Do the rules for license plates (Chapter 14, Subchapter 7) also apply to the temporary paper buyer's tags dealers issue to new car buyers, including the 100-foot visibility rule and the no-cover rule?
Subject
Whether the temporary preprinted paper buyer's tags that licensed Arkansas dealers issue to new car buyers must comply with the license-plate display rules in Chapter 14, Subchapter 7 of the Arkansas Code, including the requirement that a license plate be visible from 100 feet and the prohibition on covers that reduce reflectivity.
Plain-English summary
A new car buyer who drives off the dealer lot in Arkansas is supposed to display a temporary paper buyer's tag while waiting for permanent registration and a metal license plate. Senator Flippo asked whether the same rules that govern metal license plates (Subchapter 7) also govern these paper tags.
The AG's answer: no. The two regimes are separate. License plates have to be readable from 100 feet in daylight (§ 27-14-715(c)) and cannot have covers that reduce reflectivity (§ 27-14-716). Paper buyer's tags have their own rule, in § 27-14-1705: they must be "visible and readable when viewing" them, with no specific distance, and they go where the permanent license plate would go. The Secretary of the Department of Finance and Administration sets the specifications for paper tags.
Because the requirements run on parallel tracks, "some of the requirements for temporary tags will overlap with license plates; some will not." The AG flagged that the buyer's tag rule does not import the 100-foot rule from § 27-14-715.
The AG also corrected a factual premise in the question: license plates are issued by the Office of Motor Vehicle when a vehicle is registered, not by dealers. Only the temporary tags are dealer-provided.
This is a follow-up to AG Op. 2024-086, which addressed the same buyer's tag versus license plate issue more broadly. Op. 2024-089 takes the same position on the specific subchapter-7-versus-subchapter-17 framing.
What this means for you
If you just bought a car in Arkansas
The dealer-issued paper tag is the legal display until your registration goes through and you get a metal plate (typically within 60 days under registration rules). You don't need to worry about whether the paper tag is "readable from 100 feet" or has reflective coating; those rules govern metal plates. But you do need the paper tag in the spot where the permanent plate would go, and it has to be visible and readable when someone looks at it.
If you are an auto dealer
Issue temporary preprinted tags following the specifications set by the Arkansas DFA Secretary. The light plastic cover that the statute requires for paper tags is not the same prohibited "cover" that § 27-14-716 outlaws for license plates; the AG explicitly read the rules as independent.
If you are a police officer enforcing display rules
Cite a paper tag violation under § 27-14-1705, not under §§ 27-14-715 or 27-14-716. The 100-foot visibility rule does not give probable cause to ticket a paper tag that is readable up close but not at distance.
If you are a traffic court attorney
This opinion (and Op. 2024-086 cross-referenced) is the AG's authority for the position that paper buyer tag display rules are independent of license-plate display rules. AG opinions are persuasive, not binding, but they are useful authority on a question that the Arkansas Code arguably leaves unclear.
Common questions
Q: How long can I drive on a paper buyer's tag?
The opinion notes that "in general, vehicles transferred to a new owner must be registered within 60 days." The 60-day window is the practical limit for relying on a paper tag.
Q: What if my paper tag is illegible because of weather damage?
The statutory test is "visible and readable when viewing" the tag. A weathered tag that fails that test would violate § 27-14-1705. The 100-foot rule still does not apply, but the basic legibility requirement does.
Q: Are dealers responsible for replacing damaged paper tags?
The opinion does not address dealer replacement obligations. The DFA Secretary sets specifications for paper tags, so practical questions about replacement, second issuance, or transfer go to DFA, not the AG.
Q: Can a paper tag be displayed somewhere other than the permanent license plate location?
No. Section 27-14-1705(d)(1)(A) requires the tag to be "placed at the location provided for the permanent motor vehicle license plate." Stickering it to the rear window or putting it in the dashboard would not comply.
Q: What about a buyer who uses § 27-14-902(a)(3)(B) to display an existing license plate on the new vehicle instead of a paper tag?
That is allowed under § 27-14-1705(j). The owner of a registered vehicle may move a current plate to a replacement vehicle rather than use a temporary paper tag.
Background and statutory framework
A.C.A. § 27-14-703. Establishes that "every motor vehicle … driven or moved upon a highway … shall be subject to the provision of this chapter," with listed exceptions. The exceptions list includes vehicles operated in conformity with provisions relating to manufacturers and dealers.
A.C.A. § 27-14-715. Issuance of license plates by the Office of Motor Vehicle on registration; the 100-foot daytime visibility requirement.
A.C.A. § 27-14-716. Display of issued license plates and the prohibition on covers that make a license plate harder to read or that reduce reflectivity.
A.C.A. § 27-14-1705. The separate regime for temporary preprinted paper buyer's tags. Sets the location requirement (where the permanent plate would go), the visibility-and-readability requirement (no specific distance), the role of the DFA Secretary in setting specifications, and the option for owners of registered vehicles to display an existing plate instead.
