April 19, 2012
M E M O R A N D U M 2012-8
TO: License Plate Issuing Officials
FROM: Jay Starling, Assistant Director
Motor Vehicle Division
SUBJECT: Mini-Trucks and Low Speed Vehicles
This memorandum will clarify several common misconceptions regarding mini-trucks and low speed vehicles.
Mini-trucks and low speed vehicles are not the same type of vehicle.
A mini-truck is defined as a four-wheeled reduced dimension truck that is not less than 48 inches wide, with an unladen
weight, including fuels and fluids, of not less than 1,500 pounds, equipped with a fully enclosed metal cab, an installed
speed governor to prevent the truck from attaining a speed of more than 25 miles per hour, headlamps, stop lamps,
front and rear turn signal lamps, tail lamps, reflex reflectors, a parking brake, rearview mirrors, windshield, seat belts,
and a nonconforming vehicle identification number (§40-12-240). See attached picture.
A low speed vehicle is defined as a four-wheeled motor vehicle with a top speed not greater than 25 miles per hour, a
gross vehicle weight rating (GVWR) of which is less than 3,000 pounds and complying with the safety standards provided
in 49 C.F.R. Section 571.500. The term includes neighborhood electric vehicles. Other examples of low speed vehicles
include ATVs, UTVs, dune buggies, rail buggies, etc.
Low speed vehicle dealers and manufacturers often advertise low speed vehicles as “street legal.” Both mini-trucks and
low speed vehicles are exempt from titling in Alabama; however, the registration requirements for mini-trucks and low
speed vehicles are different. Note that both type vehicles are exempt from titling regardless of whether they can be
registered.
Low speed vehicles may only be operated on the public roads if they are certified as meeting all federal and state
statutes, rules, and regulations governing safety, emissions, and antitheft standards. Accordingly, the license plate
issuing official must verify the following information before registering a low speed vehicle. The low speed vehicle must
have a 17 digit vehicle identification number (VIN) which conforms to National Highway Safety and Traffic
Administration (NHTSA) standards, and the manufacturer’s statement of origin (MSO) must state that the vehicle
complies with the safety standards for a low speed vehicle or that the vehicle complies with Title 49 Code of Federal
Regulations (CFR) section 571.500. The manufacturer will also affix a decal certifying that the vehicle meets these
standards. Often the MSO or bill of sale will reflect that the low speed vehicle is for off road use only, which indicates
that the low speed vehicle cannot be licensed for use on the roadways. If the MSO or bill of sale states “off road use
only”, the vehicle cannot be registered.
A mini-truck may only be issued a mini-truck license plate and cannot operate on interstate highways (§32-6-59). Mini-
truck license plates are ordered through the Plate Reservation and Ordering System (PROS) and will be mailed to the
registrant.
Prior to issuing a license plate or transferring a license plate for use on a motor vehicle that is not required to be
titled, the license plate issuing official must physically inspect the vehicle to verify that the VIN on the vehicle is the
same as the VIN on the documents required to register the vehicle [§32-8-32(b)]. This inspection will also enable
license plate issuing officials to determine whether the vehicle can be registered in Alabama. Operation of vehicles that
are not intended for use on the roadways, regardless of whether they are registered, may subject the vehicle operator
to citation by law enforcement. Note that county license plate issuing officials may utilize form MVT 5-10 (see
attachment) to appoint government officials to inspect vehicles located in Alabama on their behalf.
If you have any questions, please contact the Registration Section at (334) 242-9006 or [email protected]bama.gov.
