HS-7 and EPA 3520-1: The Two Forms You Need to Import a Classic Car

Updated October 14, 2026 · USAutozilla

Short answer: to bring a car at least 25 years old into the United States you file two one-page declarations at customs. On the DOT form HS-7 you tick box 1, which exempts the car from federal safety standards. On the EPA form 3520-1 you tick code E, which exempts it from federal emission standards. No Registered Importer, no bond, no modification work. Your customs broker normally files both with the entry.

HS-7: the safety declaration

The HS-7 is the NHTSA “Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety, Bumper and Theft Prevention Standards” declaration. It is handed to US Customs at the time of importation, and today its data is normally transmitted electronically with the entry.

• Box 1 is the one you want: the vehicle is 25 or more years old (49 CFR 591.5(i)). A car that qualifies here is admitted without regard to whether it complies with the Federal Motor Vehicle Safety Standards. No conversion, no crash test, no Registered Importer, no DOT bond.
• Box 2A / 2B are for cars that already conform to US standards — a US-market car coming home, for instance.
• Box 3 is the nonconforming route: a Registered Importer, a DOT conformance bond and modification work. This is what you avoid by waiting for 25 years.
• Box 5 covers a non-resident bringing a car in temporarily; box 4, a car entering only to be exported again.

How the 25 years are counted

NHTSA states that the 25-year period runs from the date of the vehicle’s manufacture — not from the model year and not from the first registration. In practice that means month for month: a car built in June 2001 qualifies from June 2026. A car one month short does not qualify, and it can be refused entry, exported or seized.

Proving the age

The manufacturer’s build plate is the normal proof, since it carries the month and year of manufacture. NHTSA accepts other evidence when no such label exists: an invoice showing the date of first sale, a registration document showing the car was registered at least 25 years ago, or a statement from a recognised vehicle historical society identifying the vehicle’s age. Get a clear photograph of the plate before you pay for the car.

EPA 3520-1: the emissions declaration

The EPA form 3520-1 is the “Declaration Form: Importation of Motor Vehicles and Motor Vehicle Engines”. It is submitted to Customs for each vehicle, and one form can cover a shipment if the attachments describe every vehicle in it.

• Code E is the classic-car code: a vehicle at least 21 years old, calculated by subtracting the calendar year of manufacture from the year of importation, which in its original unmodified configuration is exempted or excluded from EPA emission requirements.
• Code B is for a US-certified car carrying an EPA emission control label in English in the engine bay.
• Codes A, C, J and Z are the ICI routes: a car that qualifies for none of the exemptions must be imported through an Independent Commercial Importer, and EPA will not authorise its release to the owner.

Two details catch people out. First, EPA counts in calendar years (year of import minus year of manufacture), while NHTSA counts from the date of manufacture; the stricter of the two decides when your car can enter, and for a 25-year-old car that is always the NHTSA month. Second, code E says original unmodified configuration: an engine swap or a stripped emissions system can take a car out of the exemption.

What else goes with the entry

• CBP form 7501, the entry summary, filed by your customs broker.
• The original foreign title or registration document and the bill of sale. Several states later require a certified English translation.
• Proof of the build date — the build-plate photo, kept with the file.
• Duty at the rate in force on the day of entry: currently 10% for a car made in the EU, 12.5% for one made in the UK, 25% for a vehicle classified as a truck. See the full cost breakdown.

The 25% Section 232 automobile tariff does not apply to vehicles built at least 25 years before the year of entry.

Common mistakes

• Trusting the model year. A “2001 model” built in late 2000 or in 2001 are two different cars at the border. Only the build plate counts.
• Shipping too early. The car must be 25 years old when it is entered, not when it is bought or loaded. Time the sailing.
• Assuming federal clearance means you can register it. It does not. Title, VIN inspection, emissions and safety checks are set by your state, and California does not register imported diesels. Check yours in the state-by-state registration guide.
• Modified cars under code E. If the car is no longer in its original configuration, talk to the broker before it ships.
• Pick-ups and vans. They can be classified as trucks and pay 25% duty. Confirm the classification first.

Who actually fills these in

Your customs broker prepares the HS-7 and 3520-1 with the entry; you supply the build-plate photo, the foreign title and the bill of sale. On every car we sell, we do this for you: the car is inspected in the European country where it is located, the paperwork is prepared before it sails, and it lands at a US port cleared, with the import documents in your name. Browse the inventory or ask us to find a specific car.

Sources

• 49 CFR 591.5(i) — “The vehicle is 25 or more years old.”
• NHTSA, Importation and Certification FAQs — the 25-year period runs from the date of manufacture; acceptable proof of age; entry under box 1 of the HS-7.
• EPA form 3520-1 (08/2024) — code E, code B, codes A/C/J/Z and the Independent Commercial Importer requirement.
• CBP, NHTSA Summary of PGA Message Set Processing — HS-7 box 1, 49 CFR 591.5(i), electronic filing.
• CBP, Section 232 Additional FAQs, Automobiles.

This is general information, not legal advice. Your licensed customs broker confirms the classification, the forms and the duty rate applicable on the date of entry.

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