| Product Description | Federal Definition | Preferred State Definition | Size limits | Titling & Liens | Standards Enforcement | Taxes |
|---|---|---|---|---|---|---|
| Manufactured Home |
Means a structure, transportable in one or more sections, which, in the traveling mode, is eight body feet or more in width or forty body feet or more in length, or when erected on site is three hundred twenty or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained therein. Calculations used to determine the number of square feet in a structure will be based on the structure’s exterior dimensions measured at the largest horizontal projections when erected on site. These dimensions will include all expandable rooms, cabinets, and other projections containing interior space, but do not include bay windows. This term includes all structures which meet the above requirements except the size requirements and with respect to which the manufacturer voluntarily files a certification pursuant to 3282.13 and complies with the standards set forth in part 3280. |
Federal Law and the definition of a Manufactured Home is Preemptive of State Law. Florida Only Exception: Florida Law allows a 500 sq. ft. HUD Code built Manufactured Home to be sited in a FL Recreation Vehicle Park and for purposes of that occupancy shall be designated a Park Model which can be used for |
(Federal Preemptive size limits.) Must be larger than 320 square feet, no upward size limitations, no limit on the number of chassis, may be smaller than 320 square feet provided that the manufacturer has filed a certification with HUD that specifically allows the smaller unit to be classified as a Manufactured Home. Width of a Manufactured Home means its largest overall width in the traveling mode including cabinets and other projections, which contain interior space. Width does not include bay windows, roof projections, overhangs, or eaves under which there is no interior space. Length of a Manufactured Home means its largest overall length in the traveling mode including cabinets and other projections, which contain interior space. Length does not include bay windows, roof projections, overhangs, or eaves under which there is no interior space, nor does it include |
Titled with liens by the state (by DMV and other agencies) may have a procedure to allow the title to be surrendered to allow this unit to be reclassified as real property when it is permanently attached to the land and owned by the same individual(s). |
HUD in conjunction with State Administrative Agencies (SAA’s) mandate compliance with the Federal Manufactured Housing Construction Standards. Utilizes in-plant unannounced product inspections, dealer lot inspections for transit damage and a new effort to monitor proper set-up procedures is being |
May be taxed as personal property or in some states may be required by state law to pay a Manufactured Home tax in lieu of a local personal property tax. May, as an option, be attached to the property and as such become taxed as real estate with both the home and the land taxed as a single entity. |
| Mobile Home or Trailer Coach or Coach |
No Federal Definition | A vehicular structure built before July 15, 1976 that is not required to be constructed in conformance with Title 24 CFR, Part 3280 (HUD Code) that is designed and intended for use as a permanent dwelling, mounted on a chassis comprising of one or more sections that when connected to the required utilities includes the plumbing, heating air conditioning and electrical systems contained therein. |
No limits as to the minimum or maximum size of this structure are specified in the definition of a mobile home except as may be stipulated under the jurisdictional authority’s general or specific highway movement or oversized load permit movement regulations. Caution: The Mobile Home classification includes a few remaining units built prior to 1960 that are smaller than today’s Travel Trailers but were originally built and intended for use as permanent dwelling units but are of such a size that they can still be registered for highway use. |
Sometime defined as Trailer Coach or Coach in state law. These are confusing and outdated terms that should be eliminated. Titled with liens by the state (by DMV and other agencies) may have a procedure to allow the title to be surrendered to allow this unit to be reclassified as real property when it is permanently attached to the land and owned by the same individual(s). |
Some states had an agency imposed inspection and enforcement program as did the national trade association representing the industry, but these programs were either dissolved or were taken over when the HUD program was enacted by congress in 1976. | May be taxed as personal property or in some states may be required by state law to pay a Manufactured Home tax in lieu of a local personal property tax. May be attached to the property and as such become taxed as real estate. |
