The Tiny House Has Wheels! What Do We Do?
Chassis provisions for Tiny Houses On Wheels have been treated like an anomaly for now 4 ICC code cycles and now it has been pushed over to the next code cycle which will not be until 2030. Affordable housing cannot wait. All across the world there is a battle for tiny houses on wheels and the question by the regulatory bodies that could approve and regulate them ” Is A Tiny House On Wheels A Structure Or A Vehicle?”. The compliance path is for both, The wheels conjure up complete confusion and they are treated like Godzilla coming down the road instead of a viable solution for housing.
Listen to second CAH hearing on October 22, 2025.
Martin Hammer Co- Author Of Appendix Q Tiny House
Second CAH Hearing Oct. 22, 2025
A Tiny House On Wheels Is Both A Vehicle And Structure
The public comment that was just heard at the second CAH hearing and turned down had the perfect and immediate pathway for adding chassis provisions for tiny houses as an I-Code change to Appendix BB Tiny Houses and they left no gaps in what was needed for a tiny house on wheels that could be approved as a dwelling. The proponents covered chassis regulations, structural requirements by an engineer, and requirements to be on a foundation, and legally hooked up to utilities.
As Vina Lustado stated at the hearing” Movable Tiny Homes sit at the intersection of building code and transportation code, yet they are NOT manufactured housing, HUD has clarified that Movable Tiny Homes are not under their purview and RV rules fail to address full time occupancy and fire life safety. ”
NHTSA Requirements For Trailers
The pathway for tiny houses on wheels, also known as movable tiny houses is already available right now, all that has to be done is address and merge the steps and intersect them so they no longer sit at the intersection of building codes, and transportation code.
How Did The ICC 1215 Standard Gain 'Consensus' On The Transportation Section?
The OSMTH 1215 committee had the opportunity and they were given the information by interested parties regarding the regulatory pathway already in existence for the chassis, but the committee has chosen to ignore the regulatory pathway for motor vehicles, which include trailers.
Small Residential Unit Data Plate In ICC 1215
The statement on the right for the builder sounds more like a boys scout pledge or a pinkie swear between two friends instead of a legitimate statement that should be on a Data Plate.
My Questions About The Data Plate And Statement
- They statement is basically giving the builder the ability to self -certify that the Movable Tiny House Is Inspected, but What Agency Inspects Them?
- How could a Movable Tiny House comply to the IRC, if Movable Tiny Houses are not in the code?
- How can a Movable Tiny House be inspected by the requirements of an AHJ, if they are only guided by ICC 1215, that has denied most federal requirements that states are mandated to follow?
NHTSA Requirement
NHTSA Requirement Certification Label For Chassis
THIS VEHICLE CONFORMS TO ALL FEDERAL MOTOR VEHICLE-SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE.
Above is an example of a self certification label that goes on a trailer chassis required by NHTSA that is placed on the chassis by the manufacturer which also includes the VIN number which the committee is denying the need for. The statement is also required by federal law.
Statutory Prohibition
I participated as an interested party for over a year and at one point it looked like there was going to be progress in referencing the FMVSS and labeling requirements which was written by an interested party who was an ex code official to assure the building official that the appropriate federal laws have been met. There was a lot of discussion on this topic, but the public comment was rejected in favor of a transportation section that is trying to override federal law and create their own rules and to create an exception for a chassis used as an independent carrier system that does not have a VIN, and is never in the NHSTA/DOT system, and is an illegal trailer that I refer to as a ‘Ghost Trailer’.
NHTSA Certification Requirements
The integrated chassis section does not give the accurate steps for a trailer manufacturer and is setting manufacturers up for failure and the potential of hefty fines for non compliance.
The Key To Regulating Tiny Houses On Wheels Will Be To Start With The Legitimate
Requirements For Trailers That Include Labels Affixed By The Manufacturer
To get tiny houses on wheels moving past the intersection of ICC, HUD, and RVs, all that has to happen is to create the path that is already in existence for each stage of compliance and to know where one’s authority begins and ends, so there is no overlap and no one is taking on a liability that they should not take on. ICC 1215 could have done this, but have chosen no to.
At the CAH hearing, there were a few building officials that were very concerned about their burden of liability and did not even feel that the IRC was the appropriate location to regulate vehicles and the ICC 1215 standard will give the building officials even less assurance toward tiny houses on wheels because of the purposeful omission of the steps for compliance.
The Standard Should Be Withdrawn
The ICC 1215 standard should be withdrawn and everyone should work on a new public comment with the proponents of RB42-25- 1 at the next ICC hearing and bring the industry together as a united front. The best work of the standard could be added to the public comment and there is potential that it could be approved for the inclusion in the 2027 IRC.
The Small Residential Unit will only bring confusion to the tiny houses industry and interrupt the progress of Appendix Q Tiny Houses.
Related Blog Post
NHTSA: Trailers And Motor Vehicles
Nov. 5, 2025
Thank you for all you are doing on behalf of those living tiny. The housing crisis continues to grow and I real feel that tiny houses could be an intragyral part of the solution. Over a million people live full-time in RV’s which are substandard and unhealthy as a full-time environment but that is what they can afford. Tiny Houses are a better solution for about the same cost. Keep pushing.
Thank you for your kind words. I thank you as well Kevin!