Reference guide · HS-7 / 3520-1
Importing a vehicle into the US
A vehicle import is an ordinary customs entry with two federal declarations attached to it. CBP wants classification, value and duty. NHTSA wants to know whether the vehicle conforms to the Federal Motor Vehicle Safety Standards or is exempt, declared on DOT form HS-7. EPA wants to know whether it meets federal emission standards or is exempt, declared on EPA form 3520-1. Each declaration stands on its own regulations, and a vehicle can be exempt from one and not the other.
The two clocks
The NHTSA exemption for older vehicles runs at twenty-five years and it is counted from the date of manufacture with the month included. A car built in March 2001 becomes importable in March 2026, not on the first of January. The declaration is made under 49 CFR part 591, which governs importation of vehicles subject to the safety, bumper and theft prevention standards.
EPA's exemption for older vehicles runs at twenty-one years under 40 CFR part 85, and it requires the vehicle to be in its original unmodified configuration. Put a modern engine in a 1998 shell and the emissions exemption is the thing you lose. Between twenty-one and twenty-five the two rules diverge, and that gap is where most of the bad advice lives: a twenty-two year old car can satisfy EPA on age alone and still need a route through NHTSA.
Newer than twenty-five
A vehicle built to a foreign specification and too young to be exempt has to be conformed. On the safety side that means a Registered Importer under 49 CFR part 592, and the model has to appear on NHTSA's list of vehicles determined eligible for importation, or you petition for an eligibility determination first. A DOT conformance bond is required on top of your customs bond. On the emissions side the parallel route runs through an Independent Commercial Importer.
Neither path is fast and neither is cheap, so price the conformance before you buy the car rather than after it is on a ship. There is also the Show or Display route for vehicles of genuine historical or technological significance, which trades the safety conformance for a hard annual mileage cap. It does not answer the EPA question, which still has to be answered separately.
What we need before the vessel arrives
- Foreign title or de-registration document, showing the seller as registered owner.
- Bill of sale or invoice, showing the price actually paid.
- Bill of lading or RoRo booking, with the VIN matching the title character for character.
- HS-7 and EPA 3520-1, completed against the correct exemption or compliance basis.
- Photographs of the VIN plate and the manufacture date plate. This is what proves the age claim, and it is the one people forget until CBP asks.
Duty, and what is stacked on it
Classification comes first. Passenger vehicles and cargo vehicles sit in different headings of HTSUS chapter 87 and carry very different ordinary rates: 2.5 percent on a passenger car against 25 percent on a cargo truck, a spread that dates from a 1963 retaliation over poultry and still decides which side of a classification argument you want to be on. Motorcycles are in their own heading again.
Above the ordinary rate, a Section 232 action on automobiles and certain automobile parts has been in force since 2025 and applies by tariff subheading rather than by vehicle age. Whether it reaches a given car is therefore a classification question, and the answer for a forty-year-old coupe is not automatically the answer for a new one. We check it per VIN against the annex in force on the entry date and quote the total before filing, not after.
On the water
A vehicle arriving in a container needs an ISF like any other cargo. A vehicle arriving RoRo is break bulk, and the ISF is still required: under 19 CFR 149.2 it is due no later than 24 hours before arrival rather than 24 hours before lading. Separately, APHIS requires the undercarriage to arrive free of foreign soil. A dirty chassis gets the car sent out for cleaning at your cost, on your time, while the terminal clock runs.
After release, which is not the end
Customs clearance is not a title. What a state motor vehicle agency generally wants is the entry summary stamped by CBP, form 7501, together with the foreign title, the bill of sale and, in most states, copies of the HS-7 and 3520-1. States differ on the rest and several require a VIN inspection before they will issue.
Ask for the stamped 7501 while the entry file is still open. Going back for it a year later, when the car is sold and the buyer's DMV has questions, is a considerably worse day than asking for it at release.
One car or a container of them
The sequence does not change with volume: confirm the age basis, classify, file the declarations correctly the first time, and have the release documents in hand before anybody needs them. Send the VIN, the build date and the foreign title and we will tell you what it takes before you commit: contact.
If the car is already booked, the useful moment to talk is now rather than the day it lands.