Understand What Counts as a UCR “Vehicle”
For UCR purposes, you count power units, not trailers.
Vehicles that count:
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Trucks
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Truck tractors
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Buses (commercial passenger vehicles)
Vehicles that do NOT count:
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Trailers
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Semi-trailers
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Dollies
Only self-propelled commercial motor vehicles are included.
Count Vehicles Used in Interstate Commerce
Include any power unit that:
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Operates across state lines, OR
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Transports interstate freight or passengers (even within one state)
This applies to:
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For-hire carriers
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Private carriers
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Owner-operators
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Passenger carriers
Include All Vehicles You Own or Operate
Your fleet size must include:
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Vehicles you own
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Vehicles you lease (long-term or short-term)
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Vehicles operated under your USDOT number
If the vehicle operates under your USDOT number, it counts—even if:
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You don’t own it
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It’s temporarily leased
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It’s not used every day
Use the Correct Timeframe (Very Important)
Your UCR fleet size is based on the highest number of power units you operated at any time during the previous calendar year.
Example:
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You ran 3 trucks in March
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Expanded to 6 trucks in July
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Reduced back to 4 trucks in December
Your UCR fleet size = 6
Do NOT Reduce Fleet Size for Seasonal or Sold Vehicles
You must still count:
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Trucks sold mid-year
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Seasonal trucks
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Trucks parked or inactive for part of the year
If they were operated at any point during the year, they count.
Owner-Operators: Special Notes
Owner-operators with their own USDOT number:
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Count your own truck(s)
Owner-operators leased to a carrier:
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If operating under the carrier’s USDOT number, the carrier counts the truck—not you
Brokers, Freight Forwarders & Leasing Companies
If you are:
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A broker
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A freight forwarder
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A leasing company
You do not count vehicles, but you must still:
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Register for UCR
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Pay the lowest UCR fee tier
Double-Check Before Submitting
Before filing:
Review your MCS-150
Verify leased and temporary vehicles
Confirm peak fleet size
Make sure no trailers are counted
Over-reporting = overpaying
Under-reporting = penalties, citations, and audits
Quick UCR Fleet Size Checklist
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Count power units only
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Include leased & owned vehicles
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Use the highest number operated last year
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Ignore trailers
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Don’t reduce for seasonal use
Bottom Line
Your UCR fleet size is the maximum number of power units you operated at any point during the previous year—nothing more, nothing less.