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HUD Publishes Proposed Rule Clarifying RV Definition

The US Department of Urban Affairs (HUD) today published a Proposed Rule entitled Manufactured Home Procedural and Enforcement Regulations; Revision of Exemption for Recreational Vehicle. This publication represents a significant milestone in the RV industry’s 10-year effort to draw a brighter and clearer line between recreation vehicles (RVs) and manufactured housing.

HUD’s proposed rule seeks to revise the exemption for RVs that are not self-propelled and is based upon a recommendation from the Manufactured Housing Consensus Committee (MHCC), an advisory committee made up of manufactured housing producers, retailers, consumers and the general public  At the RV industry’s request, the MHCC recommended that HUD define a RV as a unit built on a vehicular structure, not certified as a manufactured home, designed only for recreational use and not as a primary residence or for permanent occupancy, and built and certified by the manufacturer in accordance with either the National Fire Protection Association (NFPA) or American National Standards Institute (ANSI) consensus standards for recreational vehicles. 

HUD is proposing to adopt the MHCC’s recommendation but modifying it to require certification with the updated ANSI standard, A119.5-15, and by including a requirement that units claiming this exemption prominently display (on a cabinet or countertop, for example) a notice stating that the unit is designed only for recreational use, and not as a primary residence or permanent dwelling until the completion of the sale of the RV.  The proposed rule narrative also requests comments on various issues around the definition of RVs.

“We are gratified to have achieved a clear and objective distinction between RVs and manufactured housing,” said RVIA President Frank Hugelmeyer. “We are grateful to Pamela Danner and the HUD staff for their hard work in expediting this rule, and we look forward to working with our industry allies at RVDA and ARVC as well as our friends at the Manufactured Housing Institute, Manufactured Housing Association for Regulatory Reform as well as state regulators and associations to provide comments and address the questions posed in HUD’s narrative around the proposal while continuing to protect the industry’s interests.”

The entire proposed rule can be found here:

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