What Is IRP?
IRP is an acronym for The International Registration Plan, Inc. According to the IRP website, "the International Registration Plan (Plan) is a reciprocity agreement among states of the US, the District of Columbia and provinces of Canada which recognizes the registration of commercial motor vehicles registered by other jurisdictions."
"The unique feature of this Plan is that, even though license fees are paid to the various jurisdictions in which fleet vehicles are operated, only one license plate and one cab card is issued for each fleet vehicle when registered under the Plan. A fleet vehicle is known as an apportionable vehicle and such vehicle, so far as registration is concerned, may be operated both interjurisdictionally and intrajurisdictionally.‚"
In other words, the license fees are paid to just one jurisdiction (state or province) rather than to multiple jurisdictions, but the carrier can travel in all the member jurisdictions.
Why Does IRP Matter?
With the IRP Plan, a carrier works with one jurisdiction – the base jurisdiction – for filing and payment of licensing fees to multiple jurisdictions.
This is an improvement over the previous method of dealing directly with multiple jurisdictions; it saves time, provides stability with knowing registration requirements are being met, and minimizes the amount of paperwork (physical or electronic) for carrier to submit.
It also provides operational flexibility since it allows a carrier to transport goods in jurisdictions outside of its base (home) jurisdiction.
What Equipment Is Covered under the IRP?
All apportionable vehicles are required to use the IRP.
The technical language states that a vehicle is considered apportionable if it will travel in two or more jurisdictions, transports people or cargo, and:
- Has two axles and a gross vehicle weight or registered gross vehicle weight over 26,000 pounds, OR
- Has three or more axles, regardless of weight, OR
- Is used in combination, when the gross vehicle weight of such combination exceeds 26,000 pounds
From a practical perspective, if your vehicle has three or more axles OR the Gross Vehicle Weight (GVW) is over 26,000 pounds (with trailer), then it is considered an apportioned vehicle.
There are exceptions: recreational vehicles, vehicles displaying restricted plates, and government-owned vehicles.
Note: Trailers are not apportioned. They need to be properly registered in the base jurisdiction and are then granted ‚"free and full Reciprocity" in the other member jurisdictions. Since the IRP mileage data is based off the vehicle distance traveled, there is no IRP requirement to track the distance traveled of any associated trailers.
Do I Have To Use It?
There is no requirement to participate in the IRP for vehicles outside the scope described above even if you travel in multiple jurisdictions. You can always deal with each jurisdiction and file the applicable fees for the trip registration permits. Vehicles or combinations with a gross vehicle weight of 26,000 pounds or below, however, have the option to use the IRP but are not mandated.
If your business is all in one jurisdiction, let's say, if you only handle intrastate shipments and plan to continue to move only intrastate shipments, then there is no requirement to use the IRP regardless of vehicle size.
How is IRP Different than IFTA?
This can be confusing because both facilitate the payment of taxes across multiple jurisdictions, and both use distance travelled as part of the calculations. IFTA (International Fuel Tax Association) is designed to collect and disburse fuel taxes while IRP handles registration and license fees.
They are two different organizations with separate registration and data submission requirements. The rationale of having one organization handle the collection and payment of taxes or fees, however, applies to both organizations. If a carrier is a member of one of them, then the carrier will likely be a member of the other also.
Do ELDs Provide The NECESSARY Data?
It depends. Many Electronic Logging Devices (ELDs) will capture some of the necessary data, but not all of it. Just because an ELD complies with the Federal Motor Carrier Safety Administration's (FMCSA) criteria that does not always mean it also meets the IRP requirements. It may, or it may not.
The IRP has put out a chart that describes its requirements and the difference between its requirements versus the FMCSA.
A link to the chart can be found here.
HOW and Where Do I Register?
Registration varies by jurisdiction. In general, to select a jurisdiction as your "base jurisdiction" you need to have a physical presence (an established place of business) in the jurisdiction. The documentation for proving that varies by jurisdiction.
Generally speaking, you will need to provide proof of your base jurisdiction through documents such as:
- Utility bills
- State government identification such as driver's license
- Titles
- Tax returns
- Weapons permit (US only)
- Health care card (Canada only)
Note that not all of the above are required - it varies from jurisdiction to jurisdiction. To get the specific information for yours, click here and here.
How Are IRP Costs Calculated?
The jurisdictions you travel in will receive a prorated amount of their registration fee based on the percentage of miles your vehicle(s) travel in their jurisdictions.
For instance, if your vehicle traveled 100,000 miles in a year and of those miles 14,000 were in A, 25,000 in B, 40,000 in C, 10,000 in D, and 11,000 in E, the percentages for the jurisdictions would be:
A: 14%
B: 25%
C: 40%
D: 10%
E: 11%
If the registration fee in D was $1,500 and the registration fee in E was $1,000, then $150 (10% of $1,500) would be paid to D and $110 (11% of $1,000) to E. The others (A, B, and C) would receive their applicable payments.
Of course, you just make one payment to your base jurisdiction, and they make the payments to the other jurisdictions. But because each jurisdiction determines its own annual fees and the total due is based on the prorated amount, it is possible for two carriers to run very similar miles but pay different IRP amounts due to their proportionate mileages in the jurisdictions.
For the first year, however, you will not have reportable miles. The Average Per Vehicle Distance (APVD) calculation for your base jurisdiction is used instead. The APVD is based on the average distance vehicles from your base jurisdiction traveled to all other IRP member jurisdictions during the previous calendar year. After your first year, your actual miles will be used for the calculations.
There may also be some additional fees (administrative, etc.) that are base jurisdiction specific.
This fee estimator may be helpful in calculating your total fees.
Anything Else?
There is a great deal of information on the IRP website.
Important things to note include:
- The Reporting Period is always July 1 to June 30
- All miles (business and personal) need to be accounted for
- Fuel taxes are not covered with IRP
- The IRP is not a substitute for Operating Authority registrations
- Records must be kept for a minimum of the current and past three years
And, of course, while there are common requirements that apply to all jurisdictions, exceptions occur. Check with your base jurisdiction for specific registration requirements.
Other Related Articles:
IFTA Stickers and IFTA Reporting