DOT Proposes Fentanyl Testing for CDL Drivers

On September 2, 2025, the U.S. Department of Transportation (DOT) published a Notice of Proposed Rulemaking (NPRM) that would add fentanyl and its metabolite norfentanyl to the mandatory drug testing panel for commercial truck drivers. If finalized, this would mark the first major expansion of DOT’s testing program since 2017, reflecting the growing threat of fentanyl in the broader opioid crisis.

Public comments on the proposal are open until October 17, 2025 under docket number DOT–OST–2025–0049.

Why Fentanyl Testing Is Being Added

Fentanyl is driving nearly 70% of overdose deaths nationwide, killing more than 150 Americans every day. It is 50 times stronger than heroin and 100 times stronger than morphine, making even tiny amounts potentially lethal.

While fentanyl was once mainly combined with heroin, it is now commonly used as a stand-alone drug or pressed into counterfeit pills. In the proposed rulemaking, the DOT noted:

“Fentanyl accounts for a large proportion of overdose deaths in the United States and is therefore an important public safety concern.”

For the trucking industry, this proposal addresses the increasing risk of fentanyl use among safety-sensitive workers. According to an article published in Transport Topics, carriers that already use hair follicle testing have reported a sharp rise in fentanyl positives in recent years.

What the Rule Would Change

The headline change in this proposal is adding fentanyl and norfentanyl to DOT’s testing panel. But whenever DOT updates its program, it often uses the rulemaking to adjust other parts of the process at the same time. Alongside fentanyl, DOT is suggesting several technical updates that would modernize the testing program and align it with the latest federal health guidelines.

The proposed changes include:

• Adding fentanyl to both urine and oral fluid testing, and norfentanyl to urine testing.
• Raising the morphine confirmation threshold from 2,000 ng/mL to 4,000 ng/mL.
• Eliminating the requirement for a clinical exam in certain morphine/codeine cases.

The DOT projects this change to result in an annual cost of about $18 million across nearly 7 million tests. The rule emphasizes that the safety benefits far outweigh the costs since preventing even a single major crash involving fentanyl use could justify the expense.

Current DOT Testing Requirements

Right now, DOT requires testing for five drug categories: marijuana, cocaine, amphetamines, opioids, and PCP. Testing is conducted via urine samples, with oral fluid testing authorized in 2023 but not yet widely implemented.

Fentanyl is not currently included, which means a driver could test “clean” on a DOT screen while still using one of the deadliest drugs in circulation. This rule is designed to close that gap.

When Fentanyl Testing Would Be Required

The addition of fentanyl to the DOT panel would apply to all required drug tests, including:

• Pre-employment
• Random
• Post accident
• Reasonable suspicion
• Return-to-duty and follow-up

A positive fentanyl result would trigger the same consequences as any other DOT drug violation — immediate removal from safety-sensitive duties and entry into the return-to-duty process with a Substance Abuse Professional.

When Could the Fentanyl Testing Rule Take Effect?

The public comment period runs through October 17, 2025. After reviewing the feedback, DOT is expected to issue a final rule within the next 12 to 18 months. In the meantime, carriers should continue to follow existing testing requirements and remain alert for updates.

At US Compliance Services, we track every rulemaking and regulatory change to ensure your programs remain compliant. If the fentanyl testing rule is finalized, we’ll guide you through the changes and ensure your testing program stays up to date.

If you have questions about this proposal or need support managing your DOT drug and alcohol testing compliance program, reach out anytime.