Brake Requirements-Trailers under 10001 being towed by CMV

Background: Our business operates a variety of truck and trailer types and combinations to haul our own equipment, fleet is 27 units. We haven't ever had to answer this question before so we want to ensure we reading the regs correctly. All of our current trailers, smallest is a 12k equipment trailer have brakes on all wheels. All of our trucks and the trailer we pull carry valid annual inspection stickers, to be compliant with 396.17.
We are looking at purchasing a fleet of smaller specialized units that were custom built by their previous owner. These are dual torsion axle, weight rating is 8k on these custom trailers based on the paperwork provided. However, these only have brakes on the rear trailer axle. These would be pulled by our F350 and F450s.
Our mechanic/qualified inspector was looking these trailers over and brought up that he didn't think these trailers would be able meet the criteria to for the annual inspection due to all wheels not having brakes. We thought maybe there was an exemption because of the weight being under 10001, but that does not appear to be the case (393.42). We don't mind changing the brake setup. We just want to ensure that it is needed, so we can factor that into our offer.
Any insight would be appreciated. Thanks

 

BREAKAWAYS ARE ALL NEW...WE ARE GOOD THERE! THX

 

Pedigreed Bulldog, I have a question for you. That may help us. The current plates on these vehicles are apportioned IL. This will change if we purchase to NM, but maybe you can help clarify. Do you state that IL law requires brakes on both wheels over 3K or due to FMCSA regulations it requires braking on all wheels not just the trailer being equipped with brakes per the IL law? Our rule in NM is similar.
IL Rule
"Every trailer or semitrailer of a gross weight of over 3,000 lbs. must be equipped with brakes when operated upon a highway. Such brakes must be so designed and connected that in case of an accidental breakaway of a towed vehicle over 5,000 lbs., the brakes are automatically applied."
NM Rule
"Trailers must be equipped with brakes if they have a gross weight of 3,000 lbs. or greater.
In any combination of motor-drawn vehicles, means shall be provided for applying the rearmost trailer brakes, of any trailer equipped with brakes, in approximate synchronism with the brakes on the towing vehicle."
Thanks

 

Thanks for your response.