Importing a motor vehicle into the United States or Canada involves complex federal requirements, unfamiliar ownership documents, language barriers, exemptions and fraud risks for motor vehicle agencies (MVAs). Determining whether a vehicle should be titled, registered, branded, referred for investigation or denied requires a clear review process.

AAMVA’s “Imported Vehicles: Guidance on Establishing Jurisdictional Policy” gives jurisdictions a practical framework for making those decisions consistently and confidently.

Why Titling and Registering Imported Vehicles Is Complicated

Importing a vehicle involves multiple federal agencies with complex requirements and documentation. Customs and Border Protection (CBP) processes imported vehicles first, verifying ownership, collecting duties and tariffs, reviewing entry documents, and confirming that Environmental Protection Agency (EPA) emissions requirements and National Highway Traffic Safety Administration (NHTSA) safety requirements have been addressed before the vehicle can be released to the owner or an importer for modification.

A vehicle may be lawfully imported yet ineligible for titling or registration. MVA staff are required to review complex entry documents and other supporting materials to confirm whether the vehicle is eligible for road use before it can be titled or registered. Without clear policies and procedures, agencies face inconsistent decisions, increased operational risk and greater exposure to fraud.

Noncompliant and Exempt Vehicles Add Even More Complexity

Vehicles manufactured for foreign markets may not have been originally built to U.S. safety or emissions standards. These noncompliant vehicles must either qualify for an exemption or be modified by an authorized importer—such as a registered importer for safety compliance or an independent commercial importer for emissions compliance—before they are allowed to permanently remain in the U.S. When a vehicle is deemed noncompliant, MVAs must see proof that the required modifications were completed and approved before titling or registering the vehicle for road use.

Without clear policies and procedures, agencies face inconsistent decisions, increased operational risk and greater exposure to fraud.

Additionally, some vehicles qualify for exemptions based on age, purpose or length of stay, such as age-exempt vehicles, Canadian vehicles imported for personal use, temporary imports by nonresidents, show or concept cars, off-road vehicles and incomplete vehicles or parts. Exemptions do not eliminate oversight; rather, a different set of rules applies. Therefore, MVAs need to verify whether an exemption is valid and that all conditions have been met before titling or registering the vehicle.

What This Means for MVAs

Imported vehicles create unique operational challenges. Staff may need to interpret foreign ownership documents and must understand how U.S. requirements differ from other countries. They also need to verify paperwork with limited access to the information exchanged among the CBP, NHTSA and EPA. Without a clear paper trail, MVA staff may not be able to determine whether a vehicle was legally imported, remains under bond, is still noncompliant or entered temporarily.

Timing restraints can also complicate titling. If agencies require vehicles to be titled within a specified time frame from the date of purchase, they may need to impose or waive penalties if a customer has not fulfilled the importation requirements within that time frame.

Fraud and Operational Risks

Fraud prevention is another critical concern. MVAs must be able to recognize noncompliant or exempt vehicles, identify warning signs and respond appropriately when fraud is suspected.

“The importation of vehicles into the U.S. is not immune from fraud, and there is potential for significant financial gain by those who circumvent importation and vehicle titling laws. In these situations, people seeking illegal gain will look for jurisdictions they believe will help them further their criminal enterprise,” says Paul Steier, AAMVA’s vice president of law enforcement programs and services. “MVAs have an important responsibility of preventing and detecting this fraudulent activity and the AAMVA ‘Guidance on Establishing Jurisdictional Policy’ contains information to ensure MVAs are proactive in these endeavors.”

Potential fraud risks include:

• Vehicles imported for personal use that are later sold
• Noncompliant vehicles brought in disassembled as parts
  and reassembled after importation
• Vehicles with undisclosed security interests
• Internal fraud, including staff bribery
• Undocumented or incomplete odometer history, or incorrect kilometer-to-mile conversions
• Undisclosed, unrecognizable damage
• Vehicle identification number (VIN) cloning and stolen vehicles
• Title brand fraud

How AAMVA’s Guidance Helps

AAMVA’s imported vehicles guidance document helps jurisdictions establish clear, consistent procedures for identifying noncompliant vehicles, recognizing indicators of fraud and determining whether a vehicle should be titled or registered. It provides background information and practical recommendations for establishing jurisdictional policies that emphasize safety, compliance, fraud prevention and interagency coordination.

The guidance also includes implementation tools and references, including web links and contacts for inspections, paperwork verification and consumer education; a quick-reference chart for the NHTSA HS-7 Declaration Form; a sample Office of Foreign Missions Non-eligibility Letter; and a sample U.S. Forces POV Registration/Title Certificate.

Recommended Jurisdictional Actions

To put the guidance into practice, jurisdictions should consider the following actions:

• Form internal working groups with policy, operations, legal, IT, training, investigations and communications representatives.
• Review existing statutes, administrative rules, title branding practices, inspection requirements and penalty constraints.
• Engage law enforcement, federal partners, industry representatives, consumer protection organizations and other stakeholders.
• Develop supporting materials, including staff training, inspection reports, consumer education resources and
  escalation procedures.

Imported vehicle transactions will continue to challenge MVAs as global vehicle markets, federal requirements and fraud risks evolve. AAMVA’s guidance document helps staff make informed decisions, protects consumers, supports public safety and promotes strong jurisdictional policy for consistency across multiple offices and transactions.