DIY: How to import a JDM KEI class mini truck into the U.S.

DISCLAIMERS: I am not a licensed customs broker.  The information here was obtained through research and the consultation of CBP officers and import specialists.  Each port and CBP office may have their own particular way of doing things so I am not liable for any issues that arise during your importation.  That said, my information has helped many people successfully import their own vehicles.  Also, CBP understands the complexity of filing one’s own import entry and will offer significant assistance and latitude to first-timers.  Remember, they work for you and are there to help.

SHOULD YOU IMPORT A KEI TRUCK?

Importing a vehicle into the USA can be a frightening experience for someone who’s inexperienced in doing so.  The internet is full of stories of US Customs seizing vehicles which makes some question whether it’s worth the risk.  Yes, there are some risks, but for people importing a single vehicle at a time for personal use the process is actually quite simple.  I recently successfully imported my own KEI truck and have compiled this guide as a resource for anyone else who is interested in doing the same.  While I cannot guarantee that your experience will be as smooth as mine, this guide will certainly help you avoid the major pitfalls.  That said, there are many reasons why it’s preferable to purchase a KEI truck from a U.S. dealer.  You’ll hopefully get service and support as well as supporting a U.S. business.  However, there are advantages to importing your own, such as:

Typically a significantly lower price, and (maybe) better maintenance.  In Japan, vehicles must undergo a comprehensive examination periodically.  For older KEI trucks, the inspections are annually from what I’ve read.  Therefore, getting a vehicle directly from Japan will hopefully mean it’s in good mechanical condition.  Most likely the vehicle was driven in the city or in the farms and it wasn’t abused.  It also ensures that it is mostly stock so you most likely won’t have to worry about CV joint binding from bad lift jobs and other such problems.

THE U.S. IMPORT PROCESS FOR VEHICLES

When importing a vehicle into the U.S. one usually must file what’s called a formal entry.  It is a process in which an entity notifies the U.S. government what, when, where and how a commodity is entering US commerce.  To file a formal entry, one registers for a Customs importer number (a unique ID for every importer) and files entry paperwork with U.S. Customs within no earlier than a week before or no later than 10 days after the cargo arrives into port.  A Customs bond must also be purchased.

Fortunately, for shipments worth less than $2500 a formal entry is not required.  The importer can do what’s called an “informal entry”.  An informal entry does not require a customs bond nor does it require obtaining an importer number.  In addition, the importer can simply go to the Customs office at the port the cargo is entering and request assistance on how to do an informal entry.  That said, if you read this guide you will know exactly how to file your own informal entry.

This guide assumes that you live near or intend to travel to the seaport that will receive your vehicle.  If this isn’t the case you can hire a customs bonded shipping company to transport the vehicle to a customs bonded warehouse near you from which to file entry.  The other method is to hire someone to file the entry at the original seaport, get the vehicle released and then transport it normally directly to your doorstep.

CERTAIN LAWS THAT YOU SHOULD KNOW ABOUT    

Due to lobbying by Mercedes-Benz of America, Congress passed laws that require the EPA and DOT to restrict the import of non-US origin vehicles unless they meet U.S. safety and environmental standards.  Whether or not U.S. vehicles are inherently superior to vehicles from other countries is outside the scope of this document.  What is important is that YOUR VEHICLE WILL BE SEIZED UNLESS IT MEETS THESE REQUIREMENTS.  Luckily, there is a 25 year old exemption for “classic vehicles”.  If a vehicle is 25 years or older from the date of manufacture (month and year) it can legally be imported into the U.S. without having to meet DOT standards (21 years for EPA standards).  This is why current year KEI trucks are imported as “off-road vehicles with speed limiters” while older KEI trucks require no such modifications.

Some vehicles, such as the 1990 Suzuki Carry that I imported do not specify the month of manufacturer.  In such cases, there are resources online that can decode the VIN and tell you approximately a range of months that it would have been manufactured.  On my Carry the VIN showed the truck looked to be have been built around February so I used that as the month of manufacture and imported my vehicle in February.  Customs would have to prove that the vehicle wasn’t manufactured on the date specified to seize the vehicle.  FYI, seizing and detaining are different.  Customs may detain anything for inspection but to actually seize and take ownership of the item (forfeit) Customs requires an administrative or criminal violation.  Ergo, if you state the vehicle was mfg’d on 4/1990 and an engine label or seat-belt tag says differently or there is evidence that the model you’re importing did not exist in the configuration for the year you claimed than your vehicle can be seized.  Keep things on the up and up and be as transparent as possible and you will be fine.

