# USA: HUD sets seven steps to rewrite the manufactured home code

HUD's action plan of 7 October lists seven steps to open its 50-year-old code to homes built without a steel chassis. HousingWire reports none can be sold before the code is updated.

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The Department of Housing and Urban Development published its Next Generation Manufactured Housing Action Plan on Wednesday 7 October 2026, in press release No 26-082. The document lists seven actions the department intends to take now that Congress has removed the rule that every manufactured home must sit on a permanent chassis.

The plan is a work programme, and it changes no rule by itself. The federal regulation that defines a manufactured home still describes a structure built on a permanent chassis, and the installation standards are written around the same assumption. The rules for a home without one are still to be proposed.

HUD's release carries one sentence from Secretary Scott Turner that sums up the starting point: "For 50 years, the HUD Code has provided a national framework for safe, quality, affordable housing."

<div class="keyfacts">
<div><b>7</b><span>actions listed in HUD's plan</span></div>
<div><b>50 years</b><span>age of the HUD Code</span></div>
<div><b>12 months</b><span>length of the multifamily initiative</span></div>
</div>
<p class="src">HUD press release No 26-082 and action plan, 7 October 2026; National Institute of Building Sciences announcement, October 2026.</p>

## What the plan commits HUD to

Three of the seven actions are rulemakings on existing parts of Title 24 of the Code of Federal Regulations. Two look at building types the federal system does not cover today, and two are support work.

<figure class="fig"><figcaption><b>The seven actions in HUD's plan</b><span>Next Generation Manufactured Housing Action Plan, 7 October 2026</span></figcaption>
<div class="scroll"><table class="tbl">
<thead><tr><th>Action</th><th>What HUD says it will do</th><th>Rules concerned</th></tr></thead>
<tbody>
<tr><td>1. Energy efficiency</td><td>Run a rulemaking in line with the consensus committee's recommendations, after a regulatory impact analysis.</td><td>Part 3280</td></tr>
<tr><td>2. Chassis-free construction</td><td>Review the committee's recommendations, then propose rules on structural design, transport, lifting and connections, in a standards-based framework for homes with and without a chassis.</td><td>Part 3280</td></tr>
<tr><td>3. Foundations and installation</td><td>Review the committee's recommendations, then propose rules on foundations, anchoring, structural connections and setting procedures.</td><td>Part 3285</td></tr>
<tr><td>4. Multi-module pathway</td><td>Explore which housing types and designs made of transportable sections can fit the system while keeping substantial factory completion.</td><td>Part 3282</td></tr>
<tr><td>5. Five or more units</td><td>Develop a federal performance-based construction and safety code for larger residential buildings.</td><td>New, modelled on Part 3280</td></tr>
<tr><td>6. Case studies</td><td>Document early chassis-free projects and publish the lessons.</td><td>None</td></tr>
<tr><td>7. Manufacturer on-ramp</td><td>Write guidance and offer resources for existing modular and other off-site builders entering the federal system.</td><td>None</td></tr>
</tbody>
</table></div>
<p class="src">Source: HUD action plan. Part numbers refer to Title 24 of the Code of Federal Regulations.</p></figure>

The plan attaches no deadline to any of the seven. On actions 2 and 3 it says the Office of Manufactured Housing Programs will review future recommendations of the Manufactured Housing Consensus Committee and then propose rules. The committee is the advisory body the plan relies on to help identify where the present framework works well and where it creates barriers to innovation.

## How the HUD Code differs from a state modular code

A manufactured home is built to a single national building code, known as the HUD Code. The National Manufactured Housing Construction and Safety Standards Act of 1974 told HUD to write that code, and the department's regulations apply it to homes that entered production on or after 15 June 1976. The construction and safety standards are in Part 3280, the enforcement procedures in Part 3282 and the model installation standards in Part 3285.

The federal standard replaces local ones. Under section 3282.11, a state may keep a standard on a matter the federal code covers only if it is identical to the federal one, and it may not demand its own inspection or its own label as a condition of sale. Checking is done by private or state bodies approved by HUD: a design approval agency reviews the plans and the quality control procedures, and a production inspection agency keeps the manufacturing process under ongoing surveillance. The manufacturer's certification label is then fixed permanently to each transportable section.

A modular home is also built in a factory, but it follows another route. Section 3282.12 lets a manufacturer take a structure out of the federal Act by certifying that it is designed only for a site-built permanent foundation, is not designed to be moved once installed, and is built to a listed building code. Action 7 of the plan addresses those modular builders.

## What the July law changed

The 21st Century ROAD to Housing Act became effective on 11 July 2026, according to HUD's minutes of the consensus committee's meeting of 23 July. HUD's plan says section 301 of the Act removes the permanent chassis requirement and directs the department, in consultation with the committee, to set revised standards for homes built without one. The same section, the plan says, creates the need to review how such homes are installed, supported and fixed to the ground.

The Act also settles a question of authority. A HUD official told the committee in July that the law clarifies that HUD has primary authority over energy efficiency standards for manufactured housing. The minutes also record that the department is required to issue those standards within one year of enactment and to update them every three years after that. The committee then reviewed its 2022 recommendations on energy standards and voted unanimously, with 16 votes, to have its comments sent to the department; the action plan says the committee reaffirmed those recommendations at that meeting.

