U.S. Department of Homeland Security

United States

March 2007

Coast Guard Boating Safety Circular 85

§ 181.23 Hull identification numbers required. This applies to a boat with engine and NOT the bare hull without engine.


When a boat leaves the place of manufacture or assembly for the purposes of sale, it must comply with applicable Coast Guard safety standards and regulations: -

All boats 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

unexposed location on the interior surface of the boat or beneath a fitting or item of hardware).

Bare hull manufac turers are not boat manufacturers. There are noregulations which apply to a bare hull. Coast Guard safety standards or

Therefore, a bare hull manufacturer should n ot:

  1. affix a HIN, because the Manufacturer Identification Code in an HIN affixed to a boat identifies the entity that is legally responsible

  2. for construction of the entire bo at -- not just the hull;


    A bare hull manufacturer should not:

    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 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 that party

  3. is responsible for the certification of the entire boat.)

    Bare hull manufacturer should not:

  4. affix a certification label;

  5. affix a U.S. Coast Guard Maximum Capacities label; or

  6. install flotation.

The Flotation 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 flotation material.

, the 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 obtain a

Hull 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 regulations.

The Recreational Boating Product Assurance Division recognizes that t here are boat manufacturers with Manufacturer Identification Codes who manufacture

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 companies

should be free of HINs or other compliance labels.


At the 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

learn that kit boat manufacturers are subject to U.S. Coast Guard safety standards and regulation s.

The term, “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

vessels, components


[emphasis supplied], or associated equipmen t.”