Custom/Hybrid Aftermarket Hull Registration and HIN Talk

[OCD Solutions]

I have been doing a bit of research regarding registering my latest hull and am trying to gather as much information as I can to make this process easier for all of us, as well as educate the builders on what they can provide to make things easier. I am learning as I go so bear with me if I make incorrect statements and feel free to correct me. In an effort to keep this first post as accurate and up to date, I will be editing the context as I go so don't freak out if things change.

Long story short, aftermarket hulls do not come with a HIN.

Why not?

Well, a HIN can only be issued by a manufacturer that builds a complete, certifiable, water ready boat.

Since our hulls, as delivered, are far from water ready, we assume the responsibility of making it compliant and thus become the manufacturer. We then must register our completed boats as "homebuilt" with the local state authority.

This is the point where things get tricky and everybody's experience has been different. Every state is a bit different and even different offices within a state can differ greatly.

Some of the most common requirements seem to be;
- Bill of sale
- Sales agreement or receipt of payment
- completed application for State Issued HIN
- Payment of applicable taxes and fees

Additional things that can and have been requested;
- List of material
- Receipts for listed material
- Letter of intent
- pictures or actual presence of hull for inspection
- HIN or C/O issued by hull builder (not required and covered in further detail later)

What this boils down to is that you will have to contact your local authority and simply ask what documentation they require to process a request for a state issued "homebuilt" HIN.

*** The only reason I am going thru all this is because the particular authority I am dealing with, is insisting that the hull builder must issue the HIN. I have stated numerous times that they are exempt because it is not a complete boat but they are demanding I provide the documentation backing my statement. What you will see below is the regulations and documentation I have gathered in order to satisfy their request. I certainly hope that no one else has to go thru this but hopefully, if I do my homework, I can make it easier if they ever do.

I finally found the smoking gun on HIN's. If you run into any issues, print the following document and show it to your state authority.

As per page 3 of USCG Boating Safety Circular 85 published in March of 2007
http://www.uscgboating.org/assets/pdf/recalls/BSC85_1.pdf

BOATS VS. BARE HULLS

A bare hull is not a boat:

- A bare hull manufacturer has no way of knowing the 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 navigation lights.
- If the finished boat is later recalled 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 manufacturer should not be legally responsible for defect notification and correction (unless, of course, such a defect involved complete hull failure).

Bare hull manufacturers are not boat manufacturers.

There are no Coast Guard safety standards or regulations which apply to a bare hull. Therefore, a bare hull manufacturer should not:

(1) 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;
(2) affix a certification label;
(3) affix a U.S. Coast Guard Maximum Capacities label; or
(4) install flotation.

The Flotation Standard is predicated on the assumption that a manufacturer has performed certain tests in accordance with the Safe Loading Standard. Since these tests are not performed on bare hulls, then logically, there is no regulation requiring a bare hull manufacturer to install flotation material.

Instead, 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 there are boat manufacturers with Manufacturer Identification Codes who manufacture both finished boats and bare hulls. The finished 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.

The USCG regulates the standards to which a boat must be constructed. They issue a MIR (Manufacturers ID Code) to recognized boat builders who use that to assign HIN (Hull identification numbers) or C/O's (Certificate of Origin) to each boat before it can leave the factory.

A HIN or C/O is required to register a boat within a state and obtain a title or registration. The USCG has absolutely no involvement in this process.

Here are some of my sources;
http://www.uscgboating.org/regulations/boat_builders_handbook_and_regulations.aspx
http://newboatbuilders.com/pages/hin.html

You can download the boat handbook and read thru all the regulations here;
http://www.uscgboating.org/regulations/boatbuilder_s_handbook/downloads.aspx

You can search thru all the current listed Companies and there MIR's here;
http://www.uscgboating.org/recalls/mic1.aspx

Links to other threads on the same topic but with some specific state requirements

California: http://www.x-h2o.com/threads/131533...rick&highlight=list+of+all+hull+manufacturers

 

[subhard]

The ski clinic provides HIN on hulls, but only on rtr units. They told me when they applied the cost guard was very strict and specific that the skis had to be complete units for them to be issued.

 

[OCD Solutions]

The ski clinic provides HIN on hulls, but only on rtr units. They told me when they applied the cost guard was very strict and specific that the skis had to be complete units for them to be issued.

Well that would be a good reason.

I used that loophole when I applied for the state issued HIN on my first Matrix but I never could find documentation to back it up. I pushed hard for over a month and SCDNR finally processed it just to get rid of me. They did add a note on my file that they would only do it once and that next time, I would require a letter of exemption from the Coast Guard citing the specific exclusion or a letter from my builder citing the exclusion. I kept stating that a HIN was for a complete boat and that these were not complete RTR boats and therefore except.

So, if we can come up with that exception in writing, all we would need is a receipt from the hull builder and then we become the boat builder ourselves and can title as a homebuilt.

