Home Built Boats, MIC Numbers, Manufacturer Statement Of Origin And Business

Discussion in 'Boatbuilding' started by zstine, Mar 3, 2021.

  1. zstine
    Joined: Sep 2013
    Posts: 140
    Likes: 18, Points: 18, Legacy Rep: 10
    Location: New Jersey

    zstine Senior Member

    I’m preparing to build a boat for my own use and am trying to weigh the pros and cons from just doing a ‘home built’ titled by the state of NJ, or to becoming a ‘boat building business’. While I’m not planning to build to sell now, I would welcome a contract build offer if others want me to build them one after seeing mine. I have read newboatbuilders.com page and the uscg boat builders handbook.

    For my home-built, I could have NJ inspect the boat, provide a HIN (NJ Police to do their “HIN Investigation Report” form OS/SS-10A) and get an NJ title. But my understanding is that I can send an email to MICAPP@uscg.mil requesting a MIC number registration and that alone allows me to create HIN to apply to my boat..? It sounds too easy. To title a new boat, NJ also requires a “Manufactures Statement of Origin”. I’m not clear if getting a MIC number is sufficient for me to be a “manufacture” in the eyes of NJ. Do I need to have a business registration and additional compliance to generate an MSO and be a boat manufacturer?

    If I do need to register a business, that's likely a show stopper b/c I assume that opens me up to more regulation and inspections, like Permits and EPA compliance inspections for example. Obviously, a business has to file taxes and there’s start-up time and costs just to register. And since I’m building in a residential zoned garage, that likely wouldn't fly as for 'manufacturing'. ... So, I would forgo the whole business thing…. But then I guess I can’t sell any more copies, right?
     
  2. Ike
    Joined: Apr 2006
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    Location: Washington

    Ike Senior Member

    The USCG does not issue MICs to people for a one off homebuilt boats. They only issue a MIC.s to a business building and selling recreational boats. If you are just building a boat for yourself then you have to go the state route. I thought I made that clear in my website (newboatbuilders.com) but I'll have to go back and see it it needs revising. Back when I was working there we used to send a copy of the MIC assignment letter to the State Boating Law Administrator in the affected state. I don't know if they still do that.
    As far as inspections go, the Coast Guard does what they call factory visits. They are not inspections, because the people who visit are civilian contractors who do this for the Coast Guard. They are not law enforcement. If they see something wrong they will tell you and help you correct it. But that's a far as that goes. The kicker is that if you sell a boat that doesn't meet the regs, and the USCG discovers it, you will have to recall and fix all the boats that have the problem, and for a small builder that can be a huge financial burden. I have never heard of an EPA inspection of a small boatbuilder. The state may require you to get a permit as a business. I am not familiar with NJ business laws. As far as EPA requirements go, if the boat has a permanently installed fuel system it has to meet EPA requirements but you can buy that as a package deal from the tank manufacturers, you just have to hook it up. Same with inboard/ IO engines. If it's an outboard, not much for you to do, just rig the boat. If it's a fiberglass boat the MACT (styrene emissions, dust etc.) laws may apply but that may depend on the size of your business. Small businesses are excepted from a lot of Federal Regulations. But again the state may have it's own ideas on that.

    And BTW there are hundreds of builders who build boats in their garage, or barn, or backyard shed, and sell them. Generally speaking that's how many get started in the business.
     
    Will Gilmore likes this.
  3. zstine
    Joined: Sep 2013
    Posts: 140
    Likes: 18, Points: 18, Legacy Rep: 10
    Location: New Jersey

    zstine Senior Member

    Thanks for your reply and the web page is a big help. I figured that you would need a biz name, but when I searched MIC numbers, I found many builders in NJ that don't appear to have business names. hmmm, perhaps they are "sole proprietorships" and a personal name and SS is sufficient with no business EIN... ex. Untitled Document https://www.uscgboating.org/content/manufacturers-identification-detail.php?id=2614
    for my 'for-me' first boat, it sounds like the State HIN/Title method is the path of less resistance.. even if I don't need to worry about EPA coming into my garage! haha. I guess if I want to sell these I will cross that bridge and the whole business thing when it comes to that.
     
  4. Ike
    Joined: Apr 2006
    Posts: 2,673
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    Location: Washington

    Ike Senior Member

    The Coast Guard doesn't require a business name. Your name will suffice. However most states do require a business name for a business license.
     
  5. Buckethead
    Joined: Mar 2020
    Posts: 7
    Likes: 0, Points: 1
    Location: San Francisco Bay

    Buckethead Junior Member

    Let's see the boat!
     

  6. The Q
    Joined: Feb 2014
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    Location: Norfolk, UK

    The Q Senior Member

    The land of the free, have one hell of a lot more regulations than the UK, if I want to build my own boat there's none of the above until you reach 40ft ish LOA. If commercial yes there regulations, but still a lot more freedom than above.
     
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