Paper Logs 8 Days or Less Rule

Pretty much that. I'm not going to give advice on what I would do, just informing you of the law as written.

 

@ZVar, isn’t there a rental truck exemption, as well?

jj Keller suggests:

• The driver must have a copy of the “rental agreement,”
• The rental agreement must clearly identify the carrier and the dates of the rental period (and that the rental period is 8 days or less in duration),
• The driver must have a copy of the Federal Register notice that created the exemption, and
• The driver must have records of duty status for the previous seven days (printouts from a previously-used AOBRD/ELD system are acceptable).

 

I'm not finding anything that deals with rentals specifically, so I would say no there isn't. At least until someone can point out a rental exemption.
This would imply it's not, by not specifically mentioning it.
Who is exempt from the ELD rule? | FMCSA
And this is kinda the same, it doesn't mention it either.
Top 6 ELD Exemptions | Zonar Systems

That said, there are a lot of exemptions out there for specific companies and specific scenarios, so if someone can show the exemption I'm always willing to learn.

 

I know the rental companies wanted an exemption, but I don't think they got one.

 

Ha! Found it! it existed, but expired October 21, 2022.

Electronic Logging Device (ELD) Exemptions, Waivers and Vendor Malfunction Extensions | FMCSA

 

Well, now, looky here....

Seems like it was extended. The answer to the question is: Yes, you may use paper logs in a rental of 8 days or less.

Using the ELD exemption for short-term rental trucks

"In place since 2017, the exemption was recently extended another five years, until October 12, 2027. Because it’s billed as “temporary,” details are not found in the regulations but rather only through announcements made in the Federal Register."

And the Federal Register announcement:
Federal Register :: Request Access


"FMCSA announces its decision to provisionally renew the Truck Renting and Leasing Association, Inc. (TRALA) exemption from the provisions that require a motor carrier to install and require each of its drivers to use an electronic logging device (ELD) to record the driver's hours-of-service (HOS). The exemption allows drivers of property carrying commercial motor vehicles (CMVs) rented for 8 days or less, regardless of reason, to not use an ELD in the vehicle. These drivers remain subject to the standard HOS limits and must maintain a paper record of duty status (RODS) if required. The exemption renewal is for 5 years."