Interstate Carrier ResourcesFMCSA Exempt Commodities: What You Can Haul Without an MC Number
Reviewed by Austin Park, founder of ICR Filings · Updated October 29, 2026
- An exempt for-hire carrier hauls unregulated property for pay. If every load is exempt, FMCSA does not require operating authority (an MC number).
- The law exempts ordinary livestock, unmanufactured agricultural and horticultural products, unpreserved fish, and some feed and seed.
- Processing usually ends the exemption: butter, cheese, canned produce, roasted coffee, and frozen dinners are not exempt.
- One regulated load changes the answer, and exempt carriers still need a USDOT number for interstate trucks of 10,001 lbs or more.
Most for-hire carriers need operating authority (an MC number) to haul across state lines. One big exception is carriers that only haul exempt commodities: mostly farm products that have not been processed. If that is all you haul, FMCSA does not require an MC number. The hard part is knowing what counts.
What an exempt for-hire carrier is
FMCSA defines an exempt for-hire motor carrier as one that transports exempt (unregulated) property owned by others for compensation. It says exempt commodities usually include unprocessed or unmanufactured goods, fruits and vegetables, and other items of little or no value. Its operating authority page lists for-hire carriers that exclusively haul exempt commodities among those not required to have an MC number.
What the law exempts
The exemption comes from 49 U.S.C. 13506(a)(6). It covers a motor vehicle used to carry:
- ordinary livestock;
- agricultural or horticultural commodities, other than manufactured products made from them;
- commodities on an older federal exempt list (Ruling No. 107), except frozen fruits, frozen berries, frozen vegetables, cocoa beans, coffee beans, tea, bananas, hemp, and certain imported wool products;
- cooked or uncooked fish and fresh or frozen shellfish, but not fish treated for preserving such as canned, smoked, pickled, spiced, corned, or kippered;
- livestock and poultry feed and agricultural seeds and plants, when hauled to a farm or to a business that sells agricultural supplies to farmers.
Examples from FMCSA's own list
FMCSA publishes Administrative Ruling No. 119, a composite list of commodities marked exempt or not exempt, and calls it a partial listing. A few entries:
| Exempt | Not exempt |
|---|---|
| Fresh mushrooms | Bananas |
| Honey, in the comb or strained | Butter and cheese |
| Nursery stock; growing or cut flowers | Coffee, roasted or instant |
| Sugar beets | Coal and charcoal |
| Cotton, ginned or unginned | Canned fruits and vegetables |
| Bees | Frozen dinners; commercial fertilizer |
The not-exempt items on the right come from 49 CFR 372.115, which reproduces Administrative Ruling No. 133: a list of commodities that are not exempt by statute. It also lists animal fats, cotton yarn, preserved fish, and several processed feeds such as alfalfa pellets and wheat bran. Feed hauled to a farm can still fall under the feed exemption above, so check the destination as well as the commodity.
Rules of thumb in Ruling 119
- Bagging: placing exempt commodities in bags does not affect their exempt status.
- Additives: minor additives are allowed. The ruling's informal rule of thumb is no more than 5 percent non-exempt additives.
- Advertising: a reasonable amount of advertising material shipped with the exempt goods it relates to does not change the shipment.
What exempt carriers still need
The exemption is from operating authority. It does not remove the USDOT number: any interstate operation in a vehicle with a weight rating or weight of 10,001 lbs or more needs one, along with the biennial MCS-150 update that keeps it active. Your state may have its own rules too.
Unsure whether your loads qualify? The free filing checker asks what you haul and lists what applies. If you are adding regulated freight, see how to get an MC number.
Common questions
Is hay exempt?
Generally yes. Administrative Ruling 119 lists hay as exempt, including chopped and dehydrated hay. Processed feeds are different: 49 CFR 372.115 lists alfalfa meal and alfalfa pellets as not exempt, unless hauled to a farm or farm supplier under the feed exemption.
Are bananas exempt?
No. The statute that creates the agricultural exemption names bananas, along with coffee beans, cocoa beans, tea, and frozen fruits and vegetables, as not exempt.
Do exempt carriers need a USDOT number?
Yes, if they run interstate in a vehicle of 10,001 lbs or more. The exemption is from operating authority, not from USDOT registration.
What if most of my loads are exempt?
FMCSA's rule covers carriers that exclusively haul exempt commodities. If you also haul regulated freight interstate for pay, you need operating authority for that freight.
Does putting produce in bags make it regulated?
Not by itself. Administrative Ruling 119 notes that placing exempt commodities in bags does not affect their exempt status.
Official sources
- FMCSA FAQ: What is an exempt for-hire (exempt commodities) motor carrier?
- FMCSA: What is operating authority and who needs it?
- 49 U.S.C. 13506: exempt commodities and operations
- FMCSA: Administrative Ruling No. 119, composite commodity list (exempt and not exempt)
- 49 CFR 372.115: commodities that are not exempt (Administrative Ruling No. 133)
- FMCSA: Do I need a USDOT number?
This guide is general information, not legal advice. Rules and fees change, so confirm with the official source before you file.
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