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Commercial Vehicle
Registration Act (CVRA)
When a business sells or wants to sell
trailers less than 2,000 pounds, we must
provide correct information regarding dealer
license requirements. This information is
not clearly defined by statute. To get to
definitive answer to the applicable
requirements we must look at several
statutes. First we must look at the
definition of motor vehicle as defined in
Section 320.01 (1).
Section 320.01 (1)(a) Florida Statutes
reads, “An automobile, motorcycle, truck,
trailer, semitrailer, truck tractor and
semitrailer combination, or any other
vehicle operated on the roads of this state,
used to transport persons or property, and
propelled by power other than muscular
power, but the term does not include
traction engines, road rollers, such
vehicles as run only upon a track, bicycles,
or mopeds.”
The above statute applies only to the fact
that all trailers must be registered to be
operated upon the roads of Florida
regardless of the size or weight.
When we look at the section of the law that
applies to titling motor vehicles we find
under Section 319.20 a pound limit for
trailers requiring a title. Therefore,
trailers under 2,000 pounds net weight do
not require a title.
Section 319.20, Florida Statute reads, “The
provisions of this chapter apply
exclusively, except as otherwise specially
provided, to motor vehicles and mobile homes
required to be registered and licensed under
the laws of this state and defined by such
registration laws. The provisions of this
chapter do not apply to any moped or to any
trailer or semitrailer having a net weight
of less than 2,000 pounds. All provisions
of this chapter relating to title
certificates also apply to any recreational
vehicle type unit and to any mobile home
classified and taxed as real property
pursuant to s. 320.0815(2); and no title,
lien or other interest in such vehicle or
mobile home shall be valid unless evidenced
in accordance with this chapter.”
To determine the dealer license requirements
we look at Section 320.27 for the definition
of motor vehicle as it applies to motor
vehicle dealers.
Section 320.27(1) (b), Florida Statutes
reads, “ Motor vehicle” means any motor
vehicle of the type and kind required to be
registered and titled under chapter 319 and
this chapter, except a recreational vehicle,
moped, motorcycle powered by a motor with a
displacement of 50 cubic centimeters or
less, or mobile home.”
Section 320.27 (1) (c), reads in part,
“Motor vehicle dealer” means a person
engaged in the business of buying, selling,
or dealing in motor vehicles or offering or
displaying motor vehicles for sale at
wholesale or retail, or who may service and
repair motor vehicles pursuant to an
agreement as defined in s.320.60 (1)…”
Based on a review of Section 320.27 (1)(b)
that defines a motor vehicle of the type and
kind required to be registered and titled
and Section 320.27. (1) (c) which defines a
“ motor vehicle dealer”, and because
trailers under 2,000 pounds do not meet the
definition of “a motor vehicle”, since they
are not required to be titled, a business is
not required to hold a dealer license in
order to sell them.
Larger retail or home improvement stores are
not required to become a licensed dealer as
long as they are selling trailers under
2,000 pounds. However, if these stores sell
more than 25 trailers in a 12-month period
that weigh 2,000 pounds, they are required
to meet the license requirements of Florida
Statute 320.27.
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