Citations
- A.C.A. §§ 27-14-703, 27-14-715, 27-14-716, 27-14-902(a)(3)(B), 27-14-1705
- Ark. Att'y Gen. Op. 2024-086 (companion opinion)
Source
Official summary
Question 1: Because preprinted paper buyer's tags are provided by dealers and are specifically "addressed in [A.C.A. §] 27-14-1705," are "the buyer's tag[s] … excluded [under § 27-14-703] from following the [sections] in" subchapter 7 about license plates?
Brief response: The statutory display requirements for temporary preprinted buyer's tags are independent of those for license plates, so temporary tags do not need to meet the display requirements for license plates. Some of the requirements for temporary tags will overlap with license plates; some will not.
Question 2: "How can the buyer follow both codes": the requirements for both preprinted paper buyer's tags and license plates?
Brief response: Because the requirements for temporary preprinted paper buyer's tags and license plates are independent, a buyer is not required to apply the license plate requirements to temporary tags.
Question 3: "If the rhetoric for 27-14- subchapter 7 says one thing and subchapter 17 says another, would these two codes be ambiguous?"
Brief response: Because the requirements for temporary tags and license plates do not conflict, this question is moot.
Original opinion text
Opinion No. 2024-089
January 30, 2025
The Honorable Scott Flippo
State Senator
Post Office Box 705
Bull Shoals, Arkansas 72619
Dear Senator Flippo:
I am writing in response to your request for a follow-up opinion related to Attorney General Opinion 2024-086. In that opinion, you broadly asked whether "Temporary Preprinted Buyer's Tags [are] required to follow AR Codes § 27-14- in Sub-Chapter 7." You have now asked several specific questions about that subchapter.
Initially, you note that A.C.A. § 27-14-703(1) exempts from "the provisions of this chapter," that is, Chapter 14 of Title 27, "[a]ny vehicle driven or moved upon a highway in conformance with the provisions of this chapter relating to manufacturers … [and] dealers …." You also note that, under A.C.A. § 27-14-1705, licensed dealers issue preprinted paper buyer's tags.
In your request, you state that "plates are provided by dealers," but plates are not provided by dealers. They are provided by "[t]he Office of Motor Vehicle, upon registering a vehicle." A.C.A. § 27-14-715(a). On the other hand, temporary preprinted buyer's tags can be provided by the dealer. As explained in Opinion 2024-086, temporary preprinted buyer's tags and license plates have distinct purposes and distinct requirements. They overlap in that "a temporary preprinted buyer's tag only temporarily satisfies certain buyers' duties to display a valid license plate on a vehicle" before registration.
DISCUSSION
Question 1: Because preprinted paper buyer's tags are provided by dealers and are specifically "addressed in [A.C.A. §] 27-14-1705," are "the buyer's tag[s] … excluded [under § 27-14-703] from following the [sections] in" subchapter 7 about license plates?
Under A.C.A. § 27-14-703, "[e]very motor vehicle … driven or moved upon a highway … shall be subject to the provision of this chapter." One of the requirements in Chapter 14 is that all registered vehicles have an attached license plate, which is issued when the vehicle is registered. These license plates must meet several display requirements, such as location specifications and readable-distance requirements. But before a license plate is issued at registration, there is no duty to display a license plate on the vehicle.
Instead, before being registered, a vehicle that is bought from a licensed dealer must obtain and display a temporary preprinted buyer's tag. These temporary tags have their own display requirements, some of which overlap with issued license plates; some of which don't. For example, a similarity is that the temporary tags must "be placed at the location provided for the permanent motor vehicle license plate." But unlike license plates, which must be readable from 100 feet in daylight, there is no statutory distance from which temporary tags must be visible; they need only to be "visible and readable when viewing" them. Beyond the statutory requirements for temporary tags, "[t]he Secretary of the Department of Finance and Administration shall provide specifications, form, and color of the temporary preprinted paper buyer's tag."
In other words, the statutory display requirements for temporary preprinted buyer's tags are independent of those for license plates, so temporary tags do not need to meet the display requirements for license plates. Instead, temporary tags must meet their own requirements, which are set out in § 27-14-1705 and by the Secretary of the Department of Finance and Administration. Some of the requirements will overlap with license plates; some will not.
Question 2: "How can the buyer follow both codes" — that is, the requirements for both preprinted paper buyer's tags and license plates?
As explained above, the requirements for temporary preprinted paper buyer's tags and license plates are independent, so a buyer is not required to apply the license-plate requirements to temporary tags.
Question 3: "If the rhetoric for 27-14- subchapter 7 says one thing and subchapter 17 says another, would these two codes be ambiguous?"
Because the requirements for temporary tags and license plates do not conflict, this question is moot.
Deputy Attorney General Noah P. Watson prepared this opinion, which I hereby approve.
Sincerely,
TIM GRIFFIN
Attorney General