When determining whether the IRP is required or just a wise alternative to trip permits for vehicles weighing 26,000 pounds or less and crossing state lines, it’s best to check with the states in which the vehicle will be operated to learn of registration requirements.