Do you need a CDL and Commercial Registration to Tow?

If you plan to tow a trailer, there are several things you should know. The best place to start is with what you plan to tow. Therefore, A-E below cover the most common towing situations in Michigan.

A.  For a small utility trailer, basic safety is usually sufficient. You need to be sure that the trailer:

• Is properly licensed, with a light that illuminates the license plate.
• Has at least one working taillight.
• Must have at least one working stoplight if the trailer or its load obscures the towing vehicle’s stoplights.
• Has two red rear reflectors.
• Mudflaps are mandatory.
• The hitch is securely fastened.
• The breakaway chains are attached and will function as needed.
• The tires have at least 2/32” of tread.

B.  For recreational trailers, or trailers that weigh more than 2,500 lbs. but less than 3,000 lbs., the additional safety requirements in addition to the above includes:

• Trailer lights must be working properly, including tail lights, brake lights and turn signals.

C.  For recreational trailers over 3,000 lbs., but less than 10,000 lbs., the additional requirements include:

• Amber colored reflectors attached near the front of each side of the trailer.
• Red reflectors attached near the back on each side of the trailer.
• Two amber colored clearance lights on the front of the trailer, and one amber clearance light near the front on each side.
• Two red clearance lights on the back of the trailer and one red clearance light near the back on each side.
• Working trailer brakes.

D.  For large trailers weighing 10,000 lbs. or more, you will want to review Michigan vehicle code MCL 257.312e, which states in part that:

(1) Except as otherwise provided in this section, a person, before operating a commercial motor vehicle, shall obtain the required vehicle group designation as follows:

(a) A person, before operating a combination of vehicles with a gross combination weight rating of 26,001 pounds or more including a towed vehicle with a gross vehicle weight rating of more than 10,000 pounds, shall procure a group A vehicle designation on his or her operator’s or chauffeur’s license. Unless an indorsement or the removal of restrictions is required, a person licensed to operate a group A vehicle may operate a group B or C vehicle without taking another test.

(b) A person, before operating a vehicle having a gross vehicle weight rating of 26,001 pounds or more, shall procure a group B vehicle designation on his or her operator’s or chauffeur’s license. Unless an indorsement or the removal of restrictions is required, a person licensed to operate a group B vehicle may operate a group C vehicle without taking another test.

(c) A person, before operating a single vehicle having a gross vehicle weight rating under 26,001 pounds or a vehicle having a gross vehicle weight rating under 26,001 pounds towing a trailer or other vehicle and carrying hazardous materials on which a placard is required under 49 CFR parts 100 to 199, or designed to transport 16 or more passengers including the driver, shall procure a group C vehicle designation and a hazardous material or passenger vehicle indorsement on his or her operator’s or chauffeur’s license.

What does this mean for you? Before you get on the road you need to consider if you and your vehicle qualify in any of the above categories. You should know your gross vehicle weight rating (GVWR). You should know your trailer’s GVWR. Then you need to know the ACTUAL weight of your vehicle plus trailer, plus the weight of the load you intend to carry—this is called the elected gross vehicle weight (EGVW). This will tell you which requirements you need to meet.

If the combined weight is over 26,000 pounds, including a trailer of 10,000  pounds or more, you will need a class A CDL. If you do not have a class A CDL, with appropriate registration, you will be cited for “Operating a commercial motor vehicle without a CDL, as well as for not having a proper elected gross vehicle weight. Both of these citations carry fines and penalties.

E.  If you are pulling a Recreational Double:

• This is a combination of a pickup truck pulling a fifth-wheel trailer and a second trailer attached to the rear of the fifth wheel, you will need an “R” endorsement on your drivers’ license.
• The requirements for the trailers and their safety remain the same as above, with restrictions on the total weight and the length of the three vehicles.
• The towing capacity of the pickup must be equal to or greater than the weight of the two trailers.

Know before you go—take the time to review your gross vehicle weights, to check your trailer(s) for all safety requirements, and to obtain the proper licenses or registration. If you do have a problem, call Van Den Heuvel Law Office right away. Our attorneys are very experienced in vehicle citations and will help you resolve any citations or penalties.