| Recreational Park Trailer | Part 3282.8 Applicability (g) Recreational Vehicles: Recreational Vehicles are not subject to this part, Part 3280, or Part 3283. A recreational vehicle is a vehicle which is: (1) built on a single chassis; (2) 400 square feet or less when measured at the largest horizontal projections; (3) self propelled or permanently towable by a light duty truck; and (4) designed primarily to be used as temporary living quarters for recreational, camping, travel or seasonal use, but not as a permanent dwelling. |
Recreational Vehicle. A vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel, or seasonal use that either has its own motive power or is mounted on, or towed by another vehicle. The basic entities are: camping trailer, fifth-wheel trailer, motor home, park trailer, travel trailer, and truck camper. Recreational Park Trailer. A recreation vehicle primarily designed and intended to provide temporary living quarters for recreation, camping or seasonal use. It is built on a single chassis, mounted on wheels with a gross trailer area not exceeding 400 square feet in the setup mode. Each recreational park trailer is certified by its manufacturer as complying with ANSI A119.5. |
May not exceed 400 square feet when erected on site as defined by the measurements used for a manufactured home as defined by 24 CFR, Part 3280 that is preemptive of state laws. May be less than 320 square feet provided that any units less than 320 square feet remain wider than 8½ feet when traveling on the highway so as to require a special movement permit. |
Defined as a Manufactured Home under federal law. However, the expressed congressional intent was to have HUD treat these units (designed and intended not for use as a permanent dwelling, but as temporary living quarters for recreational, camping, travel, or seasonal use) uniquely. As such, HUD administratively exempts Recreational Park Trailers from compliance with the HUD Construction Standards for Manufactured Homes. States generally classify these units as a type of Recreation Vehicle. About half of all states require these units to be sold by a licensed RV dealer who is, by law, responsible for collecting sales taxes, perfecting liens and titling the units, setting them up, and serving any warranty needs. Many additional states do not mandate a dealer to be licensed but have found that the same firms who are also licensed for other RV products such as Motor Homes that do require a dealer’s license make the most sales. Most states title these units as Recreational Park Trailers. Some define and classify them incorrectly as: mobile homes, trailer coaches, travel trailers or campers. Others refuse to title them as vehicles at all and require that they be sold with bills of sale with liens perfected under the UCC. Improper classifications and lack of uniformity among the states creates multiple problems when vehicles are moved state to state and apply for replacement titles or when local jurisdictional authorities are attempting to enforce local zoning and/or state taxation requirements. The improper classifications leave the local officials confused and unable to act responsively. |
Twenty states require compliance with the ANSI A119.5 Standard for all new Recreational Park Trailers sold as new. Six of these states have an in-state enforcement program that monitors the manufacturers’ conformance to the ANSI A119.5 Safety Standard. Fifteen states were originally doing the monitoring but legislators have concluded that the program only duplicates an effective safety inspection and enforcement program mandated by the trade association that represents this industry. State courts accept the ANSI A119.5 Standard for Recreational Park Trailers as a nationally recognized Safety Standard and may impose punitive or treble damage awards against manufacturers or servicing dealers who have caused damages by intentionally ignoring this standard for financial gain. |
In general a vehicle sales tax is imposed upon each sale (some states allow a credit for trade-ins). Additional taxes can be imposed as personal property at the local level unless the unit is of such a width that it may be registered for highway use and has also paid an imposed vehicle tax which may exclude this unit from a local personal property tax. |
| Travel Trailer | Part 3282.8 Applicability (g) Recreational Vehicles: Recreational Vehicles are not subject to this part, Part 3280, or Part 3283. A recreational vehicle is a vehicle which is: (1) built on a single chassis; (2) 400 square feet or less when measured at the largest horizontal projections; (3) selfpropelled or permanently towable by a light-duty truck; and (4) designed primarily not to be used as a permanent dwelling but as temporary living quarters for recreational, camping, travel or seasonal use. |
