Qualifying for a lower fee category under the Unified Carrier Registration (UCR) program can result in significant savings. However, it may also wave a yellow flag for auditors, so it’s important to get it right. With enrollment now open for 2024, now’s the time to check your numbers.

Counting your vehicles to determine your fee category has four steps. Note that intrastate vehicles are included with interstate vehicles, at least through the third step.

1. Determine how many vehicles the registrant owns or operates.

Only vehicles owned or operated by a motor carrier or freight forwarder count toward its UCR fee. These include all vehicles that are either:

• Registered in the name of the carrier or freight forwarder, or
• Controlled by it under a long-term lease (one of 30 days or more) during a vehicle registration year.

2. Determine how many owned or operated vehicles are commercial motor vehicles (CMVs).

For UCR purposes, a CMV is defined as a self-propelled vehicle used on the highways in commerce principally to transport passengers or cargo, if the vehicle:

• Has a gross vehicle weight rating or gross vehicle weight of at least 10,001 pounds, whichever is greater; or
• When connected to trailing equipment has a gross combination weight rating or gross combination weight of at least 10,001 pounds, whichever is greater; or
• Carries placarded amounts of hazardous materials, regardless of the vehicle’s weight; or
• Is designed to carry more than 10 passengers, including the driver.

3. Determine the relevant time period of the vehicle count.

The size of a carrier or freight forwarder fleet is determined as either:

• The number of CMVs declared as owned or operated on the last Form MCS-150 filed with the Federal Motor Carrier Safety Administration (Option A on the registration form), or
• The number owned or operated during the year ending the June 30 before the beginning of the calendar year for which the UCR fee is being determined (Option B on the registration form).

4. Exercise (or not) certain options to add or subtract vehicles from the number of CMVs owned or operated.

At this point, the registrant should have determined the full count of CMVs, both interstate and intrastate, in its fleet. Now, UCR allows certain types of registrants to add or subtract certain categories of vehicles to arrive at the final count for purposes of determining their fees. Note that taking advantage of these provisions is entirely optional and not all types of carriers have these options.

Including smaller vehicles: A for-hire motor carrier may include in the count of its fleet any of the motor vehicles, regardless of their weight or the number of passengers for which they are designed, which the carrier operates on the highway to carry either freight or passengers for compensation.

A freight forwarder is not eligible to include such vehicles, and a private carrier of property is also disqualified by the requirement of hauling for compensation, which private carriers, by definition, don’t do.

Why do this? Because federal law bars state and local governments from imposing most credential requirements on an interstate motor carrier’s vehicles that have been included in its fleet when determining the carrier’s UCR fee.

Excluding intrastate vehicles: A motor carrier, either for-hire or private, may exclude vehicles that operate only in intrastate commerce in the transportation of property (including, for this purpose, waste and recyclables) from its fleet count for purposes of the UCR fee. Note that:

• Freight forwarders are not eligible for this exclusion, and
• A motor carrier may not exclude intrastate passenger vehicles.

Keys to Remember: Determining your fee category under UCR is not a simple process, but it’s important to get it right. The UCR enrollment period for 2024 opened October 1, with registration and fees due by January 1, 2024.