KEY DEFINITIONS

There are certain key terms that you should be aware of:

1. Importer – the entity that is filing the customs entry (files the customs paperwork and pays the duties)
2. Consignee – The entity that will be receiving and owning the commodity (you)
3. Date of Import – When the commodity enters the Customs territorial borders of the U.S. (e.g. when a ship enters the port)
4. Date of Entry – When the paperwork is filed with Customs to apply for entry.
5. Date of Export – When the commodity was exported from the country of origin
6. Duties – A customs tax to be paid on commodities entering the U.S.  The duty on vehicles for the transportation of goods, i.e. trucks, is 25% and 2.5% for passenger vehicles.
7. Port of Entry – the port through which the commodity will enter the US
8. HTS Code – Harmonized Tariff Code.  Each commodity has a classification code that determines what duties will be paid on its import. You can search HTS codes at: hts.usitc.gov.  Perhaps the most difficult part of the process is determining the proper HTS code.  Passenger vehicles start with the HTS heading 8703 and vehicles for the transport of goods start at 8704.
9. Customs Ruling – If the HTS classification of a specific commodity is in question, e.g. should a KEI Mitsubishi Minicab with off-road tires, suspension and a dump bed be classified as a dump vehicle for off-highway use or as a standard vehicle for the transportation of goods, Customs may publish a customs ruling that will make clear exactly which HTS applies to the commodity. See (https://www.dropbox.com/s/3pxljn19bj1uamu/086305.doc?dl=0) for an example.  Rulings are published in CBP’S CUSTOMS RULINGS ONLINE SEARCH SYSTEM (CROSS).
10. Customs Bonds – Bonds for the purpose of insuring that Customs will receive payment of fees for the importation of goods. There are ISF bonds, entry bonds and DOT bonds.  Informal entries do not require the purchase of bonds.
11. Importer Security Filing 10+2 (ISF) – In 2009 a new requirement when into effect requiring formal entries by sea to submit cargo and carrier information in advance to CBP. ISF filings are required even for informal entries.
12. Harbor Maintenance Fee (HMF) – Certain ports require the payment of a HMF which is .125% of the value of the cargo. For a list of ports that require HMF see: https://www.gpo.gov/fdsys/pkg/CFR-2011-title19-vol1/pdf/CFR-2011-title19-vol1-sec24-24.pdf
13. Merchandise Processing Fee (MPF) – MPF is paid on all imports. For formal entries it is 0.3464% of the value of the cargo up to a max of $485.  For informal entries, it is $2 if the entry or release is automated and not prepared by CBP personnel, $6 if the entry or release is manual and not prepared by CBP personnel, and $9 if the entry or release, whether automated or manual, is prepared by CBP personnel.
14. Bill of Lading – The bill of lading (BOL) works as a receipt of freight services; a contract between a freight carrier and shipper and a document of title.

THE PROCESS STEP-BY-STEP

-=STEP 1=-

Contact a vehicle exporter.  They will either have an inventory of vehicles you can choose from or they can export a vehicle that you have purchased from auctions.  If importing from Japan (which applies to most of us) I would highly recommend Japancardirect.com.  They have a great track record of delivering vehicles that meet or exceed the customer’s expectations. Tradecarview.com is another great resource.  It is a marketplace for Japanese exporters and contains a large listing of Japanese vehicles for sale and features convenient search functions.

Price quotes are generally given as CIF or FOB.  CIF means that the exporter will arrange and pay for transportation of the vehicle to the port, shipping from the port to your country and insurance.  An FOB quote only includes the cost of transporting the vehicle to the outbound port and it is up to the customer to arrange for shipping and insurance.  CIF is certainly the more convenient option.

If purchasing a single vehicle, the most common shipping method is roll-on roll-off (RORO).  The vehicle will literally be driven onto the ship and off which avoids fees for renting port equipment to unload cargo.  Another benefit to not using a shipping container is that if the container gets selected for x-ray inspection by Customs, Customs will charge the importer significant fees which can be avoided by using RORO.

***IMPORTANT***

Make sure the vehicle will be thoroughly steamed cleaned so that it is pest free before export.  Otherwise, it may fail USDA inspection and you will be forced to return the vehicle or pay $$$ to house and clean it.

Typically when registering a vehicle at your local Department of Licensing they will require a vehicle title.  In some countries such as Japan, the vehicle title is turned over to the government in order to get approval for export.  This approval is in the form of an export certificate.  The exporter will provide you with the original export certificate and hopefully an English translated copy.  Make sure that the translation features a stamp or seal certifying that the translation is accurate to avoid issues with the DOL when you go to register your vehicle.