Recreational Vehicle. A vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel, or seasonal use that either has its own motive power or is mounted on, or towed by, another vehicle. The basic entities are: camping trailer, fifth wheel trailer, motor home, park trailer, travel trailer, and truck camper. Travel Trailer. A vehicular unit, mounted on wheels, designed to provide temporary living quarters for recreational, camping or travel use, of such size or weight as not to require special movement permits when towed by a motorized vehicle, and of gross trailer area less than 320 sq. ft. (29.7 m2). |
320 square feet or less but must be tow able without a special movement permit. No specific size limits except as they apply generally to any vehicle’s combination length, width and height limitations when in operation on the highway. State limits vary with the maximum width set at 102" in nearly all jurisdictions. States differ on the width allowances for appurtenances. |
They are titled with liens administered by a state agency (usually the DMV). | Twenty states mandate compliance with the ANSI A119.2 Standard for all Travel Trailers sold as new. Six of these states have an in-state enforcement program to monitor the manufacturers’ conformance to the ANSI A119.2 Safety Standard. At one time, fifteen states were enforcing the Standard but legislators have determined that the program only duplicates an effective safety inspection and enforcement program mandated by the trade association that represent this industry. State courts accept the ANSI A119.2 Standard for Recreation Vehicles as a nationally recognized Safety Standard and may impose punitive or treble damage awards against manufacturers or servicing dealers who have caused damages by intentionally ignoring this Standard for financial gain. |
In general, a vehicle sales tax is imposed upon each sale. (Some states allow a credit for tradeins.) Additional taxes for unregistered units can usually be imposed as personal property at the local level. Units registered for highway use might also be required to pay an imposed vehicle tax, which might also exclude the Travel Trailer from any local personal property taxes. |
| Fifth-Wheel Trailer | Part 3282.8 Applicability (g) Recreational Vehicles: Recreational Vehicles are not subject to this part, Part 3280, or Part 3283. A recreational vehicle is a vehicle which is: (1) built on a single chassis; (2) 400 square feet or less when measured at the largest horizontal projections; (3) selfpropelled or permanently towable by a light-duty truck; and (4) designed primarily as temporary living quarters for recreational, camping, travel or seasonal use, not as a permanent dwelling unit. | Recreational Vehicle. A vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel, or seasonal use that either has its own motive power or is mounted on, or towed by, another vehicle. The basic entities are: camping trailer, fifth wheel trailer, motor home, park trailer, travel trailer, and truck camper. Fifth-Wheel Trailer. A vehicular unit, mounted on wheels, designed to provide temporary living quarters for recreational, camping, or travel use, of such size and weight as not to require special movement permit(s), of gross trailer area not to exceed 400 sq. ft. (37.2 m2) in the set-up mode, and designed to be towed by a motorized vehicle that contains a towing mechanism that is mounted above or forward of the tow vehicles rear axle. |
Less than 400 square feet but must be towable without a special movement permit. No specific size limits except as they apply generally to any vehicle’s combination length, width and height limitations when in operation on the highway. State limits vary with the maximum width set at 102" in nearly all jurisdictions. States differ on the width allowances for appurtenances. |
Are titled with liens administered by a state agency (usually the DMV). | See above, as the ANSI A119.2 Standard also applies to Fifth-Wheel Trailers. | In general, a vehicle sales tax is imposed upon each sale. (Some states allow a credit for tradeins.) Additional taxes for unregistered units can usually be imposed as personal property at the local level. Units registered for highway use might also be required to pay an imposed vehicle tax which might also exclude the Fifth-Wheel Trailers from any local personal property taxes. |
| Camping Trailer |
Part 3282.8 Applicability (g) Recreational Vehicles: Recreational Vehicles are not subject to this part, Part 3280, or Part 3283. A recreational vehicle is a vehicle which is: (1) built on a single chassis; (2) 400 square feet or less when measured at the largest horizontal projections; (3) selfpropelled or permanently towable by a light-duty truck; and (4) designed primarily as temporary living quarters for recreational, camping, travel or seasonal use, not as a permanent dwelling unit. | Recreational Vehicle. A vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel, or seasonal use that either has its own motive power or is mounted on, or towed by, another vehicle. The basic entities are: camping trailer, fifth wheel trailer, motor home, park trailer, travel trailer, and truck camper. Camping Trailer. A vehicular portable unit mounted on wheels and constructed with collapsible partial sidewalls that fold for towing by another vehicle, and unfold at the campsite to provide temporary living quarters for recreational, camping, or travel use. |
