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Q: Paperwork involved in automaker importing vehicles from Germany ( Answered 5 out of 5 stars,   1 Comment )
Subject: Paperwork involved in automaker importing vehicles from Germany
Category: Business and Money > Accounting
Asked by: magoo22-ga
List Price: $100.00
Posted: 22 Apr 2004 07:45 PDT
Expires: 22 May 2004 07:45 PDT
Question ID: 334312
If an automaker wants to import cars or trucks from Germany, what
paperwork is required, and what US government agency is it filed with?
Also, where could one go to view this paperwork assuming it is a
public record?

Request for Question Clarification by pafalafa-ga on 22 Apr 2004 07:50 PDT
In general, information about imports is handled by the Customs
Service, and is maintained by them as confidential business
information -- I have rarely known information like this to be made

There may be other filing requirements specific to automobiles, but
I've never come across them.  Is there anything in particular we
should be looking for?

If there is a type of car, or an importing company, that is of special
interest to you, it would be helpful to know that.  Also, if there is
a particular type of information you're after -- e.g. number of cars
imported -- it would help to know that as well.

Lastly, if you're looking for instructions about how you, yourself,
can go about importing cars from Germany, let us know, and perhaps we
can assist you.

Clarification of Question by magoo22-ga on 22 Apr 2004 16:53 PDT
Specifically, I'm working on a law suit where I'm trying to determine
what the automaker has stated, on any government paperwork, is the
"Make" and "Model" of a specific vehicle that they are importing. It
seems logical that they must fill out some paperwork with the US
Government that may be related to a tariff/duty or other regulated
process that requires "filings".

Unfortunately I cannot give the name of the automaker.


Request for Question Clarification by pafalafa-ga on 22 Apr 2004 16:56 PDT
One more question, if I may.  

Do you know the approximate year of the car?  There are different
requirements for current models than for antiques, or (I think) for
cars that pre-date certain pollution control requirements.

Clarification of Question by magoo22-ga on 23 Apr 2004 18:57 PDT
Good Question. The vehicle has been imported to the US since 2000 or
2001 and continues thru today.

Clarification of Question by magoo22-ga on 23 Apr 2004 19:01 PDT
One more thing that may help. This is an automaker that is importing
many, many of the same vehicle in question, which is a "new" vehicle
(as opposed to "used").

Request for Question Clarification by pafalafa-ga on 23 Apr 2004 20:01 PDT
Thanks for the additional's a big help.  

From what I can see, there are probably paperwork requirements that
have to be filed with Customs, the Department of Transportation
(regarding safety standards) and to EPA (regarding pollution

I can detail the relevant forms (to the extent specific forms are
involved -- some requirements appear to be more of the
self-certification type).

I want to check with some agencies next week as to the public
accessibility of these forms.  But (and I'm quite experienced in this
area) I highly doubt they are publicly available, as they are most
likely treated as proprietary business information.

If this is, indeed, the case, are you still interested in the
information as an answer to your question?  If you are allowed
discovery during your case, perhaps you can unearth copies of the
forms from the company itself.

Please let me know if you would accept this information as an answer,
even if the forms are not publicly-available.


Clarification of Question by magoo22-ga on 24 Apr 2004 04:26 PDT
Yes. Please proceed. FYI, I have already checked the NHTSA Federal
recall database and found some good information there, so you don't
have to run down that road - at least not as far as recalls are

Thanks for your help and quick replies.
Subject: Re: Paperwork involved in automaker importing vehicles from Germany
Answered By: pafalafa-ga on 27 Apr 2004 16:44 PDT
Rated:5 out of 5 stars
Hello magoo22-ga,

Whew...this has been the proverbial wild goosechase!

Importing a vehicle involves US government regulations which means, of
course, that (a) it's really complicated and (b) it's hard to get a
straight answer about what forms might be publicly available.

The research is made even more difficult by not knowing what, in
particular, I'm looking for -- there are so many variations on the
regulatory theme, that without knowing the particular company and
particular car model in question, I can only offer generic information
about how the system works, and where you might go for additional
sources of information.  However, there are certainly some promising
possibilities out there.

In short, imported cars are cleared through Customs, and must meet
safety regulations imposed by the US Department of Transportation, and
environmental regulations imposed by the US Environmental Protection
Agency.  All three of these agencies are potential sources of

For starters, let's begin with an overview of the import regulations from the DOT:

(Imported From a Country Other Than Canada) 

January 13, 2004

The following provides information concerning the importation of a
passenger car, truck, trailer, motorcycle, moped, bus, or MPV built to
comply with the standards of a country other than the U.S. or Canada. 
Importers of motor vehicles must file form HS-7 (available at ports of
entry) at the time a vehicle is imported to declare whether the
vehicle complies with DOT requirements. As a general rule, a motor
vehicle less than 25 years old must comply with all applicable Federal
motor vehicle safety standards (FMVSS) to be imported permanently.

