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How a 25 year old kei truck comes into the United States
Federal law lets a motor vehicle at least 25 years old into the country without meeting today's U.S. safety standards, counted from the day it was made. EPA admits a vehicle at least 21 years old in its original configuration with its original model of engine. The truck is declared on two federal forms at the port, pays the 25 percent truck duty and then goes to your state, which decides road use.
- JapanA yard, an auction or a farm
- The PacificBy ship, with its bill of lading
- The portA US port with a sailing from Japan on record
- Your stateTitle and the roads it allows
The two ages
Twenty five years for safety. Twenty one for emissions.
Two agencies count a truck's age two different ways. The safety rule is the stricter one, so a truck built in October 2001 or earlier clears both on age, provided its engine is the model it left the factory with.
Safety, NHTSA
The 25 year rule
(9) a motor vehicle that is at least 25 years old; or
30112(a)(1) bars importing a motor vehicle manufactured after an applicable safety standard took effect unless it complies and is certified. 30112(b) lists where the section does not apply, and (9) is the age paragraph.
The 25 years run from the date of manufacture.
Emissions, EPA
The 21 year provision
EPA Form 3520-1 code E covers a vehicle at least 21 years old by calendar year subtraction and in original unmodified configuration, with the same model of engine as originally installed. No EPA letter is needed in advance.
By calendar year that reaches trucks built in 2005 or earlier, in their original unmodified configuration.
40 CFR
What changed, and what did not.
Title 40 of the Code of Federal Regulations holds EPA's import rules. Two recent changes touch kei trucks, and neither closes the road truck lane.
In force 27 March 2023
The old nonroad exemption is gone
EPA removed the ancient engine/equipment exemption, 1068.315(i), in 88 FR 4296. An engine or a piece of equipment can no longer come in on age alone as nonroad. A road truck 25 years or older never needed it.
88 FR 4296Federal Register, read 28 October 2026In force 20 April 2026
The newest change to the vehicle import rules
Struck the words in 85.1515(d) that kept an ICI out of the greenhouse gas averaging banking and trading program, leaving: An ICI may not certify using nonconformance penalties. It did not touch the 21 year exemption in 85.1511.
91 FR 7686Federal Register, read 28 October 2026Newer trucks
How a newer kei truck comes in
A kei truck under 25 years old comes in as nonroad equipment. EPA treats a mini truck as a motor vehicle unless it is permanently governed to 25 mph or less. Governed that way it is a nonroad vehicle, and its engine must be covered by an EPA certificate of conformity before it reaches US Customs, as every mini truck arriving since 8 December 2008 has been. A certificate covers one engine family for one model year and belongs to the importer that holds it.
Mini-trucks, importing used motor vehicles as nonroad vehiclesEPA, read 28 October 2026At the port
The papers that bring a truck in.
Each one is filed or shown at entry. Every card opens the rule or the page it comes from.
Original bill of lading
CBP names it first among what clearance needs, with the bill of sale and the foreign registration. It is also the usual evidence of the right to make entry.
Carrier issues it, importer presents itCBP motor vehicle page; 19 CFR 142.3(a)(2)
Bill of sale and foreign registration
Named by CBP with the bill of lading.
ImporterCBP motor vehicle page
CBP Form 5106
Creates the importer identity. Filed with the first formal entry. The number is the IRS employer identification number, a Social Security number or a CBP assigned number.
Importer of record, once19 CFR 24.5
Customs bond on CBP Form 301
Merchandise is not released unless a single entry or continuous bond is on file.
Importer of record19 CFR 142.4(a)
Entry, CBP Form 3461 or its electronic equivalent
Secures release, with a commercial invoice and evidence of the right to make entry.
Importer of record or a licensed broker for them19 CFR 142.3(a)
Entry summary, CBP Form 7501
Declares and pays the duty. Can serve as the entry too when filed at the time of entry.
Importer of record or a licensed broker for them19 CFR 142.3(b)
DOT Form HS-7, Box 1
The 25 year safety declaration.
ImporterNHTSA FAQ; 49 CFR 591.5(i)(1)
EPA Form 3520-1, code E
The 21 year original configuration emissions declaration. No EPA letter needed in advance. Customs may require proof of vehicle age.
ImporterEPA Form 3520-1, edition 2024-08, page 1
Proof of age
The manufacturer's label. Without one, a first sale invoice or a registration from 25 years back. Without those, a historical society statement.
Importer, on requestNHTSA FAQ
Clean undercarriage
CBP relays that USDA requires the undercarriage of an imported vehicle to be free of foreign soil.