-=STEP 2=-

Pay for the vehicle.  This is almost always done via bank transfer.  If an exporter asks for payment by Western Union or MoneyGram, run!  They are most likely a scam.  Assuming you went CIF, after the exporter receives payment they will airmail you an original Bill of Lading (BOL) from the shipping line as well as a commercial invoice and a certificate of insurance.  The exporter will offer dates of arrival.  Make sure the date of arrival you choose is at least 25 years past the vehicle’s date of manufacture if you intend to file DOT and EPA exemptions.  The shipping line will then contact you and provide you a notice of arrival/freight invoice with specifics like the arrival date, the commodity being transported and instructions on how to provide payment for the collect charge.  The collect charge covers fees the port charges against the shipping line.  For my import, the collect charge amounted to $123.  You will also need to mail the original BOL that you received from the exporter to the shipping line.  Pay the collect charge and mail the BOL so that the shipping line receives them at least two days before the ship makes port if you intend to take receipt of the vehicle ASAP (assuming there isn’t a customs hold).

-=STEP 3=-

 Download CBP form 7501.  I have created a version that is electronically fillable here: https://www.dropbox.com/s/bp3z8g9rysu4vww/CBP_Form_7501.pdf?dl=0

This handbook explains how to complete this form: https://www.dropbox.com/s/r3va7hbvtow00z4/CBP%20Form%207501_Instructions.pdf?dl=0

For informal entries, the Official CBP handbook states the following:

The following blocks are to be completed for informal entries where
applicable: [1, 2, 6, 8, 10, 11, 12, 14, 16, 17, 23, 26, 27, 28, 29A, 30A, 30B, 31, 32A, 33A, 33C, 34, 35, 36, 37, 38, 39, 40, and 41]. For ABI transmissions, blocks 9,15, and 20 are also required.
When goods are released on a CBP Form 3461 and subsequently followed up by an informal entry summary (CBP Form 7501), the entry date (date of release) must be shown in block 7 on the CBP Form 7501.  Block 21, Location of Goods, will be filled in only if merchandise has been placed in a general order warehouse.

No statistical copy of the CBP Form 7501 is required for an informal entry summary.

You will see that the example I’ve provided is already populated with values that were used during the import of my Suzuki Carry truck.  You most likely won’t need to change fields 1, 2, 4, 5, 9, 16, 17, and 18.

Note: When filing an informal entry you will not have a customs entry number.

Fields 6, 19, 20 (port codes):  To determine the port codes consult this document: https://www.dropbox.com/s/o3hb1ifw24g2oji/schedule%20K%20foreign%20port%20codes.txt?dl=0

Fields 22 and 23: For informal entries, your importer number will be your social security number or IRS tax ID.

Field 21, (BLOCK 21) LOCATION OF GOODS/General Order (GO) Number):  the storage location of the vehicle after the vehicle is unloaded from the ship at port.  This location will be provided to you by the shipping line.  If the location has a customs FIRMS code you must use the code.  You can find the code here: FIRMS30_0.TXT

That said, you don’t need to fill out field 21 unless your vehicle is in a general order warehouse which means your goods made it to the port but you didn’t file your entry within 15 days and the goods were moved to a general order warehouse for storage.

Fields 27 – 30 (Commodity details): Enter your vehicle specifics in fields 27 – 30.  First, determine the proper HTS code.  There are free resources on the web that can help in determining the code, such as: https://www.simplyduty.com/import-calculator/ (this site will allow you to lookup 3 codes for free).  The HTS code starts with a 4 digit heading followed by pairs of numbers separated by decimals such as 8703.33.0045.  Each pair of numbers after a decimal denotes a more specific classification.  The heading for passenger motor vehicles is 8703 and for motor vehicles for the transportation of goods it is 8704.  Details you will need to determine the proper HTS code are engine type (spark ignition combustion (gasoline) or compression combustion (diesel), engine displacement in CC’s, engine cylinders, gross vehicle weight (GVW) in metric tons, interior volume/cargo capacity in cubic meters, cargo capacity in metric tons.  Sometimes whether to classify a motor vehicle as mainly for transporting passengers or goods isn’t as simple as it seems.  For example, a stock Mazda MPV van is classified as a motor vehicle for transporting passengers but if the rear seats are removed it is classified as being designed for the transportation of goods.  A stock Toyota 4Runner, which I would have assumed would be classified under the 8703 heading is actually classified under 8704 since the rear seats can fold down flat and it has a large cargo capacity.  If a customs ruling exists on the particular vehicle you’re importing the correct HTS code will be stated in the ruling.  Customs Rulings can be searched using CBP’S CROSS system: https://rulings.cbp.gov/home

Under the HTS code make sure you include your vehicle’s VIN number, year, make and model.  While only the VIN is required on the form, stating the other information as well may assist you in the registration of the vehicle when you get your plates.

32A (Entered value): The vehicle’s purchase price not including freight and insurance.

32B (CHGS): To determine 32B, add up the cost of all freight, port, and insurance charges incurred in importing your vehicle.  Proceed the value with the letter C.

33A (duty rate):  Calculate 34 by multiplying 32A by 33A.

