Do You Need a CDL to Operate a Refrigerated Trailer?
You’re ready to expand your catering business, start delivering fresh produce, or rent a refrigerated trailer for an event, but do you need a commercial driver’s license (CDL) to tow it?
The answer depends on weight ratings and vehicle type, not the fact that it’s refrigerated. Most small trailers, like the 6×8, 6×12, and 6×16, paired with a standard pickup do not require a CDL.
Understanding CDL Requirements
CDL rules are based on weight thresholds set by the FMCSA:
- Class A CDL: Required if GCWR ≥ 26,001 lbs AND trailer GVWR > 10,000 lbs.
- Class B CDL: Required if a single vehicle GVWR ≥ 26,001 lbs or towing a trailer under 10,000 lbs.
- Class C CDL: Only applies for hazardous materials or passenger transport. Not relevant for small refrigerated trailers.
Key Takeaway: If your combined vehicle + trailer weight is under 26,001 lbs, and your trailer is under 10,000 lbs GVWR, you don’t need a CDL.
For official FMCSA guidance, see FMCSA CDL Overview.
When You Don’t Need a CDL
Small portable refrigerated trailers (6×8, 6×12, 6×16) generally have GVWR under 10,000 lbs. Combined with a standard pickup, they stay well under the federal threshold.
Other scenarios where no CDL is needed:
- Personal or non-commercial use: Moving your own goods or family catering
- Rental situations: Many rental companies use small refrigerated trailers to stay under CDL thresholds.
When You Might Need a CDL
You would only need a CDL if:
- Combined weight exceeds 26,001 lbs
- Trailer GVWR exceeds 10,000 lbs
For 6×8, 6×12, and 6×16 trailers and a standard pickup, this rarely happens.
How to Check if You Need a CDL
- Find your vehicle’s GVWR
- Usually on the door jamb sticker or manufacturer spec sheet
- Find your trailer’s GVWR
- Located on the trailer VIN plate or rental documentation
- Add GVWRs to calculate GCWR
- GCWR = Vehicle GVWR + Trailer GVWR
- Compare to 26,001 lbs
- GCWR < 26,001 lbs → No CDL required
- GCWR ≥ 26,001 lbs → Class A CDL may be required
Benefits of No-CDL Refrigerated Trailers
- Lower costs: No CDL training/testing, no renewal fees, lower insurance.
- Driver flexibility: Any licensed person can tow; family members can help.
- Faster setup: Start your business or delivery immediately.
- Simpler compliance: Fewer DOT rules to follow, no logbooks, no medical certificate needed.
Most small refrigerated trailers (6×8, 6×12, 6×16) do not require a CDL. The key numbers to remember:
- Keep combined GCWR under 26,001 lbs
- Trailer GVWR under 10,000 lbs
- Verify your vehicle and trailer ratings before towing
Want to find out more about renting or buying a refrigerated trailer? Contact Penguin Trailer.
FAQs
Q: Can I rent a refrigerated trailer without a CDL?
A: Yes! Most rental companies offer small trailers (<10,000 lbs GVWR) that can be towed without a CDL. Always check trailer specs and your tow vehicle capacity.
Q: Can I tow it with my pickup truck?
A: Most 1/2 ton, 3/4 ton, and 1 ton pickups can tow 6×8 to 6×16 trailers without a CDL. Confirm your truck’s GVWR and towing capacity.
Q: Does refrigeration require a special license?
A: No. The refrigeration unit itself doesn’t affect CDL requirements.
Q: Do I need a CDL if I cross state lines?
A: Federal CDL rules apply for interstate commerce. For small trailers under 10,000 lbs, no CDL is required. Always check your state DMV rules.
Disclaimer: This article is intended for general informational purposes only and should not be interpreted as legal or licensing advice. CDL requirements can vary by state and situation. Always check with your local Department of Motor Vehicles or relevant licensing authority for the most accurate information.
