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This question is a bit more complicated than it appears on the surface, and the answer is going to be largely dependent on the circumstances under which you're transporting the horses.

First, we have to consider what vehicles require a CDL. In short form, single vehicles and combination commercial vehicles with a Gross Vehicle Weight Rating or Gross Combination Weight Rating of more than 26,000 lbs. require a CDL. Weight rating is defined as the weight those vehicles are designed to be laden to - not their actual weight or empty weight. And if the actual weight exceeds the weight rating, you're in violation and operating an illegal vehicle or combination.

A Class A CDL is for vehicles with a Gross Combination Weight Rating of more than 26,000 lbs. when the vehicle in tow is rated at more than 10,000 lbs. It's common knowledge that this is the class of licence required for commercial tractor-trailer combinations, but is not restricted to that. For example, a commercial use pickup rated at 15,000 lbs. towing a trailer rated at 15,000 lbs. would also require a Class A CDL.

A Class B CDL is for single vehicles with a Gross Vehicle Weight Rating in excess of 26,000 lbs., and allows for trailers with a weight rating of up to 10,000 lbs. to be towed.

Class C CDL is not applicable here.

Next, we have to figure out what the nature of the vehicle is, if it meets the weight rating criteria to require a CDL. If it is a commercial vehicle, a CDL will be required. If it is not, a CDL may not be.

If you're operating such a vehicle as a third-party for-hire carrier and transporting the horses for someone else, you would need a CDL (as well as ICC/MC and IFTA or single state fuel tax registration) and a USDOT number.

If you're transporting your own horses with your own vehicle, and it's appropriately registered, you fall under exemptions.

If the power unit is a registered farm vehicle, it does not require a CDL provided the following criteria is met:

  • It is registered and plated as a farm vehicle, and such information is displayed on the vehicle
  • It is used only for the activities of that farm, and is not hired out on a third-party basis. For example, a sod farmer who has their own tractor-trailer to deliver the sod they grow can fall under this exemption.
  • It is operated by the farmer, members of the farmer's immediate family, or direct employees of the farmer. A direct employee is a W-2 employee - a 1099 contractor would not be a direct employee, and would require a CDL.
  • It is operated within a 150 mile radius of the farm from which is operates. The moment that vehicle leaves that 150 mile radius, a CDL is required.

It may also be possible that the power unit (tow vehicle) is registered as a recreational vehicle, in which case, it also falls under an exemption, provided that:

  • It is not used for the transport of commercial goods or on a for-hire basis for the transport of good, provision of services, or transport of people.
  • It is appropriately registered and plated as such.
  • The driver of the vehicle is not operating it on a for-hire basis, whether a direct employee of a farmer or not.

A farm vehicle will still be required to cross scalehouses and ports of entry; a recreational vehicle will not be.

If the total Gross Combination Weight Rating is under 26,001 lbs., a CDL is not required, although a DOT medical card will be required to be carried by the driver if the vehicle meets the criteria of a commercial vehicle (a vehicle operated on a for-hire basis) and has a Gross Vehicle Weight Rating/Gross Combination Weight Rating of more than 10,000 lbs.

Licencing for registered farm vehicles and recreational vehicles (both single vehicles and combination vehicles) does not fall under the jurisdiction of the Federal Motor Carrier Safety Administration, and thus the requirements for such vehicles are left to the states which issue the licences to the vehicle operators. Some states will have a non-CDL Class A and Class B licence. Others may use a "chauffeur's licence" system with endorsements specific to the type of vehicle being operated. You will have to check with your state's DMV as far as those licencing requirements go, since I do not have the luxury of knowing which state you're in.

If there are further questions pertaining to this, or new questions arising as a result of the answer I've given you, you may contact me directly via email (the address is in my bio page).

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Q: Do you need a CDL to pull a horse trailer to a horse show?
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