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That depends. CDL requirements depend on the weight rating of the vehicle, not the weight it actually is. If you need a CDL for it when it's loaded, then you need a CDL for it when it's empty. If it's a single vehicle or a combination rated at more than 26,000 lbs, and in which the vehicle in tow is rated at 10,000 lbs. or less, then you need a Class B CDL. If the trailer is rated at more than 10,000 lbs., and the total Gross Combination Weight Rating is more than 26,000 lbs., then you need a CDL.
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