ShipperCBP motor vehicle page
The duty
The chicken tax, at every age.
Every kei truck pays the 25 percent truck duty, the one people call the chicken tax, whatever its age. U.S. Customs has ruled so for kei trucks built in 1990 and 1993, and the 25 year rule decides only whether a truck may come in, not what it pays.
The chicken tax is the popular name for the 25 percent rate on trucks. It is not a term in the tariff schedule. As read, a Japanese kei truck classed in 8704.31.01 pays 25 percent and nothing stacks on it. A broker settles the classification and the rate on the day of entry.
- The classification of each truck. CBP's rulings put kei trucks, mini dumpers and deck vans in 8704.31.01 at every age, see chicken_tax. A broker or a binding ruling settles a borderline van.
- Kei vans. A kei van with passenger seating on permanent anchor points can fall in 8703.21.01 at 2.5 percent (H302977), while one with an unbelted folding rear seat is 8704.31.01 (N364403). 8703.21.01 is not in note 33(b), so the Section 232 auto duty does not reach it, but the 2026 Section 301 action brings a Japanese good under 12.5 percent up to 12.5 percent (9903.05.49) unless its annex exempts it.
- Origin. Product of Japan is assumed for a truck built there.
- Age. No carve out for used or 25 year old vehicles exists in notes 33 or 52, and CBP's rulings on 1990 and 1993 trucks confirm age changes nothing.
- The date. Every measure above moved in 2025 or 2026. The rate is the one in force on the day of entry.
US tariff line 8704.31.01
25 percent
Goods vehicles with only a spark ignition piston engine, G.V.W. not exceeding 5 metric tons. Japan has no special rate on this line.
US International Trade CommissionHarmonized Tariff Scheduleread 28 October 2026
Our part
What we do between Japan and you.
Pick the truck
The body, the work and the state it is going to. Your state page says what it can do there.
Find it in Japan
Auctions, exporters and dealers in Japan sell kei trucks abroad. Before you pay a seller, get its chassis number, its manufacture date and a full set of photographs.
We check the age and the engine
The manufacture date against the 25 year line, the engine against its original model and the truck against your state page.
It ships
Cleaned underneath, then from Japan to a port where a sailing from Japan is on record, with its bill of lading, bill of sale and Japanese registration.
It is entered
At the port the entry is filed with US Customs, the truck is declared to DOT and EPA and the truck duty is paid.
The title
Keep every stamped paper with the truck. Your state title office asks to see them.
The 25 year lane, step by step
Eleven steps, in order.
The law's own sequence for a road truck 25 years or older, from the manufacture date to your state's title office.
Check the date of manufacture. It must be at least 25 years before the day the truck is entered, counted to the day. The manufacturer's label shows it. Without a label, a first sale invoice or a registration record from 25 years back does. Without those, a recognized historical society's statement.
Check the configuration. The truck must be in its original unmodified configuration and the engine must be the same model as the one originally installed.
Choose the importer of record. It is usually you, the buyer. The importer of record files CBP Form 5106 with its first formal entry.
Put a customs bond in place, single entry for one truck or continuous for many. CBP does not release the truck without one.
Clean the undercarriage of foreign soil before it ships.
Ship it. The carrier issues the original bill of lading. Keep the bill of sale and the foreign registration with it.
File the entry at the port. The importer of record, or a licensed customs broker acting for them, files the entry and the entry summary with the commercial invoice.
Declare it to both agencies. DOT Form HS-7 under Box 1 and EPA Form 3520-1 under code E. CBP may ask for proof of age.
Pay the duty. A kei truck classed under HTS 8704.31.01 pays 25 percent.
Take release and keep every stamped paper. The entry papers and the two declarations are what a state title office asks to see.
What a title office asks for varies by state.
Title and register it in your state. Your state decides road use.
Questions
What people ask first.
Is a 25 year old kei truck legal to import?
Yes. Under 49 U.S.C. 30112(b)(9) the federal safety standards do not bar a motor vehicle at least 25 years old, and EPA's Form 3520-1 code E covers a vehicle at least 21 years old in its original configuration. Your state then decides whether it can be titled for the road.
How are the 25 years counted?
From the date of manufacture to the day of entry. The manufacturer's label shows the date. Without a label NHTSA accepts a first sale invoice or a registration record from 25 years back, and without those a recognized historical society's statement. A model year on its own is not a date of manufacture.
Which federal forms does it need?
