In 2018, the U.S. Department of Housing and Urban Development (HUD) redefined and clarified the RV exemption from manufactured housing standards. This provided a critical solution to the regulatory uncertainty that had plagued RV manufacturers, dealers and campgrounds for decades. The achievement was the result of many years of work by the RV Industry Association (RVIA)’s Government Affairs Team and the wider industry to clarify HUD’s definition of an RV, which was outdated and ambiguous as to whether HUD regulated certain larger RVs.
In the final rule, which took effect on Jan. 15, 2019, HUD created the clarity the industry sought as it exempted RVs from the Manufactured Home Construction and Safety Standards and stated multiple times in its response to commenters that its intent is to unequivocally clarify that RVs are not to be regulated by HUD.
Why does this matter?
While the rule remains a win for the RV industry, as it provides regulatory certainty for RV manufacturers, dealers, and campgrounds, it also serves as a reminder about the importance and value of the RV industry remaining self-regulated and exempt from HUD regulation. Like other rules, it can be revisited by the agency for a variety of reasons, especially since HUD explicitly states in the 2018 final rule that it has the authority to regulate the manufacture of certain RVs if it finds it necessary to do so. Given that RVs are regulated as motor vehicles by the National Highway Traffic Safety Administration and RV manufacturers adhere to nationally recognized RV standards, HUD did not find it necessary to regulate RVs. As long as RVs are built in compliance with the nationally recognized RV standards, HUD should have no reason to change its position on RVs and begin regulating RVs as housing in the future, which would unnecessarily burden RV manufacturers without benefitting RV consumers.
For more information or questions, please contact the RV Industry Association Senior Director of Government Affairs Chris Bornemann at cbornemann@rvia.org.
