Your Complete Guide to Navigating Federal Motorhome Regulations

What’s better than firing up your RV, hitting the asphalt, and embarking on a great-American road trip?

Well, not much. Few things compare to the freedom of the open road. But, before sparking the ignition, you’ll need to understand what federal regulations say about living out of your motorhome. Unfortunately, it’s not as cut-and-dry as you’d expect. If you’re considering diving head-first into the nomad life, here’s what you need to know.

Family vacation travel RV, holiday trip in motorhome

Clarifying the Exemption of Recreational Vehicles as They Pertain to HUD Safety Standards

Nearly half a century ago, Congress passed the National Manufactured Housing Construction and Safety Standards Act, establishing construction standards for manufactured homes. Commonly known as the “HUD Code,” these federal standards regulate all aspects of home construction, including:

Design and construction
Strength and durability
Transportability
Fire resistance
Energy efficiency

Since the inception of the HUD Code in 1976, recreational vehicles have largely been exempted from federal housing regulations. However, it’s important to note today’s motorhomes are entirely different from the pop-up campers and Airstream trailers of the 70s. As RVs evolved, HUD regulations did too.

The Need for a Broader Exemption

Prior to recent rulemaking, the RV exemption clause was widely criticized for not drawing a clear enough distinction between:

Recreational Vehicles: which are designed for temporary, recreational use
Manufactured Housing: which is designed for permanent, year-round dwelling

Over the years, this distinction became a bigger issue, as RV manufacturers began producing much larger vehicles with features that resembled manufactured homes. From extendable porches to lofted sleeping areas, these additions have raised questions as to whether oversized RVs need extra safety validations.

Essentially, there was confusion over whether the HUD should regulate larger RVs because they meet the definition of a manufactured home, or if RVs should be exempt based on their intended design: temporary and recreational use.

The HUD’s Proposed Rule: Expanding RV Exemption

To address this issue, the HUD issued a memorandum in 2014 and 2015, reiterating the method through which RVs should be measured to qualify for the RV exemption. Some key takeaways were as follows:

Fifth-wheel travel trailers, because they exceed the 320 square foot classification of a “manufactured home,” were subjected to HUD’s Manufactured Home Construction and Safety Standards and its Manufactured Home Procedural and Enforcement regulations.
After discussion and debate, the HUD voted to approve a recommendation to adopt language more clearly differentiating RVs from manufactured housing and simplify its RV exemption.

These memorandums boiled over on February 9th, 2016, when the HUD revised their definition for manufactured homes, seen in 24 CFR 3282.8 (g). Simply put, the HUD clarified—and effectively expanded—RVs as they apply to federal safety standards.

How the HUD’s Ruling Affects the RV Industry: Three Things You Need to Know

Even with the 2016 changes, concerns were still raised over the vague applications of 24 CFR 3282.8(g).

In response, on January, 25, 2019, the HUD released its last and final rule, which definitively updated the definition of RVs as “exempt from HUD regulations”. Overall, the 2019 ruling was a significant win for the RV industry. However, this new legislation still included a few provisions that motorhome owners need to be aware of:

1) The HUD Will No Longer Regulate RVs, Park-Model Recreational Vehicles (PMRV), and Fifth-Wheels

First, and most importantly, the new rule clearly establishes that the HUD has no say in regulating RVs, including PMRVs and fifth-wheels.

This is a breath of fresh air for many motorhome manufacturers, bringing much-needed certainty to the production process. In the 2014 and 2015 memoranda, there wasn’t a clear line between temporary housing and permanent housing.

With the new exemption, it was the HUD’s intent to unequivocally clarify that RVs are beyond the scope of its regulatory mission. With the new rule, motorhomes are now defined as:

Vehicles or vehicular structures not certified as manufactured homes
Designed only for recreational use, and not as a primary residence or for permanent occupancy; and either:
- Built and certified in accordance with NFPA 1192-15 or ANSI A119.5-15
- Self-propelled vehicles

2) Park-Model RV (PMRV) Manufacturers Need to Display a Separate “Manufacturer’s Notice”

For RV manufacturers, the biggest changes stemming from the January regulations are as follows:

Manufacturers need to display a safety notice in each PMRV kitchen. The notice must be displayed in “a temporary manner,” and delivered to the purchaser prior to the final stages of the sales process.
The title, MANUFACTURER’S NOTICE, must be clearly legible and at least 1 inch in size. The content needs to be typed using letters at least ½ inch in size, and must state:
- “The Manufacturer of this unit certifies that it is a Park Model Recreational Vehicle designed only for recreational use, and not for use as a primary residence or for permanent occupancy. The manufacturer of this unit further certifies that this unit has been built in accordance with the ANSI 119.5-15 consensus standard for Park Model Vehicles.”

Until the sales transaction is complete, no one—not even the purchaser—is allowed to remove the notice.

3) The Rule Will Specifically Reference the 2015 ANSI and National Fire Protection Association NFPA Standards

Finally, the new rule references the American National Standards Institute (ANSI) and the National Fire Protection Association (NFPA) 2015 editions of RV safety regulations. During these rulings, the RV Industry Association lobbied to incorporate broader references, as they didn’t want to tie safety standards to any particular year.

However, the HUD chose to follow 2015 standards, stating: “we must reference specific editions, due to the Federal Register’s rules for incorporation by reference to non-governmental publications.”

At the end of the day, the new regulations are a huge step forward for RV owners, dealers, and manufacturers alike. With less federal oversight, it’s much easier for you to get back to what matters most—exploring the open road.

mother and son watching the sunset with their motor home at the edge of the sea

Ready To Discover the Open Road? Finance Solution Can Help Get You There

Is a cross-country road trip calling your name, but RV logistics seem to be holding you back?

Don’t worry, Finance Solution is here. Whether you’re looking to refinance your current motorhome, want to qualify for a new purchase, or need to obtain an RV warranty, we’re ready to lend a helping hand. Start a conversation to learn more, and discover the difference that comes with an expert approach.