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I wouldn't say it's a requirement, there are exemptions or loopholes. Not sure if it's the case anymore but it used to buy you could buy a glider semi if you wanted to, basically a brand new truck with an old engine. The advantage being no DEF and no e-logs, not sure if they put a stop to...

These are typically used as oilfield vans/buses more than likely, they're made to move people in remote locations. It's a cab chassis, so it looks like a brand new vehicle that someone canceled on their order from the factory.