Now, who can come up with the exclusion? I have been looking for years without any luck. I've been hesitant to contact the USCG for fear that it is illegal

 

[OCD Solutions]

Just found this quote from the ski clinic;

That is correct. We only offer HIN and Certificate of Origin on the RTR skis that we build in house, because we are verifying that it is 'water-worthy'. We cannot issue a HIN on bare hulls, as they aren't a complete unit, just a shell that clients assemble themselves.

We had a LOT of meetings with the USCG about making this happen, and plain and simple, they told us HINs on RTR units, not incomplete units.

Sounds like the footwork with the USCG has already been done. I'd love to have DK chime in and see what they provide with their bare hulls. Hopefully they have something in writing stating the exclusion.

My next question would be on what the title says for make and model. Can it still be registered as a specific brand or does it become a generic home built unit at that point? I actually got my first Matrix registered as a Trinity Composites "Matrix ES" and I would love to have the new one done the same way.

 

[Tyrant1919]

The fact RTR units came with a HIN was 50% of the reason I bought RTR. Not to mention the other fact that I hate money. It really is sad that we can't get a simple HIN supplied with appropriate paperwork for bare hulls.

As far as a letter from a bare hull manufacturer, my BoB came with an exemption sticker on the hood. I'm not posotive if this is an RTR only thing or if this is supplied with all hoods. I still have it, I'll snap a pic for you next time. I actually brought the hood in with me when I was registering it at DMV.

 

[OCD Solutions]

That would be great.

 

[speedysprocket]

Foot Rocket has a 16 digit number in the fiber glass. I'm going to attempt to use that for registration.

 

[OCD Solutions]

Foot Rocket has a 16 digit number in the fiber glass. I'm going to attempt to use that for registration.

One of the pages I listed above explains the HIN's from other countries. Some are recognized and some are not.

 

[motozachl]

When I picked up Waternuts old stunt he got his own vin down there in GA, on the registration it just states 'homemade boat'. Handed this to my local title place, received a confused whatever face while they made a title for me.

Not sure this helps lol

 

[N3vrSat1sfied]

Without reading through every comment, You are correct the USCG will only allow the manufactor to issue HIN's on seaworthy RTR vessels. That's what Eric at EME told me. In michigan it was super easy to get a HIN issues, I just took bill of sale and invoice and they issued me a number.

I don't understand why people use old hin's off a 90 SJ or something. I got a few buddies that have done it that way. It was so easy to get the HIN! Weighing the pros and cons of legal vs illegal in this case overwhelming swings to legal! Specially for insurance purposes, I dont think a 1990 SJ will come any where close to the value of my ski.

 

[chadman154]

we just apply for a home made boat in WI and get a HIN. Simple easy and cheap. Takes less than 5 min

 

[stagesrt4]

Foot Rocket has a 16 digit number in the fiber glass. I'm going to attempt to use that for registration.

where exactly is that located?

 

[OCD Solutions]

Every state and possibly every office is different. My DNR needs a letter of exception.

 

[N3vrSat1sfied]

Every state and possibly every office is different. My DNR needs a letter of exception.

I forgot SC does it through the DNR, Michigan its all handled through the secretary of state (aka DMV for other states).

 

[Poizen]

we don't have to register Jetski's here in South Africa sometimes its nice being a backwards country

 

[OCD Solutions]

we don't have to register Jetski's here in South Africa sometimes its nice being a backwards country

Well you got us there. How many other things can you say that about though, lol.

 

[smokeysevin]

I dont think a 1990 SJ will come any where close to the value of my ski.

I actually just dealt with this yesterday. With state farm you give them 2 numbers, purchase price and value. That value must be reasonable but its your call, I just insured my stx race ski for 9000 even though I paid 500 for it initially and a good one from my model year is only 4000. They ask things like engine size and hp.

Sean

 

[N3vrSat1sfied]

I actually just dealt with this yesterday. With state farm you give them 2 numbers, purchase price and value. That value must be reasonable but its your call, I just insured my stx race ski for 9000 even though I paid 500 for it initially and a good one from my model year is only 4000. They ask things like engine size and hp.

Sean

I did mine with wakezone since mine is titled as a 2013 EME. But this may be going off topic from the op. We discussed the insurance issues here: http://www.x-h2o.com/threads/132143-How-do-you-insure-your-AM-hull-build

 

[Matt_E]

I actually just dealt with this yesterday. With state farm you give them 2 numbers, purchase price and value. That value must be reasonable but its your call, I just insured my stx race ski for 9000 even though I paid 500 for it initially and a good one from my model year is only 4000. They ask things like engine size and hp.

Sean

And your policy is for agreed-upon value, not replacement value?
Were you asked to provide receipts?

 

[OCD Solutions]

Thanks for the redirect Jordan and you bring up another question. You say yours is registered as an EME but yet homebuilt at the same time? That's what I did as well with my first Matrix and wondered if that's what caused all the trouble. Would it have been easier if I had just said it was home built? I would much rather it say Trinity on the title though so I will jump thru as many hoops as it takes.