The default is electronic, and it has been since 2017. § 395.8(a)(1)(i) requires a motor carrier operating commercial motor vehicles to install, and to require each of its drivers to use, an electronic logging device to record duty status in accordance with subpart B of Part 395 — no later than December 18, 2017. § 395.20 sets the scope of what that means: the subpart applies to devices used to record a driver’s hours of service under § 395.8(a), and a device used after that date must meet the subpart’s requirements. So the question a driver actually has is not whether the mandate exists but whether they are inside it, and the rule answers that by naming the situations where manual recording is still permitted rather than by listing who is caught.

There are four of them, in § 395.8(a)(1)(ii)(A), and three are about the vehicle rather than the driver. Two of the four turn on a driveaway-towaway operation — one in which the vehicle is moved by being driven or towed as the shipment itself, rather than carrying a load. A carrier MAY require manual recording instead of an electronic device where the driver operates a commercial motor vehicle: in a manner requiring completion of a record of duty status on not more than 8 days within any 30-day period; in a driveaway-towaway operation in which the vehicle being driven is part of the shipment being delivered; in a driveaway-towaway operation in which the vehicle being transported is a motor home or a recreation vehicle trailer; or that was manufactured before model year 2000, as reflected in the vehicle identification number shown on the vehicle’s registration. Read the verb carefully. The section says a carrier may require manual recording — it is the carrier’s option, not the driver’s entitlement, and a carrier that runs everything electronically is entitled to do so even where one of these four would have allowed paper. Where paper is used, the record goes on the specified grid, in duplicate, for each 24-hour period.

A third case is different in kind, and it is easy to mistake for the second. The short-haul provisions of § 395.1(e) exempt a qualifying driver from § 395.8 and § 395.11 — not from the electronic device in favor of paper, but from the record of duty status itself — and the second of them, § 395.1(e)(2), reaches a limit as well, displacing § 395.3(a)(2) with a structure of its own. In place of the record, both provisions require the carrier to maintain and retain time records for 6 months showing when the driver reported, total hours on duty, and when they were released. Chapter 7 works those exceptions out in full, including the radius and the duty-period limits that go with each; what matters here is only the shape. One driver keeps an electronic record, one keeps a paper one, and one keeps no record of duty status at all — and none of the three is free of driving limits, though the second short-haul provision substitutes its own for § 395.3(a)(2) rather than leaving that limit in place.