How to Import a Canadian-Certified Vehicle Into the United States

First check how the vehicle was originally certified

The first question is not simply whether the vehicle came from Canada. It is whether the vehicle was originally manufactured and certified to the safety standards required for its U.S. import route.

NHTSA explains that a vehicle manufactured to comply with all applicable Federal Motor Vehicle Safety Standards (FMVSS) and bearing the original manufacturer's U.S. certification label can be imported as a conforming vehicle without a separate NHTSA eligibility determination. A vehicle carrying only Canadian certification requires a different analysis.

Do not assume that a Canadian VIN or a visually identical U.S. model proves compliance. NHTSA states that the certification label and, where applicable, information from the original manufacturer are important for establishing how a particular vehicle was manufactured.

When can a Canadian-certified vehicle use HS-7 Box 2B?

NHTSA provides a specific route for certain Canadian-certified vehicles imported for personal use. Under HS-7 Box 2B, the vehicle must be certified by its original manufacturer as complying with applicable Canadian motor vehicle safety standards and the other Box 2B conditions must be satisfied.

NHTSA's Canadian vehicle guidelines specify that this route is for a vehicle being imported for personal use and not for resale. The vehicle must not be a salvage vehicle, repaired salvage vehicle or reconstructed vehicle.

The importer must obtain a letter on the original manufacturer's letterhead, not a franchised dealer's letterhead. The letter must identify the vehicle by VIN and provide the compliance statement required by NHTSA.

What must the manufacturer letter say?

For the standard Box 2B route, NHTSA requires the original manufacturer to confirm that the specific vehicle conforms to applicable U.S. Federal Motor Vehicle Safety, Bumper and Theft Prevention Standards, subject to the limited differences permitted by the Box 2B rules.

The HS-7 declaration itself identifies permitted exceptions involving certain labeling requirements and daytime running lamp specifications. NHTSA's Canadian import guidelines also explain how certain speedometer or headlight differences can be handled.

If the manufacturer's letter identifies other deficiencies, the result can be different. For example, NHTSA states that a vehicle lacking required compliance with the automatic-restraint provisions of FMVSS No. 208 cannot be imported as a conforming vehicle under Box 2B.

Some deficiencies require proof of correction before entry

NHTSA's Canadian guidelines identify additional cases where documentary proof is required. If the manufacturer's letter states that required theft-prevention parts markings are missing, the importer must provide Customs with an invoice showing that the required markings were applied. If the issue is compliance with FMVSS No. 138 for tire pressure monitoring, NHTSA specifies documentation showing installation of the appropriate system under the conditions described in its guidelines.

When do you need a NHTSA Registered Importer?

If a Canadian-certified vehicle less than 25 years old cannot qualify for the conforming route, it may need to be imported under HS-7 Box 3. Before that can happen, NHTSA must have determined that the vehicle is eligible for importation.

NHTSA has issued blanket eligibility decisions covering many Canadian-certified vehicles because Canadian safety standards closely parallel U.S. standards, but those decisions have conditions. Some vehicles instead require an eligibility decision for the specific make, model and model year.

A Box 3 vehicle must be imported by an active NHTSA Registered Importer or by a person who has a contract with one. NHTSA maintains the official list of active Registered Importers. These are independent businesses approved to import nonconforming vehicles and perform necessary modifications.

NHTSA specifically notes that only a Registered Importer may import nonconforming vehicles for resale.

The Box 3 bond is 150% of the vehicle's entered value

A Box 3 entry requires a DOT conformance bond equal to 150% of the vehicle's entered value. The HS-7 declaration states that the bond secures the obligation to bring the vehicle into conformity within 120 days after importation or otherwise deliver it for export or abandonment as required.

The HS-7 form also requires the Registered Importer's name and NHTSA registration number and the applicable vehicle eligibility number for a Box 3 entry. A copy of the DOT bond and, when applicable, the contract with the Registered Importer are attached to the declaration.

You must also satisfy EPA emissions rules

NHTSA safety compliance is only one part of the federal import process. The U.S. Environmental Protection Agency separately regulates vehicle emissions.

