What Counts as a Mobile Home

Mobile Home Park Oversight Program staff can’t provide legal advice. We’re providing this information as education.

If you’re thinking about filing a complaint, deciding whether you need to register a park, or trying to learn more about mobile home park laws, it’s important to understand what counts as a mobile home park and a mobile home under Colorado law. This page provides a summary, but you may also want to review the laws, rules, and policies relating to mobile home parks in Colorado.

Mobile Home Park

Colorado law defines a mobile home park as a property that:

• Is used for the continuous accommodation of mobile homes
• Includes five or more occupied mobile homes
• Is operated for the benefit of the landlord or their agents, lessees, or assignees

See section 38-12-201.5(6), C.R.S.

Mobile Home

To be considered a mobile home, a structure must have all six of the following characteristics. It must:

• Be a single-family dwelling
• Be built on a permanent chassis
• Be designed for long-term residential occupancy
• Contain complete electrical, plumbing, and sanitary facilities
• Be designed to be installed in a permanent or semipermanent manner with or without a permanent foundation
• Be able to be drawn over public highways

See section 38-12-201.5(5)(a), C.R.S.

The characteristic “designed for long-term residential occupancy” is important. Even though someone may be using a structure as a long-term residence or installed it in a permanent manner, that doesn’t mean the structure was designed to be used that way. The focus of the Mobile Home Park Act is on the design and intended use, not how someone uses it.

Manufactured Homes Built Since June 1976

On June 15, 1976, the federal government established standards for the construction of factory-built manufactured homes. Any manufactured home constructed according to the federal standards on or after June 15, 1976, that is in a mobile home park falls under the Mobile Home Park Act (act) and program.

See 8 CCR 1302-15, Rule 1.3 and section 38-12-201.5(5)(b), C.R.S. Also see sections 38-29-102(6) and 24-32-3302(13), C.R.S.

Mobile Homes Built Before June 1976

A manufactured home is a mobile home. This includes manufactured homes built before June 15, 1976. See sections 38-12-201.5(5)(b) and 24-32-3302(24), C.R.S.

But the home must have the six characteristics of a mobile home in section 38-12-201.5(5)(a), C.R.S.

Campers, Motor Homes, and RVs

Camper coaches, camper trailers, fifth wheel trailers, motor homes, recreational park trailers, recreational vehicles (RVs), travel trailers, and truck campers are not considered manufactured homes or mobile homes under Colorado law.

Similarly, a community that contains campers, motor homes, or RVs is not considered a mobile home park unless the community also rents space to five or more occupied mobile homes. See 8 CCR 1302-15, Rule 1.4(B).

Park Model RVs

Park model homes are generally not designed for long-term residential occupancy. Therefore, they aren’t considered mobile homes and staff can’t investigate or enforce complaints from the owners of park model RVs.

The RV Industry Association (RVIA) is a national group that inspects and certifies park model RVs. RVIA inspects and certifies that park model RVs are built to the standards of the American National Standards Institute (ANSI). If a home is built to ANSI standards, it isn’t designed for long-term residential occupancy. Therefore, it isn’t a mobile home under Colorado law and is instead considered a “recreational park trailer.”

Park model RVs certified by RVIA may have a sticker indicating the certification. If a park model home has a RVIA certification sticker, it’s not a mobile home and doesn’t fall under the act or complaint program.

If a park model home doesn’t have a RVIA sticker on it, it may not be as easy to tell whether it was designed for short-term recreational use or designed for long-term residential occupancy.

The industry standard for park model homes is that they are designed for recreational use. Therefore, the program’s default position is that a park model isn’t a mobile home, and staff can’t investigate or enforce complaints filed by or against park model owners.

If a park model home owner wants staff to investigate their complaint, they need to provide supporting documentation to demonstrate that their home was designed for long-term residential use. This could include plans or blueprints, sale or marketing information, or certifications for the home. Staff will review supporting documentation and determine whether they can investigate the complaint.

Modular Homes

Modular homes are a type of factory-built residential structure. Under Colorado law, some modular homes may be considered mobile homes.

Administrative Rule 1.3 clarifies a modular home is a mobile home if:

• It’s situated in a mobile home park
• It has all six mobile home characteristics in section 38-12-201.5(5)(a), C.R.S., including being built on a permanent chassis

See 8 CCR 1302-15, Rule 1.3.

Tiny Homes

In 2022, the Colorado General Assembly passed House Bill 2022-1242, which updated sections 24-32-3301.1-2, C.R.S., to regulate the manufacture, sale, and installation of tiny homes in Colorado. The Division of Housing worked with the State Housing Board and their Technical Advisory Committee to establish state-level design and construction standards for tiny homes by July 1, 2023.

Tiny homes built in compliance with the state design standards on or after July 1, 2023 are considered mobile homes under the act and program.

Tiny homes built before July 1, 2023 may or may not be considered mobile homes under the act. This depends on whether the tiny home has all six mobile home characteristics in section 38-12-201.5(5)(a), C.R.S.

Similar to park model homes, if the owner of a pre-July 1, 2023 tiny home wants staff to investigate their complaint, they need to provide supporting documentation to demonstrate their home was designed for long-term residential use. This could include plans or blueprints, sale or marketing information, or certifications for the home. Staff will review supporting documentation and determine whether they can investigate the complaint.