[NOTE from pafalafa-ga:  the major piece of information here is the
filing of HS-7 -- this is the main import form for cars]

Vehicles manufactured to meet the FMVSS will have a certification
label affixed by the original manufacturer in the area of the
driver-side door.
A vehicle without this certification label must be imported as a
nonconforming vehicle. In this case, the importer must contract with a
Registered Importer (RI) and post a DOT bond for one and a half times
the vehicle?s dutiable value. This bond is in addition to the normal
Customs entry bond. Copies of the DOT bond and the contract with an RI
must be attached to the HS-7 form.

A list of vehicles previously determined eligible for importation may
be obtained from an RI or from the NHTSA web site at

[NOTE: you may want to check the "list of vehicles" link to see if
your vehicle is eligible or not]


You can see what a blank HS-7 looks like, and what sorts of
information are included, here:


? D E C L A R A T I O N ?
Importation of Motor Vehicles and Motor Vehicle Equipment Subject to
Federal Motor Vehicle Safety, Bumper and Theft Prevention Standards


Customs has its own summary of vehicle import regulations that
identifies some additional reporting requirements as well as contact
information at DOT and EPA:

Importing or Exporting A Car: Guidelines for permanent and temporary purposes



...EPA has a detailed automotive fact manual describing emission
requirements for imported vehicles.  You may obtain a copy of this
manual, called the Automotive Imports Facts Manual, or other
information about importing motor vehicles by calling EPA's Imports
Hotline at (202) 564-9240.  You may also communicate by fax at (202)
564-2057;  write to U.S. Environmental Protection Agency, Ariel Rios
Building, Manufactures Operations Division (6405-J),
Investigation/Import Section, 1200 Pennsylvania Avenue, N.W., 
Washington, D.C. 20460; or visit the Web site at

[NOTE: More about this in a little while]



...You may reach DOT's vehicle hotline at 1-800-424-9393; communicate
by fax at (202) 366-1024; write to the National Highway Traffic Safety
Administration (NSA-32), 400 7th Street, S.W. Washington, D.C. 20590

[NOTE:  Actually the contact # is: 202-366-2832 and ask for DOT Office
of Importation]


Some additional DOT information of interest, particularly the contact
information listed at the end, is here:

January 2000

...Vehicles that have been determined eligible for importation are
published annually in the federal register and in 49 CFR Part 593.10.
A list of vehicles determined eligible for importation is updated
quarterly at the NHTSA web site. The importer of a vehicle admissible
under any eligibility decision must enter that number on the HS-7
Declaration Form. Vehicles determined eligible based on an initiative
by the Administrator are designated VSA. Vehicles determined eligible
based on a petition from a manufacturer or an RI where the petition
vehicle is substantially similar to a vehicle offered for sale in the
U.S. are designated as VSP. Vehicles determined eligible based on a
petition from the manufacturer or an RI where the vehicles have safety
features that comply with or are capable of being altered to comply
with all FMVSS are designated VCP.

...After a review of the comments, the agency decides whether or not
the vehicle is eligible for importation and publishes the results in
the Federal Register. A sample submission of a conformity package may
be found in the appendix.

...For information on how to submit a petition for a vehicle not
listed in sec. 593.10 contact Mr. Luke Loy on 202-366-5308.

[NOTE:  It's possible that a "conformity package" was filed for your
vehicle as described on page A7-8 of the "Registered Importer"
document.  To check -- and to find out about the public availability
of the package -- I would suggest giving Luke Loy a call (or, whoever
may answer the phone at 2020-366-5308, since this document is several
years old]


Reporting requirements at the EPA end of things are covered here:

The Automotive Imports Facts Manual

The specific form filed is here:

EPA Standard Form 3520-1 used to import vehicles and heavy duty trucks

[NOTE that according to the instructions, the form, though an EPA
requirement, has to be submitted to Customs, not to EPA.  The same is
true of HS-7, which is also submitted directly to Customs, rather than
to DOT].