No specific size limits except as they apply generally to any vehicle’s combination length, width and height limitations when in operation on the highway. State limits vary with the maximum width set at 102" in nearly all jurisdictions. States differ on the width allowances for appurtenances. |
Are titled with liens administered by a state agency (usually the DMV). | See the above, as the ANSI A119.2 Standard also applies to Camping Trailers. | In general a vehicle sales tax is imposed upon each sale (some states allow a credit for trade-ins). Additional taxes for unregistered units can usually be imposed as personal property at the local level. Units registered for highway use might also be required to pay an imposed vehicle tax, which might also exclude the Camping Trailer from any local personal property tax. |
| Truck Camper |
Part 3282.8 Applicability (g) Recreational Vehicles: Recreational Vehicles are not subject to this part, Part 3280, or Part 3283. A recreational vehicle is a vehicle which is: (1) built on a single chassis; (2) 400 square feet or less when measured at the largest horizontal projections; (3) selfpropelled or permanently towable by a light-duty truck; and (4) designed primarily as temporary living quarters for recreational, camping, travel or seasonal use, not as a permanent dwelling unit. | Recreational Vehicle. A vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel, or seasonal use that either has its own motive power or is mounted on, or towed by another vehicle. The basic entities are: camping trailer, fifth-wheel trailer, motor home, park trailer, travel trailer, and truck camper. Truck Camper. A portable unit constructed to provide temporary living quarters for recreational, travel or camping use, consisting of a roof, floor and sides, designed to be loaded onto and unloaded from the bed of a pickup truck. |
No specific size limits except as they apply generally to any vehicle’s width and height limitations when in operation on the highway. State limits vary with the maximum width set at 102" in nearly all jurisdictions. States differ on the width allowances for appurtenances. |
Is a titled vehicle in a few states and may be titled in California as an option. Not considered as a vehicle in most states and must be sold under a bill of sale with liens perfected using the UCC. |
See the above, as the ANSI A119.2 Standard also applies to Truck Campers. | In general if the truck camper is classified as a vehicle then a vehicle sales tax is imposed upon each sale (some states allow a credit for trade-ins). Additional taxes for unregistered units may be taxed as personal property collected at the local level. Units registered for highway use might also be required to pay an imposed vehicle tax which might also exclude this unit from any local personal property tax. |
| Motor Home | Part 3282.8 Applicability (HUD Code) NHTSA |
Recreational Vehicle. A vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel, or seasonal use that either has its own motive power or is mounted on, or towed by, another vehicle. The basic entities are: camping trailer, fifth-wheel trailer, motor home, park trailer, travel trailer, and truck camper. Motor Home. A vehicular unit designed to provide temporary living quarters for recreational, camping, or travel use, built on or permanently attached to a selfpropelled motor vehicle chassis or on a chassis cab or van that is an integral part of the completed vehicle. The vehicle must contain permanently installed independent life-support systems and provide at least four of the following facilities: cooking, refrigeration or ice box, self-contained toilet, heating and/or air- conditioning, a potable water supply system including a faucet and sink, separate 110-125 volt electrical power supply and/or LP gas supply. (Source AAMVA 1980) |
State limits vary with the maximum width set at 102" in nearly all jurisdictions. States differ on the additional width allowances for appurtenances. Most states allow a motor home to a length of 45’, which may or may not include bumpers | Are titled with liens administered by a state agency (usually the DMV). AAMVA has a legislative policy that recommends to jurisdictional authorities that these units be titled using the make, name, and model year as assigned by the Motor Home manufacturer but always using the VIN number as it was assigned by the chassis manufacturer. |
See the above, as the ANSI A119.2 Standard also applies to Motor Homes | In general a vehicle sales tax is imposed upon each sale. (Some states allow a credit for tradeins.) Additional taxes for unregistered units can usually be imposed as personal property at the local level. Units registered for highway use might also be required to pay an imposed annual vehicle tax, which usually will exclude the motor home from any local personal property tax. |