Copart Odometer Status Explained: Actual, Not Actual, Exempt

Next to the mileage on every Copart lot sits a word that most buyers skim past: ACTUAL, NOT ACTUAL, EXEMPT, or, rarely, EXCEEDS MECHANICAL LIMITS. That one word can matter as much as the number itself. Among 2015 to 2022 Ford F-150s that went to sale at Copart US this autumn, trucks with an ACTUAL reading drew a median last pre-auction bid of US$2,100. Trucks marked NOT ACTUAL drew US$550.

This guide explains what each status means under federal law and in Copart's own words, why the exemption rule changed in 2021 and what that means for the car you're looking at, how Canada differs, and what SalvageAlert's records of more than a million auction lots show about mileage and bids.

The four statuses, in Copart's words and the law's

Copart's glossary defines its four odometer statuses in a sentence each. They follow the federal disclosure rules in 49 CFR Part 580, which require whoever transfers a car to state, in writing, one of three things about the reading.

ACTUAL. The seller certifies that the reading reflects the actual mileage. Copart's wording is more careful: the reading is "believed to be" the true mileage. It is a statement, not a measurement.

NOT ACTUAL. The reading doesn't reflect the actual mileage and shouldn't be relied on. Federal rules require a warning that a discrepancy exists, which is why many titles print "WARNING ODOMETER DISCREPANCY". Copart's definition covers two situations: the reading is known to be wrong, or the true mileage "cannot be known". The second is far more common at a salvage auction than the first. Texas, for example, prints the same NOT ACTUAL MILEAGE brand whether the odometer was tampered with, replaced, or simply conflicts with earlier records (TxDMV), and California's code N covers an odometer that is "broken, has been replaced, or the current owner is unsure of the true mileage" (California DMV).

EXCEEDS MECHANICAL LIMITS. The odometer has rolled past its maximum and started again. Virginia's DMV gives the classic example: a car showing 12,000 miles that has really covered 112,000. It's rare today: 0.2% of Copart US lots, such as this 2006 International truck in our data.

EXEMPT. No odometer disclosure is required by federal law. Copart's definition says exactly that and nothing more. EXEMPT says nothing about whether the reading is right. It only means nobody had to certify it.

The exemption rule changed in 2021

For decades, cars stopped needing an odometer statement once they were ten model years old. In 2019 NHTSA changed that. Under the current 49 CFR 580.17, in force since January 1, 2021, the old ten-year exemption stays only for model year 2010 and older. For model year 2011 and newer, disclosure is required until the car is 20 years old. NHTSA's own example: in 2031, model year 2011 and older vehicles become exempt.

So in 2026 the line is simple. A 2010 car is exempt. A 2011 car needs a mileage statement, and will until 2031. Vehicles over 16,000 lb gross weight and trailers are outside the rule altogether.

Copart's listings follow that line closely. Among the Copart US lots in our data, 53.6% of model year 2010 and older lots were listed EXEMPT, against 0.2% of model year 2011 and newer. The 1,256 newer lots listed EXEMPT were mostly not cars at all: the most common makes were Polaris, John Deere, forklifts, Can-Am, Kubota, Sea-Doo, Bobcat and trailers, which sit outside the rule anyway. Only a handful were passenger cars, such as this 2023 Ford Maverick. If you see EXEMPT on a recent car, ask why before you bid.

How common each status is

On the 770,348 Copart US lots that went to sale between August 16 and November 10, 2026, 77.9% were listed ACTUAL, 12.9% NOT ACTUAL, 9.0% EXEMPT and 0.2% EXCEEDS MECHANICAL LIMITS.

A NOT ACTUAL lot usually comes without a usable reading at all: 69% of them showed a mileage of zero or none. The listing doesn't say why, but on a wrecked, flooded or burned car the dashboard often simply can't be read. It's a reminder that NOT ACTUAL is more often about "unknown" than about fraud.

The share varies a lot by the state that issued the title. Among states with at least 2,000 lots, West Virginia titles were NOT ACTUAL or EXCEEDS on 32.4% of lots, New Mexico on 21.3%, Indiana on 20.4%, New Jersey on 19.9% and Florida on 18.7%. California, the biggest single source of Copart lots, was at 9.7%, and Georgia at 9.1%. Those gaps say as much about how each state records odometer status on salvage paperwork as about the cars.

Canada is a different system

At Copart Canada the picture flips: 57.2% of the 21,867 lots in our data were listed NOT ACTUAL, and only 29.9% ACTUAL. In Ontario NOT ACTUAL reached 66% of lots and in Alberta 62%; in Quebec it was 30%.