Summary information for the whole import process vis a vis EPA is here:

Quick Overview of Vehicle Import Requirements


Possibly the most valuable page of EPA documents is this one, which
summarizes non-EPA import requirements, and provides contact
information for all the relevant agencies:

In addition to Customs and DOT, EPA also introduces several other
agencies that offer ill-defined, but intriguing possibilities for
obtaining additional information:



Questions regarding the importation of your vehicle should be directed
to the Customs port where your vehicle will be entered.

[NOTE:  As I've mentioned before, Customs documents are generally
treated as confidential, and not available]



For information on Federal safety requirements contact:

U.S. Department of Transportation 
400 7th Street, S.W. 
Room 6115 
Washington, DC 20590 
(202) 366-5313

[I've already included DOT contact information earlier, but I thought
I'd add this as well]


Gas Guzzler Tax

A "Gas Guzzler Tax" may need to be paid on your vehicle. These taxes
range from $500 to $3,850 per vehicle. For more information, contact:

Internal Revenue Service 
Public Affairs Office 
1111 Constitution Avenue, N.W. 
Washington, DC 20224 
(202) 622-4920

[IRS, like Customs, generally doesn't make form submissions publicly
available, but it can't hurt to give them a call]


California Emission Requirements

The State of California has its own program for regulating the
importation of nonconforming vehicles that are sold, registered, or
operated in California. If you are a resident of, principally drive
your car in, register or intend to sell vehicles in the State of
California, you will need to comply with California's emission
requirements in addition to the Federal emission requirements. For
more information on California's requirements, contact:

State of California 
Air Resources Board 
Mobile Source Control Division 
9528 Telstar Avenue 
El Monte, CA 91731 
(818) 575-6858

[It's not clear what paperwork may be involved here, but it might be
worth giving ARB a call to find out]


I was intrigued by your comment that you found useful information in
the NHTSA recalls database, as that implies there is vehicle-related
information in non-import related data sources that can be useful to
you.  In there respect, there are several other databases you should
be aware of.

The first is a Customs database.  As I mentioned earlier, most of the
information they have is not publicly available.  But they do have
some points of access for information on policy decisions that they
want to publicly communicate.  Some of these may involve the company
or car model of interest to you (it's a long shot, but worth
chekcing).  Head to:

Customs Rulings Online Search System (CROSS) 
Searchable database of approximately 92,208 CBP rulings spanning the
years 1989 to present.

Enter some search words, and keep your fingers CROSS'ed.


NHTSA has a number of searchable databases that you are probably aware
of already, but I want to list them here,  just in case:

On this page you will find links to:

NHTSA's Recall Campaigns database 

NHTSA's Technical Service Bulletins database 

NHTSA's Defect Investigations database 

NHTSA's Consumer Complaints database 


So....let's summarize what we've got.

The main forms and agencies involved in reporting requirements for
automobile imports are:

DOT Office of Importation
Form HS-7

Registered Importer document
Mr. Luke Loy on 202-366-5308

Standard Form 3520-1
EPA's Imports Hotline at (202) 564-9240

no public contact information specific to vehicle imports
general HQ contact information can be found here:


Secondary sources of potential information:

Gas Guzzler Tax Information
Internal Revenue Service
(202) 622-4920

California  Air Resources Board 
Mobile Source Control Division 
(818) 575-6858

Customs Rulings Online Search System (CROSS)

NHTSA databases


A final comment.  I have a lot of familiarity with extracting
information from federal government files.  I have never before come
across a situation where information forms are mandated by one agency
(in this case, EPA and DOT), yet collected and kept on file at another
(Customs).  I spoke to a few staffers at DOT and EPA, none of whom
could give me a straight answer about whether their respective vehicle
import forms are publicly available information.

I suspect the odds of actually retreiving these records -- given the
confusing jurisdictions -- are very small.  However, you may want to
consider filing a Freedom of Information Act request just the same (as
long as you're not in a rush -- these generally take several months
before you get a response).  If you need any information about how to
go about this, just let me know, and I can point you in the right

I wish you luck in your information hunting.  If anything I have
written here is unclear -- or if you need additional information --
please let me know by posting a Request for Clarification, and I'll be
happy to assist you as best I can.


search strategy:  visited bookmarked sites for DOT, Customs, and EPA
and searched on "imports".
magoo22-ga rated this answer:5 out of 5 stars and gave an additional tip of: $20.00
Thank you so much. I was able to find some good info at the URLs you
posted. You certainly went above and beyond!

Subject: Re: Paperwork involved in automaker importing vehicles from Germany
From: pafalafa-ga on 29 Apr 2004 18:41 PDT
Thanks so much for the kind remarks, and for your generosity.  Hope
things work out for the best.


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