EPA states that many Canadian vehicles have emissions systems identical to U.S.-certified versions, but the Canadian vehicle may not carry a label showing U.S. EPA certification. EPA says an imported Canadian vehicle is identical to a U.S.-certified version when, among the applicable routes, it has an emissions label stating that it is certified to U.S. EPA federal emissions standards or the manufacturer's U.S. representative provides a compliance letter stating that the vehicle complies with U.S. EPA regulations. EPA generally accepts compliance information from the manufacturer's U.S. or Canadian representative.

EPA also warns that U.S. Customs and Border Protection may request a manufacturer's compliance letter even when the vehicle is determined to be identical to a U.S.-certified version.

For passenger vehicles and highway motorcycles, EPA currently identifies Standard Form 3520-1 as the import declaration form. EPA also provides electronic declaration filing through CBP's Automated Commercial Environment for applicable filings.

Documents to prepare before importation

The exact documents depend on the entry route, but for the safety and emissions issues covered here you should determine the correct route before presenting the vehicle for entry.

• HS-7 Declaration with the correct entry box selected.
• The vehicle's VIN and certification-label information.
• The original manufacturer's VIN-specific compliance confirmation when using Box 2B.
• Documentation for any correction specifically required by NHTSA, when applicable.
• EPA Form 3520-1 or the applicable EPA declaration information for the vehicle.
• Evidence supporting EPA compliance, such as the applicable emissions label or manufacturer compliance information.
• For Box 3, the vehicle eligibility number, Registered Importer information, DOT conformance bond and RI contract when applicable.
• Other ownership, customs and entry records required by U.S. Customs and Border Protection for the particular import.

Use the HS-7 box that matches the vehicle's actual status

The HS-7 Declaration is the NHTSA document used to identify the legal basis for importing the vehicle. For the Canadian-certified vehicles addressed by this procedure, two routes are particularly important:

• Box 2B covers a qualifying Canadian-certified vehicle imported for personal use when the original manufacturer provides the required confirmation and all other Box 2B conditions are satisfied.
• Box 3 covers an eligible nonconforming vehicle imported through the Registered Importer process with the required bond and supporting documentation.

Do not choose Box 2B merely because the vehicle was registered or sold in Canada. Its certification, condition, purpose of import and manufacturer documentation must satisfy the Box 2B requirements.

What if the Canadian vehicle already has a U.S. certification label?

If the vehicle bears an original manufacturer's label certifying compliance with all applicable U.S. FMVSS, NHTSA treats it differently from a vehicle that carries only Canadian certification. NHTSA's current HS-7 form provides Box 2A for a vehicle that conforms to the applicable U.S. safety, bumper and theft-prevention requirements and bears the required original manufacturer certification.

This is why inspecting the actual labels before buying or transporting a Canadian vehicle can prevent unnecessary Registered Importer work.

Do not confuse NHTSA safety compliance with EPA emissions compliance

A vehicle can satisfy one federal agency's requirements without automatically satisfying the other's. NHTSA administers federal vehicle safety, bumper and theft-prevention import requirements, while EPA administers emissions requirements.

Before transporting the vehicle to the border, verify both. EPA specifically directs Canadian-vehicle importers to determine whether the vehicle is identical to a U.S.-certified version and also directs importers to NHTSA for the separate vehicle-safety rules.

Common mistakes to avoid

• Assuming every vehicle legally sold in Canada can automatically be imported permanently into the United States.
• Buying or transporting the vehicle before confirming whether the manufacturer will issue the required VIN-specific compliance letter.
• Using a dealer letter when NHTSA requires confirmation from the original manufacturer.
• Trying to use Box 2B for a salvage, repaired-salvage or reconstructed vehicle.
• Assuming a vehicle that meets NHTSA requirements automatically meets EPA emissions requirements.
• Waiting until the border to discover that the vehicle requires a Registered Importer.
• Using a Box 3 route without first confirming that the vehicle is covered by an applicable NHTSA import-eligibility decision.
• Confusing the 120-day Box 3 conformity requirement with an official processing-time estimate.

What happens after federal importation?

Federal import compliance does not by itself complete state title and registration. After the vehicle has been lawfully imported and released under the applicable federal requirements, you must follow the rules of the state where you intend to title and register it.

If the import is connected with a move between jurisdictions, the separate Helpydo guide on registering a car after moving to a different state explains why state registration is a separate process.

Before relying on the vehicle for regular road use, it is also useful to check the VIN for open safety recalls. If you later discover a safety-related defect that is not being addressed appropriately, Helpydo also explains how to report a vehicle safety defect to NHTSA.