Issue 1 · Tools & Software · May 19, 2026

The 14 ELDs FMCSA pulled — what carriers are swapping to, and the vendor-side fight

FMCSA pulled 14 ELDs on March 4 — plus 8 from the same firmware family last year. The replacement filter, and the script for fighting cancellation fees when your firmware gets revoked.

The companion piece to Freight/Signal Issue #1. Issue #1 ships short — ≤1,000 words in the email. The Deep Dive’s long form lives here.

The recap

On March 4, 2026, the Federal Motor Carrier Safety Administration removed fourteen devices from its list of registered electronic logging devices. Enforcement began May 4, 2026 — under 49 CFR § 395.8(a)(1), a driver running one of the 14 after that date is treated as operating without an ELD and placed out of service.

Ten of the 14 are firmware reskins. FMCSA’s revocation notice names Gorilla Fleet Safety, LLC as the provider behind ClearPath ELD (formerly Trucker Path Pro), SimpleX 2 Go, LB Technologies FleetTrack ELD, HCSS Pro, ELDX Pro, AllwaysTrack ELD, and others. Different brands. Same firmware. One vendor.

This was not the first Gorilla revocation. In May 2025, FMCSA pulled 8 Gorilla-firmware devices under different brand names: AllwaysTrack, Command Alkon Trackit, ELDX, Gorilla Safety Compact ELD, HCSS ELD, LB Technologies FleetTrack HOS, Simplex ELD 2GO, and Trucker Path ELD Pro. Some of those exact names came back in March 2026, presumably as Gorilla cycled firmware versions.

CVSA’s International Roadcheck closed May 14 with ELD tampering as this year’s driver focus. Day one produced a 31.4% out-of-service rate — nearly double the 2025 full-event benchmark.

Issue #0 covered the list. This piece is the next two questions: which device to replace it with, and how to get out of the contract you’re stuck in.

The Gorilla pattern, deeper

Gorilla Fleet Safety, LLC was founded in 2013 in Spring, Texas. Its public-facing brand, Gorilla Safety, still operates as of this writing. The company is profiled on BBB as Gorilla Safety Fleet Management — not BBB-accredited, classified as a Safety Consultant — though whether the BBB-listed entity is the same legal entity as the FMCSA-registered Gorilla Fleet Safety, LLC requires direct verification.

Pricing has been public: $260 for hardware, $19.99–$36.99/month per vehicle for software. The pitch targeted “budget hunters who refuse long-term contracts” — operator-owners running a few trucks who needed federally-compliant HOS at the lowest possible monthly cost. The product worked for that until it didn’t.

The May 2025 + March 2026 revocations together account for 22 of the 67 ELDs FMCSA has removed from the registered list since January 2025 — roughly one-third of the total enforcement action, concentrated in a single firmware family. FMCSA Administrator Derek Barrs framed the pattern bluntly on May 7:

“Since January 2025, FMCSA has taken decisive action, removing 67 noncompliant devices that failed to meet federal standards.”

Two things are notable about the Gorilla pattern specifically: (1) the firmware is reskinned and sold under multiple brand names, which means a carrier’s “vendor name” check against the registered list returns false-confidence; (2) the contract terms typical of small-fleet ELD subscriptions in this price tier — monthly auto-renew, 12–36 month commits, early-termination clauses, data-export gates — turn what looks like a clean replacement decision into a contract-fight.

That’s the carrier’s actual problem. Not “find a replacement on the list.” Find a replacement, get out of the contract on the broken device, and don’t get re-trapped by the next reskin.

The replacement filter, walked

Four bullets, in order. The order matters because each step narrows the field before the next.

1. Same form factor

Pick the same physical attachment pattern your fleet already runs. BT-OBD dongle (Bluetooth to the OBD-II port, paired with a phone app); hard-wired (under-dash install, driver-display); tablet-mount (in-cab dedicated tablet). Switching form factors mid-fleet is the most expensive mistake on this list — driver retraining, mounting hardware, app changes.

2. Same telematics tier

Match what you actually use. Basic HOS is just the logbook plus DVIR. Mid tier adds GPS tracking, IFTA fuel reporting, basic driver scoring. Full fleet management adds video, predictive maintenance, dispatcher integrations. Most owner-operators and small fleets running a Gorilla-firmware reskin were on basic HOS — buying anything more is paying for features the operation doesn’t need.

3. Vendor on the FMCSA registered list ≥ 2 years

Two years of registered-list tenure is the minimum signal of operational stability. New entrants to the list are not inherently unsafe, but they carry the same revocation-risk profile that Gorilla’s reskins carried until last spring. A two-year minimum filters out the firmware churn.

4. Verify by model number, not vendor name

This is the trap. The FMCSA list tracks device model numbers. A vendor can have multiple SKUs on the list; some registered, some not. Some pull active registration when a firmware version fails compliance. Always verify the exact model number the carrier intends to buy against the registered list — not the vendor’s marketing page, and not the device sticker without the FMCSA list cross-check.