The chassis was already under review before the Act. On 12 June 2026 HUD published a proposed rule in the Federal Register to revise the definition of a manufactured home. Under it, a home of more than one storey would need a permanent chassis only under its lowest level, and the upper sections would not have to be built or transported on one. The notice limited such a home to one to four dwelling units, put the saving at roughly US$6,000 per multi-storey unit, and took comments until 11 August 2026. The Act went further and removed the requirement from the statute itself. HousingWire, reporting on that proposal on 12 June, cited Pew research of November 2025 finding that only 5 to 7 per cent of manufactured homes are moved once delivered.

## Why chassis-free homes are not on sale yet

The statute has changed and the regulations have not. On 6 October 2026, the day before the plan appeared, the definition in section 3280.2 still read: a structure transportable in one or more sections, at least 8 body feet wide or 40 body feet long in travelling mode, or 320 square feet or more when erected, and built on a permanent chassis. The definition in Part 3285 also describes a structure built on a permanent chassis. The proposed rule of June would amend both, and neither had changed by that date.

Part 3285 sets the minimum for the first installation of a new home, and every manufacturer must supply installation instructions that ensure the home is supported and anchored to meet the design loads of the construction standards.

HUD's plan does not say in so many words when a home without a chassis may be sold. HousingWire, reporting on the plan on 8 October, put it this way: HUD must first implement the changes to its code before manufacturers can sell such homes. Once that is done, the outlet wrote, manufacturers can submit chassis-free designs to HUD-approved third-party inspection agencies, and bring the homes to market once the designs are approved. Lesli Gooch, chief executive of the Manufactured Housing Institute, had explained in a July interview that more work would remain even after HUD completes its rulemaking, it added.

<figure class="fig"><figcaption><b>From statute to a home on sale</b><span>Steps 1 and 2 as HUD's plan describes them, step 3 as HousingWire reports it</span></figcaption>
<ol class="steps">
<li><b>Recommendation</b><span>The consensus committee sends HUD its recommendations on homes without a chassis.</span></li>
<li><b>Rulemaking</b><span>HUD reviews them for proposed rules updating Parts 3280 and 3285. The plan gives no date.</span></li>
<li><b>Design approval</b><span>Manufacturers submit chassis-free designs to HUD-approved inspection agencies. Once approved, they can bring the homes to market.</span></li>
</ol></figure>

The models exist in prototype. According to HousingWire, Champion Homes unveiled two chassis-free two-storey models aimed at urban infill at the 2026 Innovative Housing Showcase in Washington in September, and Cavco Industries showed the Grande Arbor, its first model without a permanent steel frame. Cavco's chief executive, William Boor, confirmed on 31 July that there is no set timeline for such models to reach the market, the outlet reported. Industry leaders, it added, acknowledge that the benefits could take at least a year to appear.

## The multifamily track

Action 5 is the furthest from present practice. HUD's release of 11 September 2024 called its final rule of that month the most extensive update of the standards in more than three decades: 90 new or updated standards and, for the first time under the HUD Code, up to four dwelling units in one manufactured home. The Federal Register shows that the rule's effective date was later moved from 17 March 2025 to 15 September 2025.

The plan now proposes a federal performance-based code for residential structures of five or more units, modelled on Part 3280. It names the questions a single home never raises: common corridors, stairs, accessibility, fire separation, shared systems and ways out.

A separate award announced the same week prepares the ground. The National Institute of Building Sciences announced that HUD had selected it, with its strategic partner MOD X, for a 12-month initiative, which HousingWire reported on 7 October. According to the institute, it is to draft a framework setting out the safety, quality and performance expectations for manufactured housing in developments of five or more units, with guidance on documenting a design and obtaining an independent technical review. The institute says the work does not change existing federal requirements, and that it will not build, run or implement demonstration projects under the award: HUD is to lead those.

## What the states must do, and what they are doing

The Act gives the states a task of their own. A summary of the bill published by the House Financial Services Committee says section 301 requires state certifications so that homes without a chassis are treated on a par with other HUD Code homes. The National Association of Realtors, in a summary of the law published on 5 August 2026, says each state must certify that its laws treat a manufactured home the same whether it is built with or without a permanent chassis, across financing, title, insurance, manufacture, sale, tax, transport and installation.

<div class="callout"><span class="mono">State deadline</span><h4>Realtors' summary puts the first state deadline at 11 July 2027</h4>
<p>According to the National Association of Realtors, certification is due within one year of enactment, and states whose legislatures meet every two years have until 11 July 2028. A state that misses a required certification must prohibit the manufacture, installation or sale of the affected homes, the association says.</p>
</div>

State legislatures have meanwhile moved on modular building under their own codes. HousingWire reported on 6 October that California's governor had signed measures the week before that curb several local building standards for qualifying factory-built projects and adjust inspection and fee rules. Tom Hardiman, executive director of the Modular Building Institute, told the outlet that seven states have adopted the ICC/MBI 1200 standards, and that he had seen more effect at state and local level than at federal level.

## What comes next

One date is set: HUD's committee minutes put the energy standards within a year of the Act's enactment. The chassis itself has no date. HousingWire notes that rulemaking and implementation timelines are not yet set, and the plan gives none for actions 2 to 5. The sequence the plan describes is committee recommendations first, then proposed rulemaking on Parts 3280 and 3285. HousingWire also reported on 6 October that a second version of the housing Act is in early-stage development among members of Congress from both parties.