The likely reason is that Canada has no equivalent of the US federal odometer statement on a title. Ontario's used vehicle information package lists the odometer readings recorded when the car changed hands, but no status, and the obligations that do exist fall on dealers: Ontario's dealer rules (O. Reg. 333/08) require them to disclose when the true distance is unknown, when an odometer has been replaced or rolled back, or when it reads in miles. A Canadian salvage car arriving at auction often has no document that certifies its mileage, so NOT ACTUAL is the honest default. Read it in Canada as "unverified", and remember Canadian readings are in kilometres. If you are buying a US car to bring north, our import guide covers the paperwork.

IAA lists the status next to the reading too, for example "226,459 mi (Actual)". In our IAA Canada data the closest field is IAA's note on where the reading came from: "Actual" on 71% of lots, insurance company documents on 10%, a history report on 8% and none on 7%. A reading taken from an insurer's paperwork or a history report is not a reading someone checked on the dashboard.

What the status does to the bids

Bidders treat a NOT ACTUAL reading as bad news. For 2015 to 2022 models at Copart US, the median last pre-auction bid on ACTUAL lots against NOT ACTUAL lots was US$1,000 against US$375 for the Toyota Camry, US$950 against US$325 for the Honda Civic, US$1,150 against US$400 for the Corolla, and US$2,100 against US$550 for the F-150.

Mileage itself moves bids just as hard. Among Camrys with an ACTUAL reading, the median fell from US$2,500 under 60,000 miles to US$350 above 180,000. For F-150s it fell from US$5,200 to US$750. A NOT ACTUAL car drew about what a car with the highest mileage drew. In other words, buyers assume the worst when they can't know, which is a reasonable instinct.

As always, these are the last bids we recorded before the live sale, not final prices, and they also reflect damage and title. The damage code matters at least as much as the mileage: see our guide to Copart and IAA damage codes.

The law behind the word

The odometer rules come from the federal Motor Vehicle Information and Cost Savings Act, now at 49 U.S.C. chapter 327. It makes tampering illegal, requires the written mileage statement on transfer, and forbids a buyer for resale from accepting an incomplete one. Auctions have their own duty: under 49 CFR 580.9 they must keep, for five years, the odometer reading on the date they took possession of each car.

The penalties are real. The civil penalty set in 49 U.S.C. 32709 has been raised for inflation to US$13,676 per violation (49 CFR 578.6). A buyer defrauded by a false disclosure can sue for three times their actual damages or US$10,000, whichever is greater, plus legal fees, and must do so within two years (49 U.S.C. 32710).

How big is the problem? NHTSA's odometer fraud page still cites "more than 450,000 vehicles" sold each year with false readings. That figure comes from an NHTSA study published in 2002, which put the cost to buyers at about US$1 billion a year. It is old, but nothing newer has replaced it. At a salvage auction the bigger risk is usually not a rolled-back odometer but no trustworthy reading at all.

How to check the mileage before you bid

1. Read the status before the number. ACTUAL is a seller's statement. NOT ACTUAL and EXEMPT both mean nobody stands behind the number.
2. Check the model year against the rule. A 2011 or newer car listed EXEMPT is unusual. Ask why.
3. Look at the photos of the dashboard. If the cluster is dark, the reading on the listing may come from paperwork, not from the car.
4. Compare with the car's history. An NMVTIS report shows the last odometer reading on the title record and any "Not Actual" or "Exceeds Mechanical Limits" brand. SalvageAlert's free VIN check shows earlier Copart and IAA lots for the same car, with the mileage listed each time.
5. Price it as high mileage. Bidders do. If you're counting on the car's mileage being low, you need evidence the listing doesn't give you.

How we built this guide

The figures come from SalvageAlert's records, analysed on a copy of the database on November 11, 2026. They cover lots with a sale date between August 16 and November 10, 2026: 770,348 at Copart US and 21,867 at Copart Canada from Copart's daily Sales Data feed, where the odometer status is a one-letter code (A, N, E, X) that Copart defines, and 81,796 at IAA Canada from our lot index. We don't store IAA's odometer status for US lots. A sale date means the lot went to auction, not that it sold. Bids are the last pre-auction bid we recorded, never the final price. Mileage bands use lots with an ACTUAL reading. Shares by title state cover states with at least 2,000 lots.

The legal rules come from 49 U.S.C. 32703 to 32710, 49 CFR Parts 578 and 580 (eCFR, current as of November 2026) and NHTSA's 2019 final rule on the exemption. State examples come from the Texas, California and Virginia motor vehicle departments, and Canadian rules from Ontario Regulation 333/08, all read on November 11, 2026.