IRP registration and apportioned plates

The International Registration Plan (IRP) lets a truck that runs in several states or provinces carry one apportioned license plate and one cab card from its base jurisdiction instead of registering in each one. You pay registration fees to every jurisdiction in proportion to the distance your fleet runs there, all through your base state. IRP is required for power units over 26,000 pounds, or with three or more axles, or in combinations over 26,000 pounds, that travel in two or more member jurisdictions.

IRP is an agreement among U.S. states, the District of Columbia and Canadian provinces, run by the member jurisdictions. The IRP organization’s site could not be read from our research machine, so this page relies on the official IRP pages of the Pennsylvania, California and District of Columbia motor vehicle departments. Details that are one state’s practice are marked as such.

Who must apportion

Pennsylvania’s statement of the rule: you must register apportionately if the vehicle "travels or is intended for travel in two or more of the member jurisdictions and is used for the transportation of persons for hire or is designed, used, or maintained primarily for the transportation of property," and it:

• is a power unit with a gross or registered weight over 26,000 pounds; or
• is a power unit with three or more axles, regardless of weight; or
• is used in combination when the combination’s weight exceeds 26,000 pounds.

Lighter vehicles and two-axle vehicles at 26,000 pounds or less "may be apportioned at the option of the registrant." Since 1 January 2016 charter buses running interstate need apportioned registration or trip permits (Pennsylvania).

The DC DMV lists vehicles exempt from IRP registration: government-owned vehicles, recreational vehicles used for personal purposes, and vehicles with restricted tags.

The thresholds are essentially the same as IFTA’s qualified motor vehicle test, which is why most carriers set up the two together (IFTA explained).

How apportioned fees work

California DMV’s explanation: when you register under IRP, "you pay pro-rated (apportioned) fees based on the percentage of highway mileage traveled in each jurisdiction." Its example: a vehicle running 50 percent of its miles in California and 50 percent in Nevada pays 50 percent of each state’s registration fees rather than the full amount in both. The base jurisdiction collects everything and passes each jurisdiction’s share on through the IRP Clearinghouse.

The DC DMV publishes a simplified renewal example for an 80,000-pound for-hire truck running 25,000 actual miles in each of four jurisdictions (100,000 miles, 25 percent each). Each jurisdiction’s full-year fee is multiplied by 25 percent:

DC notes that actual fees also depend on the registered combined gross weight and other vehicle-specific criteria, and "can only be determined after processing a completed application." Treat the table as an illustration of the method, not a quote.

Full Reciprocity Plan. Since 1 January 2015, according to Pennsylvania, apportioned registrants can operate in all IRP jurisdictions: the cab card lists every member jurisdiction, and fees are based on actual distance in the last reporting period. A new carrier with no travel history pays its first year on the base state’s average per-vehicle distance chart (Pennsylvania); California publishes its own chart.

Fees also depend on the registered weight in each jurisdiction and on each jurisdiction’s fee schedule, which is why the only reliable number comes from your base state’s fee calculator or invoice. California says the invoice balance must be paid within 20 days of the billing date.

Your base jurisdiction

You register where you have an established place of business. California’s definition, which reflects the Plan: a physical location from which the fleet accrues mileage and where its operational records are kept or can be made available. It must be owned, leased or rented by you, have a street address, be open during normal business hours, and have the fleet’s records available on request. Renting desk space in someone else’s building does not count, and the address "cannot be the address of a registration service agent." For owner-operators, "the established place of business ... may be their home address."

What the application needs

California’s list is typical of what base states ask for:

• carrier and vehicle schedules listing each vehicle, its weights and jurisdictions;
• the USDOT number of the carrier responsible for the vehicle’s safety, with an MCS-150 updated within the last 12 months;
• a taxpayer ID (FEIN or SSN) and proof of the in-state place of business;
• a signed agreement to keep mileage records;
• proof of the federal heavy vehicle use tax for vehicles over 54,999 pounds (the stamped Schedule 1 from Form 2290);
• VIN verification, and an agent authorization if a registration service files for you.

The USDOT number and MCS-150 are part of IRP for a reason. Under 49 CFR 390.19T(i), a carrier that registers its vehicles in a state participating in FMCSA’s PRISM program (Performance and Registration Information Systems Management) is exempt from filing its identification report directly with FMCSA, "provided it files all the required information with the appropriate State office."

California registrations run 12 months from the first day of the assigned month and must be renewed by midnight on the last day of that month; Pennsylvania runs all apportioned registrations from June 1 to May 31. Renewal cycles differ by state.

