Who Governs Repairs in a Manufactured Home

Why this matters

On a site-built house, the question "who do I pull the permit with" has one answer: the local building department. On a manufactured home it can have four, and they do not overlap cleanly. Shops get burned two ways. They pull no permit because "HUD covers it", and the alteration fails a state inspection when the home is sold. Or they pull a local permit for work the state reserves to its own office, and the local inspector signs off on something nobody with authority ever looked at. Knowing which layer owns which work is what lets you quote the job with the right lead time.

This card explains the layers so you know whom to call. It is not legal advice, and where a job touches the home's structure or anchoring, the call goes to the state office or a licensed installer before your crew does anything.

Four layers, stacked

A manufactured home is governed by a federal floor with state and local layers on top, and the federal floor is unusually strong: for the things it covers, it preempts state and local construction codes outright. The trick is knowing what it covers. The basics of what a HUD-code home is are owned by a sibling card; see related below.

Above all four sits the private layer: the manufacturer's warranty and installation instructions, and, in a land-lease community, the park's rules. Those are not law, but a park can stop your truck at the gate and a manufacturer can deny a warranty claim, so they behave like law on the day.

Layer one: the construction code stops at the factory door

24 CFR Part 3280 sets how the home is built: structure, fire safety, plumbing, heating, electrical, thermal design. Part 3282 is the enforcement machinery: plants are inspected by approved third-party agencies, each section gets its certification label, and the manufacturer carries obligations to notify and correct certain defects.

What this layer does for you in the field:

• It tells you what the home was built to. The data plate's wind, roof load and thermal zones come from it.
• It sets the equipment rules that still bind a replacement, such as the requirement at 3280.707 that fuel-burning heating appliances be listed for manufactured-home use and keep combustion sealed from the living space. The detail of that is owned by a sibling card.
• It gives the customer a route if you find a defect that looks factory-original and dangerous: the manufacturer, the State Administrative Agency in states that have one under Part 3282, or HUD's Office of Manufactured Housing Programs. Write down what you saw and tell the customer; you are not the one who files.

What it does not do: inspect your repair. Nobody from the federal program comes out to look at a water heater swap in 2026.

Layer two: installation is federal minimum, state-run in most places

Part 3285 is the Model Manufactured Home Installation Standards: how piers are sized and spaced, how footings sit relative to frost, how anchors and straps are placed for the wind zone, how the crossovers are connected, and how skirting is ventilated and given an access opening. The manufacturer's installation instructions sit alongside it, and where they are approved and more specific, they govern that home.

Part 3286 sets the program: installers must be trained and licensed, and installations are subject to inspection. A state can run its own program if HUD approves it as meeting the federal minimum, and many do, often with stricter rules. In states without an approved program, HUD administers it directly.

For a service trade, the practical line is this: piers, footings, anchors, straps and leveling are installer work. Many states require a manufactured-home installer license to adjust them, separate from any trade license you hold. Your plumbing, electrical or mechanical license lets you repair the systems; it does not usually let you re-level the home or move a pier that is in your way.

Layer three: the state office is where the variance lives

This is the layer that differs most and costs shops the most when guessed.

• California runs manufactured housing through its Department of Housing and Community Development, and alterations to a manufactured home generally need a permit from HCD or from the local enforcement agency, depending on where the home sits.
• Texas licenses manufactured-home installers and retailers through a manufactured housing division within its state housing department.
• Some states route manufactured housing through a motor vehicle department, because the home is titled like a vehicle until it is converted to real property; others through a fire marshal, a labor department or a building codes office.

Do not take any one of these as your rule. Look up your own state's manufactured housing office once, write down which work it reserves to itself and which it leaves to local departments, and keep that page in the shop's knowledge base. It is about an hour of work and it answers every future intake call.

Layer four: the local building department

The local department typically owns:

• Utility connections and the service: the electrical pedestal or meter base, the water and sewer laterals, the gas service up to the home's inlet.
• Accessory structures: decks, steps, carports, sheds, and screened porches.
• Alterations to the home itself, where the state leaves them local.
• Zoning: setbacks, whether a manufactured home may sit on that lot at all.

Here is the preemption point stated carefully. The local department cannot impose its site-built code on the construction of the home itself where the HUD Code covers the subject. It can, and does, govern what is built next to the home and how the home is connected to the site.

Worked example: one customer, three permit paths

The request. A customer with a double-section home on private land, built in 2004, wants three things on one visit: replace the original electric furnace with a heat pump system, add a 10 ft by 12 ft screened porch against the side of the home, and fix a sagging floor in the hall bathroom where the subfloor is soft.

Split by layer before quoting. The office's job is to see three jobs with three owners, not one job.

1. Heat pump. The new indoor unit has to be listed for manufactured-home use, and it ties into the existing floor duct system and the home's panel. In this illustrative state, the local department issues mechanical and electrical permits for equipment changes on homes on private land. One permit set, one inspection, about a week of lead time as written into the quote. The outdoor unit pad and the disconnect are site work and fall under the same local permits.
2. Screened porch. Accessory structure, local building permit. The design question is whether it bears on the home. The home's manufacturer instructions, like most, expect an attached addition to be self-supporting, with its own footings and no load hung on the home's wall or chassis, and the porch is drawn that way. Two weeks lead time for plan review is quoted, and the porch is scheduled after the heat pump, not alongside it, so the porch footings do not go in where the condensing unit pad is planned.
3. Soft bathroom floor. The tech's first move is a look from underneath before quoting. If the soft spot is a rotted floor deck from a slow toilet leak, it is a repair inside the home's structure: in this state, the state office treats a floor decking replacement as an alteration needing its permit, so it gets a third path and its own lead time. If the soft spot is a pier that has settled under the frame, it is installer work, and the shop does not touch it; the office refers the customer to a licensed installer and quotes the floor only after the home is re-supported.

What the split saved. Bundled as one quote with one local permit, the floor repair would have gone in under the wrong authority, and a settled pier would have been "fixed" by shimming the floor, which hides the real support failure until it cracks a wall. Split, the customer understands why one visit became three scheduled pieces of work.

What would change it. If this same home sat in a land-lease community, the park's rules would add a fourth approval for the porch, and in some states the enforcement agency inside a community differs from the one on private land, which California handles exactly that way. If the home were pre-1976, the federal layers would not reach it at all and the state and local layers would govern alone.

Where to stop and route the call

Act on this card for intake, quoting and system repairs. Stop and route before any of these:

• Anything that touches piers, footings, anchors, straps or leveling. Walk in to a licensed installer with the HUD tag serial numbers, a photo of the data plate showing the wind zone, and photos of the condition.
• A structural alteration such as removing or cutting a wall, a floor joist or a roof truss. That goes to the state office, and often to the manufacturer or an engineer, before a saw comes out.
• A factory defect that looks like a safety hazard. Document it and give the customer the state agency or HUD route described above.

How to verify you routed it right

Before work starts, the job record should name the owner of each piece of work and the permit number or "no permit required, per" whom. If a line on the quote says "per HUD" with no state or local office named, it has not been routed yet.

References

• 24 CFR Parts 3280 and 3282, Manufactured Home Construction and Safety Standards and procedural and enforcement regulations
• 24 CFR Part 3285, Model Manufactured Home Installation Standards, and Part 3286, Manufactured Home Installation Program
• Your state's manufactured housing office, for licensing and alteration permits
• See related: Manufactured Homes: What Is Different for Every Trade; Manufactured Home Communities and the Park Owner
• See related: Equipment Listed for Manufactured Homes; The Repair That Disturbed the Tie-Downs