As an overview, we must understand that while driver licensing and vehicle registration are separate, they affect each other. Driver licensing has two components. The first is to determine if you are commercial or non-commercial. Simply put, you are in a commercial status if you anticipate compensation for operating your vehicle and as such, you should have both a commercial driver license and a DOT registration on your towing vehicle. All other operations are non-commercial. If we operate our vehicle for personal use with no expectation of compensation, we are non-commercial. To repeat, if we expect compensation, we are commercial.
As stated, driver licenses are issued as commercial or non-commercial and come with qualifications (motorcycle, corrective lenses, etc.) and among those are weight restrictions/qualifications (A, B or C). Commercial covers all non-commercial use. To determine what weight restrictions/qualifications license we need is a simple matter. Find the vehicle weight rating of the towing vehicle and the towed vehicle from the VIN plates. Add them together. If they exceed 26,000 lbs., an “A” license is required. Less than 26,000 lbs. requires a “C” license. Examples: Towing vehicle with a manufacturer weight rating of 11,500 and a towed vehicle with a VIN plate rating of 16,000 lbs. requires an “A” license for the vehicle operator. That same towing vehicle pulling a trailer with a VIN weight rating of 14,000 lbs. requires a “C” license.
However, remember that regardless of weight, if you are defined as commercial, you need a commercial license for the appropriate weight classification. If we use a ½ ton pick-up and a 2-horse trailer and haul for compensation, we should have a commercial “C” license.
Next, we will address vehicle registration. When a towed vehicle (trailer) exceeds 10,000 lbs., the towing vehicle requires a CGVWR (combined gross vehicle weight rating) which is identified by the windshield weight sticker.
An example: A one-ton towing vehicle and a towed vehicle with a 15,000 lb. VIN rating may require a CGVWR of 23,000 lbs. (#8 sticker). There are other weight classifications and they each have specific requirements (flares, fire extinguishers, etc.) CGVWR is not required for a towing vehicle when the towed vehicle does not exceed 10,000 lbs.
For those of us hauling horses or other cargo, an added trailer registration titled “Recreational Cargo Trailer” (RCT) and “Recreational Trailer” (RT) [Title 75 PA.C.S. of the Vehicle Code] became available in August 2019. RCT are defined as those designed or adapted for the purpose of transporting animals or vehicles for non-commercial recreational use. Also included are Recreational Trailers (RT) which are defined as those designed or adapted (and used exclusively for recreational purposes) to provide temporary living quarters for non-commercial recreational, camping or travel use. This new registration eliminates the CGVWR for the towing vehicle while towing an RCT OR RT. We must still comply with the correct “A” or “C” license qualifications.
RCT or RT registrations over 13,000 lbs. are currently $90.00 per year but are eligible for optional permanent tags at a one-time fee of $425.00. To offset the new registration fee increase of the towed vehicle, elimination of the CGVWR for the towing vehicle may reduce the towing vehicle registration fee resulting in a long-term net saving.
In conclusion, all those who operate their horse trailers in a commercial application must follow the laws as previously written and applied. For those of us in a non-commercial application, we have a new classification of registration that may result in a financial saving.