Plate, cab card and what the officer checks

• One apportioned plate and one cab card per vehicle; the cab card shows the jurisdictions and the weight the vehicle is registered for in each.
• Since 1 January 2019 the Plan requires member jurisdictions to accept an electronic image of the cab card (Pennsylvania, DC). It must be "valid, accurate, accessible and readable." Pennsylvania still requires its registrants to sign the credential.
• DC’s enforcement rules: the plate goes on the front of tractors and the rear of straight trucks, trailers and buses; the cab card must be carried at all times; and renewal credentials may be displayed before the enforcement date only with the previous year’s cab card also in the vehicle.

Credentials are typically checked at ports of entry and weigh stations (weigh station directory).

Registration cycles and renewals

• Length: California registrations are good for 12 months from the first day of the assigned month and must be renewed by midnight on the last day of that month to avoid penalties. Pennsylvania runs every apportioned registration on one cycle, June 1 to May 31, and vehicles added to an existing fleet keep that cycle.
• Renewal fees: under the Full Reciprocity Plan, renewal fees are based on actual distance in the last reporting period, not estimates (Pennsylvania). Your mileage records are what your next bill is built on.
• Payment: California bills after processing and expects payment within 20 days of the billing date; DC takes payment at registration. Each base jurisdiction sets its own payment methods.
• Fleets: Pennsylvania notes that under full reciprocity there is no longer a need to split fleets by where they travel, and that the best time to consolidate fleets is at renewal.

Mileage records and audits

The DC DMV explains the Plan’s record rule: your records "must be accurate and readable and capable of supporting mileage figures submitted for the current registration year and for three preceding IRP registration years," showing all miles in each jurisdiction by each vehicle. An Individual Vehicle Mileage Record should show for each trip:

• start and end dates, and where the trip started and ended;
• the route;
• total trip miles, "including all miles loaded, empty and/or deadhead";
• miles in each state;
• unit number or VIN, fleet number, registrant’s name, trailer number and driver’s signature.

Monthly summaries such as fuel reports "are not acceptable at face value" without trip records behind them. Base jurisdictions audit periodically and bill mileage differences; a carrier without adequate records "risks being assessed the full amount charged by individual jurisdictions" (DC), and California warns of "significant penalties and interest."

What IRP does not cover

DC’s list of what apportioned registration does not take care of:

• motor fuel taxes (that is IFTA);
• operating authority (your own authority);
• the federal heavy vehicle use tax (Form 2290);
• FMCSA PRISM compliance;
• size and axle limits and bridge laws (see the bridge formula calculator);
• overweight and oversize permits.

It is also separate from UCR, the annual company fee.

Trip permits instead

IRP is voluntary for jurisdictions and, as DC puts it, "by extension, not compulsory for carriers." A carrier that does not apportion its vehicles can still travel between jurisdictions, but "must obtain trip permits" in each one it enters. For occasional trips that can be cheaper; for regular interstate work apportioned plates are usually simpler.

Apportion or buy trip permits?

For a heavy vehicle that runs interstate regularly, apportioned registration is the normal route. California tells its carriers that most California-based commercial vehicles operating at 26,001 pounds or more "must have either IRP registration or alternative commercial trip permits from the appropriate foreign jurisdictions when operating outside California," and that vehicles of 26,000 pounds or less operating interstate "may be exempt from IRP or temporary commercial trip permits under reciprocal agreements." It also advises contacting each jurisdiction you travel to if you choose not to file for IRP. A carrier making a handful of out-of-state trips a year may find trip permits cheaper; one running across state lines every week will usually find one plate and cab card simpler than buying permits trip by trip.

Worked example

Example, applying the rules above. A new one-truck carrier based at the owner’s home in Pennsylvania runs a three-axle tractor at 80,000 pounds. The tractor is apportionable (three axles, and a combination over 26,000 lb). With no mileage history, the first year’s fees are based on Pennsylvania’s average per-vehicle distance chart. The owner files Form 2290 first so the stamped Schedule 1 can go with the application, gets one plate for the front of the tractor and a cab card covering every IRP jurisdiction, and from the first trip keeps a mileage record per trip, since next year’s fees will be based on actual miles and those records must be kept for the current year and three before it. IRP fees are a fixed annual cost to spread across your miles in the cost per mile calculator.

Common mistakes

• Using a registration agent’s address as the base.
• Declaring a weight on the cab card that is lower than you actually run, then being cited at a scale.
• Declaring a lower weight on Form 2290 than on the cab card; the IRS uses the highest declared weight.
• Keeping only fuel-card summaries instead of trip-by-trip mileage records.
• Letting the renewal slide past the end of the registration month.