The three candidates that survive for a 5-truck dry-van fleet, BT-OBD, basic HOS, sub-$30/month:

Vendor	Model	Form factor	Price	Notes
HOS247	FLT2	BT-OBD	~$19/mo, free hardware	Targets owner-operators; FMCSA-registered
Blue Ink Technology	BIT ELD	BT-OBD (9-pin, 6-pin, OBD-II adapter)	~$18/mo, no long-term contract	California-based since 2016; plug-and-play
Garmin	eLog (GLK-1000)	OBD-II dongle pair	One-time ~$200, zero monthly fees	Basic HOS only; data stored on driver’s phone locally

Garmin eLog is the unusual one on this list: a one-time hardware purchase with no recurring software fee, sold by a company that is not going anywhere. The trade-off is feature-floor — Garmin’s eLog does HOS and DVIR and nothing else.

The shortlist is the shortlist. Issue #1 does not name a winner. Your fleet’s existing form factor and telematics tier do the picking; the FMCSA list does the eliminating.

The cancellation fight

When FMCSA revokes a device, the carrier’s contract with the vendor is materially impaired. The device cannot legally be used. Two contract-law doctrines apply:

Frustration of purpose (Cornell LII) excuses nonperformance when an unforeseeable event destroys the agreement’s principal purpose. Test: the party’s principal purpose is substantially frustrated, the party is not at fault, and the contract was made on the basic assumption that the cause of frustration would not occur.

Supervening impossibility applies when post-contract legislation or regulation makes performance illegal. After FMCSA revocation, 49 CFR § 395.8(a)(1) makes continued use of the device an out-of-service offense. The device cannot legally perform its contracted function.

Both doctrines have a caveat: courts read them narrowly. The argument is strong but not automatic. The carrier’s job is to build the paper trail.

The script

Written cancellation request citing the FMCSA revocation notice + 49 CFR § 395.8(a)(1).
Refuse early-termination fees. Both doctrines apply. The contract’s purpose is regulatorily impossible.
If the vendor refuses: file complaints with (a) your state Attorney General’s consumer protection division — in California, oag.ca.gov/contact/consumer-complaint-against-business-or-company; (b) the Better Business Bureau; and (c) FMCSA’s National Consumer Complaint Database (NCCDB).
If the vendor sues: small-claims is the floor. The FMCSA revocation notice is admissible. Bring the device’s serial number, the registered-list status, the FMCSA newsroom URL, and your written cancellation request.

Sample cancellation letter

Copy, fill in the bracketed fields, send via certified mail or trackable email.

Subject: Notice of Contract Termination — FMCSA ELD Revocation

Dear [Vendor Compliance Officer]:

This is formal written notice that I am terminating, effective immediately, the equipment lease and service agreement dated [DATE] for the [DEVICE MODEL NAME / SERIAL NUMBER] electronic logging device (the “Device”), provided by [VENDOR NAME] to [CARRIER NAME, USDOT #].

The Federal Motor Carrier Safety Administration removed the Device from its list of registered Electronic Logging Devices on [REVOCATION DATE]. The revocation notice is published at [FMCSA newsroom URL]. Under 49 CFR § 395.8(a)(1), any motor carrier whose driver continues to operate using a revoked ELD is treated as operating without an ELD, and safety officials are directed to place the driver out of service. The Device cannot legally perform the function for which it was contracted: federally-compliant hours-of-service recordkeeping.

The contract’s principal purpose has been frustrated by the FMCSA revocation, an act of the federal regulator outside both parties’ control. Performance has further become regulatorily impossible under 49 CFR § 395.8(a)(1). On both grounds, I am terminating the agreement and refusing any early-termination fee as inapplicable to this circumstance.

I request, within fourteen (14) days of this notice: (1) written confirmation that the account is closed and no further charges will accrue; (2) refund of any prepaid subscription beyond the date of this notice; (3) a final account statement reflecting the termination; (4) export of all hours-of-service data for the statutory retention period.

If [VENDOR NAME] refuses to honor this termination, I will file complaints with my state Attorney General’s Consumer Protection division, the Better Business Bureau, and FMCSA’s National Consumer Complaint Database. If [VENDOR NAME] initiates legal action to collect, I will treat the FMCSA revocation notice as dispositive of the contract impairment in small-claims or other appropriate forum.

Sincerely, [CARRIER NAME / SIGNATORY] [USDOT # · CONTACT · DATE]

What the complaint pathways actually do

State AG consumer protection (California’s oag.ca.gov complaint flow is the model): files in an investigation queue, does not act on individual cases unless a pattern emerges. Useful for building the public record. Response time: weeks-to-months.

Better Business Bureau: mediation-style intervention. Many vendors respond to BBB complaints because their published rating is at stake. Response time: 14–30 days typical.

NCCDB (FMCSA): the federal complaint database. Files directly with FMCSA enforcement. Will not generate per-case action but is the dataset that drives the next round of vendor revocations and rulemaking. Carriers should file even when they expect no individual response — the aggregate matters.

Small-claims: the floor. Each state has its own dollar limit ($5,000–$10,000 in most). The FMCSA notice is admissible. Most ELD subscription disputes fit inside small-claims jurisdiction.

What this issue did not do

Three things Issue #1 deliberately did not promise:

Three named carrier swap stories with prices. Carrier outreach is running; the depth lands in Issue #2 or #3 once enough operators reply.
A vendor endorsement. The filter does the picking. Freight/Signal does not take vendor money or recommend products.
A guarantee that the cancellation script works. Doctrines apply; courts read them narrowly. The script is the operator’s best paper trail, not a verdict.

The shortlist is the shortlist. The script is the script. The next move is the carrier’s.

— Aman Singh · Editor · Freight/Signal · aman@freightsignal.ai · 2026-05-19

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