DOT Form HS-7 under Box 1 and EPA Form 3520-1 under code E, filed with the customs entry along with the original bill of lading, the bill of sale and the foreign registration.
Does EPA test the truck?
No, not on this lane. A truck at least 21 years old in its original unmodified configuration, with the same model of engine it left the factory with, is exempted or excluded by age and needs no EPA letter in advance.
What if the engine has been swapped?
A replacement engine has to be the same model as the original. Anything else falls outside the age provision.
Can a newer truck come in the same way?
No. A road truck under 25 years old needs an NHTSA eligibility decision and a Registered Importer, and if it is under 21 years old it also needs EPA conformity through an independent commercial importer. The nonroad age exemption EPA once had was removed on 27 March 2023.
What duty does it pay?
A kei truck classed as a truck under tariff line 8704.31.01 pays 25 percent. Your customs broker confirms the classification and the rate on the day of entry.
Does a 25 year old truck skip the chicken tax?
No. The chicken tax is the 25 percent duty on trucks, and it applies at any age. U.S. Customs has ruled so for kei trucks built in 1990 and 1993. The 25 year rule decides whether a truck may come in, not what it pays.
Who files the paperwork?
The importer of record, or a licensed customs broker acting for them.
Is there a federal import licence?
No federal licence exists for importing a 25 year old vehicle. The importer of record holds a U.S. Customs importer number and a customs bond.
Can I drive it on the road?
That is your state's decision. Each state page sets out road use, title and registration.
Every source read, 28 October 2026
- law.cornell.edu/uscode/text/49/30112
- ecfr.gov/current/title-49/section-591.5
- ecfr.gov/current/title-49/part-592
- ecfr.gov/current/title-40/section-85.1502
- ecfr.gov/current/title-40/section-85.1504
- ecfr.gov/current/title-40/section-85.1511
- ecfr.gov/current/title-40/section-85.1513
- ecfr.gov/current/title-40/section-85.1515
- ecfr.gov/current/title-40/section-1068.301
- ecfr.gov/current/title-40/section-1068.310
- ecfr.gov/current/title-40/section-1068.315
- ecfr.gov/current/title-19/section-12.80
- ecfr.gov/current/title-19/section-24.5
- ecfr.gov/current/title-19/section-111.2
- ecfr.gov/current/title-19/section-113.11
- ecfr.gov/current/title-19/section-142.3
- ecfr.gov/current/title-19/section-142.4
- ecfr.gov/api/versioner/v1/titles.json
- ecfr.gov/api/versioner/v1/versions/title-40.json
- nhtsa.gov/importing-vehicle/importation-and-certification-faqs
- nhtsa.gov/importing-vehicle
- cbp.gov/trade/basic-import-export/importing-car
- cbp.gov/trade/priority-issues/revenue/bonds
- epa.gov/importing-vehicles-and-engines/learn-about-importing-vehicles-..
- epa.gov/system/files/documents/2024-08/form3520-1-2024-08-secured-enab..
- epa.gov/system/files/documents/2024-08/form3520-21-2024-08-secured-ena..
- federalregister.gov/documents/2023/01/24/2022-27957/control-of-air-pol..
- federalregister.gov/api/v1/documents.json,%20searches%20for%20EPA%20ru..
- federalregister.gov/documents/full_text/text/2025/04/03/2025-05930.txt
- federalregister.gov/documents/2025/09/16/2025-17908/implementing-certa..
- federalregister.gov/documents/full_text/text/2026/02/25/2026-03832.txt
- federalregister.gov/documents/full_text/text/2026/07/28/2026-15274.txt
- federalregister.gov/documents/full_text/text/2026/07/28/2026-15181.txt
- hts.usitc.gov/reststop/search
- hts.usitc.gov/reststop/search
- hts.usitc.gov/reststop/search
- hts.usitc.gov/reststop/file
- rulings.cbp.gov/ruling/H299177
- rulings.cbp.gov/ruling/N015653
- rulings.cbp.gov/ruling/N340640
- rulings.cbp.gov/ruling/N359221
- rulings.cbp.gov/ruling/N364403
- rulings.cbp.gov/ruling/H302977
- rulings.cbp.gov/ruling/N338708
- rulings.cbp.gov/ruling/N331411
- rulings.cbp.gov/ruling/N331360
- rulings.cbp.gov/ruling/N342537
- rulings.cbp.gov/ruling/H307522
- hts.usitc.gov/reststop/file
- hts.usitc.gov/reststop/file
- hts.usitc.gov/reststop/file
The public record as read on 28 October 2026, not legal advice.
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