U.S. Department of Homeland
Boating Safety Circular 85
181.23 Hull identification numbers required. This applies to
a boat with engine and NOT the bare hull without engine.
VS. BARE HULLS
boat leaves the place of manufacture or assembly for the purposes of sale,
it must comply with applicable Coast Guard safety standards and regulations:
must bear two identical Hull Identification Numbers (HINs): (1) a primary
HIN (usually affixed to the transom); and (2) a duplicate HIN (affixed to an
location on the interior surface of the boat or beneath a fitting or item of
If the boat is a monohull that is less than 20
feet in length, and is not a sailboat, canoe, kayak or inflatable, it must
bear a U.S. Coast Guard Maximum Capacities label and contain
If a boat is inboard powered and uses gasoline
as fuel, it must comply with the Electrical, Fuel and Ventilation
If a boat will be outboard powered with remote
steering, shift controls must be designed for start-in-gear
If a boat is equipped with navigation lights,
the lights must be certified.
Finally, if the boat is subject to a Coast
Guard safety standard, it must bear a certification label.
bare Hull is not a boat:
bare hull builder has no way of knowing
eventual weight of the finished boat (necessary for determining safe
loading information and any required volume of flotation material).
A bare hull manufacturer has no way of knowing
whether the finished boat will be powered by an outboard or an inboard and
whether the fuel used will be gasoline or diesel.
The bare hull manufacturer does not install
naviga tion lights.
If the finished boat is later re called for
failure to comply with an applicable Coast Guard safety standard or for a
defect which creates a substantial risk of
personal injury to the public, the bare hull
should not be legally responsible for defect
notification and correction (unless, of course, such a defect involve d
complete hull failure).
hull manufac turers are not boat manufacturers. There are noregulations
which apply to a bare hull. Coast Guard safety standards or
bare hull manufacturer should n ot:
affix a HIN, because the Manufacturer
Identification Code in an HIN affixed to a boat identifies the entity that
is legally responsible
for construction of the entire bo at
-- not just the hull;
BOAT MANUFACTU RERS
bare hull manufacturer should not:
HIN, because the Manufacturer Identification Code in an HIN affixed to a
boat identifies the entity that is legally responsible for construction of
the entire boat
-- not just
the hull; (The party that puts rigs the hull
with the engine is the one that completes the bare hull into a boat and
is responsible for the certification of the entire
manufacturer should not:
affix a certification label;
affix a U.S. Coast Guard Maximum
Capacities label; or
Standard is predicated on the
assumption that a manufacturer has performed ce rtain tests in
accordance with the Safe Loading Standard. Since these tests are not
performed on bare hulls, then logically,
there is no regulat ion requiring a bare hull manufacturer to install
individual or company that buys a bare hull is subject to the regulations.
The individual who buys a bare hull to complete for his or her own use would
Identification Number from the State where he or she resides.
A company engaged in the
business of assembling a bare hull and an engine package would be the one
that should apply for a MIC, assign the Hull Identification
Number and, if necessary,
build the boat to comply with applicable Coast
Guard safety standards and
Recreational Boating Product Assurance Division recognizes that t here are boat manufacturers with Manufacturer Identification Codes who
both finished boats and bare hulls.
The f inished boats must be built to comply with the regulations;
however, the bare hulls they sell for completion by individuals or other
should be free of HINs or other compliance labels.
KIT BOAT MANUFACTURERS AND COAST GUARD SAFETY STANDARDS
end of Ses sion 403 - Wooden Kit Boats - during the International Boat
Builders’ Exhibition and Conference (IBEX) in Miami Beach, Florida on
November 2, 2006, many attendees were surprised to
that kit boat manufacturers are subject to U.S. Coast Guard safety standards
and regulation s.
“recreational vessel manufacturer” in section 2101
of Title 46, United States Code means: � ��a person engaged
in the manufacturing, construction,
assembly or importation of recreational
[emphasis supplied], or associated equipmen