39 (Other Fee Summary): Use code 501 to identify the harbor maintenance fee and 311 for Informal merchandise processing fee.  I add the descriptions as well but it’s not required.  If you’re not using a broker and are presenting the forms directly to CBP when filing entry you should use the $6 value for the MPF.

Everything else is self-explanatory.  Consult the handbook if you are unsure.

Congratulations, you have completed CBP form 7501!

-=STEP 4=-

 Complete the Department of Transportation HS-7 Short form.

Here is an electronically fillable version:

https://www.dropbox.com/s/ycvlmc6touqx0pz/hs799short.pdf?dl=0

This form is amazingly simple and self-explanatory.  Make sure the vehicle eligibility code = 1.

-=STEP 5=-

Fill out EPA form 3520 which you can obtain here:

https://www.dropbox.com/s/vxsz381vbtl61ir/3520-1.pdf?dl=0

Again, simple and self-explanatory.  Make sure the EPA exemption number = E.

 

-=STEP 6=-

An ISF 10+2 declaration must be done within 24 hours of the vehicle being loaded onto the ship at the foreign port.  The completed ISF must be filed 48 hours before the ship’s departure.  There are several customs brokers online that advertise ISF filings for a low fee, often less than $30.  A quick Google search yielded http://www.turboISF.com, http://www.easyisf.com, and http://www.ezisfusa.com.  Contact a broker and make sure you file the ISF.  They will need some information from you such as the shipping company, the BOL #, dates, etc.  The customs brokerage should give you a list of info you need to provide.  If you’re purchasing your vehicle from a professional exporter they will provide you all the information the customs broker needs to file the ISF.  A really good FAQ on the ISF program can be found at:

Click to access 10_2faq_0.pdf

For informal entries, an ISF bond is typically not required as long as CBP determines that the merchandise meets the conditions for an informal entry.

Importers have 15 days to retrieve their shipment before the cargo is sent to a General Order Warehouse where storage charges will add up quickly.  Before that happens, contact the Customs and Border Protection Office located at the inbound port and give them the documents you filled out as well as a copy of the BOL and the commercial invoice.  Pay the duty either with cash or a check (make sure you have your driver’s license if paying by check).  They will stamp two copies of your BOL and CBP form 7501 and clear your vehicle in the system.

-=STEP 7=-

 Unless the shipper has a private terminal at the inbound port, the port will most likely act as the agent for discharging your vehicle.  Your notice of arrival/freight invoice from the shipping line will specify the place your vehicle will be unloaded.  Google the facility and speak with the import specialist there.  The import specialist can tell you the status of your cargo and whether a customs hold has been placed on it.  If there is no hold and the shipping line has notified them that you have paid the collect charge and sent the original BOL they will discharge the vehicle for you.  Give them a set of the stamped BOL and CBP form 7501.  They will print off some release papers and direct you to the pickup area.  The pickup area may be a secure access area.  If so, you will either need to hire an escort with TWIC credentials to escort you to your vehicle (the port’s website should provide a list of escorts for a nominal fee, usually $50) or if you have a U.S. military CAC card or a US Federal Government PIV card you can get through without an escort.  Go through the gate and find the import supervisor and give him your discharge document.  He’ll direct you to your vehicle which will likely be parked among other very cool vehicles.  Spend some time appreciating them.  Climb into your vehicle.  Your keys will be in the ignition.   Your vehicle’s fuel tank will most likely be near empty.  Prepare to town your vehicle home if you don’t have insurance and a trip permit.

-=STEP 8=-

Proceed to your Department of Licensing office and give them your remaining stamped form 7501, the Japan export certificate and the commercial invoice.  The value of the vehicle (not including freight) from the commercial invoice will be used to calculate your state taxes.  Some states like Texas require the vehicle to pass a safety and emissions inspection.  As long as the vehicle’s original safety and emissions equipment are intact (braking system, indicator lights, horn, headlights, muffler, etc.) the vehicle should pass.

Get your new plates.  You’ll notice that the screw holes on the plates won’t match up with Japanese plate mounts.  Whip out your drill and drill new holes in the plates (don’t drill the plate mounts on the car!!).  Mount your plates and enjoy your vehicle.

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AUTHORS NOTE

I spent quite a bit of time consulting with CBP officers, import specialists and port employees to compile all the necessary information on importing a KEI truck into a single source.  I also modified the original forms so that they can be filled out electronically.  Of course, I provide all this free to help others in the hope that importing vehicles into the U.S., especially KEI class vehicles will increase in popularity, which will lead to more demand domestically to support a growing dealer and parts market.  Furthermore, more interest in these unique Japanese vehicles will lead to more voices demanding the changing of the ridiculous U.S. 25 year rule.

If you find this information useful and wish to donate any amount to my cause I would greatly appreciate it.  I’m looking to import another car in the future and would put my donations towards this future vehicle.