There are a lot of controversial things in the truck world, such as which brand is better, towing with a half-ton or an HD and how to properly tow a load. However, none of these even comes close to the topic of a CDL for a new HD truck or RV.

The fact is new trucks, such as the 2021 Ram 3500, are claiming maximum towing numbers in the 35,000-pounds-plus range with BIG, BOLD NUMBERS on billboards and dealership signage. This is causing a lot of concern, and misinformation is rampant with anecdotal stories being turned into “that must be” the law.

Here’s the truth.

A commercial driver’s license (CDL) is a special license provided by the local state Department of Motor Vehicle’s office, which follows the law set down in the Federal Motor Vehicle Safety Standards. You can find this regulation, in all of its legal speak glory, on the Electronic Code of Federal Regulations website. You can also find a handy FAQ about the CDL license on the FMCA website as well. 

In a nutshell, the standard applies a special license type to individuals conducting commercial business with their vehicle (a very important part) and breaks this license into three parts – Class A, Class B and Class C. These classes are separated by what the vehicle is, what it is capable of towing (aka gross vehicle weight rating of 26,001 pounds or more), what it could tow with it in terms of a 10,001-pound trailer (aka gross combined vehicle weight rating), how many people the vehicle is transporting or whether or not you’ll be transporting hazardous materials.

While this seems simple enough, it isn’t so simple since individual states can assign their own special rules to a CDL, and there are exceptions — like the farmer exception I’ll cover in a minute.

Be sure to contact your local DMV to determine if there are special licenses needed for your state as well as understand the information in this article.

While the rules seem straightforward, the interpretation of them is murky at best. You’ll find all sorts of answers to CDL license question if you go down the Google rabbit hole long enough.

So, here’s the truth: It depends. That’s why it is murky.

The depends comes down to why you are towing, how much you are towing and what you are towing with.

FMCSA put together this handy image to guide law enforcement as well to help people determine whether they need a CDL. Look it over before moving on.

This visual chart is pretty handy from the FMCSA and helps clarify who really needs a CDL. (Photo provided by FMSCA)

The first place to start with answering the CDL question, is the type of towing you are doing. Let’s say you are towing an RV camper to a lake. Are you doing this to get paid? Then, no, no matter what weight, what state or what truck you are using, you don’t need a CDL.

Let’s go over that again and this is a key question: Are you towing for compensation, as part of a job, to get paid? If the answer is no, then stop reading, tell your friends they are wrong and move along.

The FMCSA specifically addresses this in its FAQ with question #3.

Recreation or commercial use is the key question when determining if you need a CDL. The FMCSA FAQ page answers this clearly. (Screenshot FMCSA website)

Simple enough.

Let’s say you are, in fact, towing for work OR your neighbor is going to give you a $100 to move his camper to the lake OR you are just curious about all the other language in the law.

Let’s start with the top image in the chart since this seems to provide the most confusion. The first statement is “any combination of vehicles with a GCWR of 26,001 or more pounds provided the GVWR of the vehicles being towed is in excess of 10,000 lbs.”

What does that really mean? First, let’s define the terms GCWR (gross combined weight rating) and GVWR (gross vehicle weight rating). The GCWR is basically adding up all the GVWR weights from whatever you are towing. This is different than curb weight (the scale weight of the vehicle) and instead this is the maximum weight the vehicle can handle.

Let’s put this in practical terms looking at towing charts like the 2021 Ford RV & Trailer Towing Guide.

In the chart below, you can see the F-350 and F-450 dual-rear wheel trucks separated out by engine, axle ratio, GCWR and length. You can also see the confusion since the diesel trucks have a GCWR more 26,001 pounds while the gas engine trucks do not — except for the 7.3-liter V-8 with the 4.30 rear axle.

The 2021 Ford F-350/F-450 towing chart. (Screenshot from Ford Fleet)

Again, we need to start with first: Are you towing commercially or recreationally? Second, we have to look at the trailer since that matters as well.

Let’s say I have a crew cab, 4×4 6.7-liter V-8 turbo diesel Ford F-350 with a 4.30 rear axle and my max GCWR is 43,500 pounds with a max trailer tow of 24,200 pounds. Now this truck would be driven by someone with a CDL if, again IF, the trailer or vehicle or whatever I’m towing has a GVWR exceeding 10,000 pounds.

In practical terms, let’s say I want to tow my race car to another state with my truck for a fun day on the track. First, since we already established it isn’t for work, we can move on to step 2, the weight. The truck’s GCWR is our first red flag indication we may need to consider a CDL and next would be the trailer GVWR. Pulling up an example on Pro-Line Trailer Sales website, I found a 8.5×16 enclosed trailer. This trailer has a max GVW aka GVWR of 7,000 pounds. This means, I would not need a CDL based on the weight issue.

Towing this car hauler with a diesel F-350 would not require a CDL even IF you were not doing it commercially. (Screenshot Pro-Line Trailer website)

Pretty straightforward to understand you need both the truck’s GCWR and the trailer GVWR. Keep in mind, a trailer more than 10,001 pounds is a pretty sizable trailer, and those trailers are sold with the GVW in mind for transporting heavy equipment like on the Pro-Line Trailer website with the GVW listed in the title of the trailer.

You can see how the trailers marked with a higher GVW look like they are for construction equipment and this is key when thinking about needing a CDL. (Screenshot from Pro-Line Trailer website)

Finally, keep in mind, we are only talking about 1-ton trucks with diesel engines and not 1/2-ton or 3/4-ton trucks. That is key as well since many of those other trucks don’t have a high enough GCWR to even enter the CDL license discussion.

Another common question that comes up with CDLs has to do with the large Class A RV buses similar in size to a semi-truck and large 5th-wheel RVs. These vehicles have grown in size dramatically over the years, and the trucks to tow them also have vastly higher tow ratings than they did just a decade ago. Do you need a CDL for those?

The simple answer is no CDL. Why? Remember the part about recreation vs. commercial? Yes, this is the key question.

However, the longer answer is: It depends on your weight as outdoorsy.com points out.

Most RVs are less than the CDL weight threshold and, more importantly, are used for recreation. (Image courtesy of Outdoorsy.com)

As the image points out, most Class A motorhomes (the really big ones) have a weight between 13,000-30,000 pounds. This means you would only need a Class B license if you were driving this commercially. So, Grandpa and Grammie can go buy a huge RV weighing close to 30k pounds — about the size of a semi — and drive it without a CDL.

Smaller Class C RVs weigh around 10,000-12,000 pounds, and you wouldn’t need a CDL if you were traveling recreationally — even if you had found a way to double this weight by pulling a 10,001-pound trailer as well. Think: Redneck towing.

One of the most common exceptions to the CDL law has to do with farmers. Basically, the Federal Government gave them a free pass to lower their burden on having a CDL license.

It essentially states if a farmer transports his goods less than 150 miles away from his farm, he doesn’t need a CDL. The idea behind this is pretty simple — to allow the farmers to bring in the crops to distribution centers without needing a CDL.

This is a nice perk for the farmer.

Don’t get caught up in what someone said “that one time” or that you heard someone say a trailer or a truck that can tow 35,000 pounds MUST have a CDL. Remember the main question is recreation vs. commercial. Answering this question first can reduce a lot of the confusion right off the bat.

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