You just bought a salvage car from a U.S. dealership and want to sell it to a foreign buyer in Canada. You’re vaguely aware of a rule stating that exporting used vehicles out of the U.S. requires specific documentation. But this is just something you’re putting up on Craig’s List. And you just bought the car, so of course it’s not used—right?
This is where things get tricky. When it comes to U.S. export regulations, what is considered a used or salvage vehicle is broader than you might expect.
According to Customs and Border Protection (CBP), a used or salvage vehicle is defined as “any self-propelled vehicle the equitable or legal title to which has been transferred by a manufacturer, distributor, or dealer to an ultimate purchaser.”
What does this mean for you? It means that even if you haven’t driven the vehicle a single mile, the vehicle is considered used unless you are the original manufacturer selling it directly to a foreign buyer. And yes, there are indeed additional requirements for exporting used/salvage vehicles that don’t apply to exporting new vehicles.
If you live in the United States and you export goods in any capacity, it’s important to familiarize yourself with the Automated Export System (AES). This is the system that the U.S. government uses to collect data on exports.
In many cases, exporters are required to file their shipment information, called Electronic Export Information (EEI), through AES before sending out a shipment. The filing is done on the Automated Commercial Environment (ACE), the online interface that enables exporters to transmit their EEI to AES.
If you are a U.S. citizen or resident with a Social Security Number, you will need to create an ACE account and provide an employer identification number (EIN) as part of the EEI. You can apply for an EIN on the Internal Revenue Service (IRS) website.
Non-U.S. citizens cannot create an ACE account and must instead authorize a U.S. agent to file on their behalf. Furthermore, non-U.S. citizens do not need to apply for an EIN, and must instead provide their passport number.
The EIN (or passport number) is used purely for identification purposes; it does not have any tax implications.
If you are exporting a used vehicle, you are required to file the EEI through AES at least 72 hours prior to departure of the vehicle, regardless of destination, value or condition.
As part of the export, you must provide proof of ownership in the form of a manufacturer’s statement of origin or a private individual’s certificate of title. You must present the vehicle’s vehicle identification number (VIN), or if there is no VIN, the product identification number (PIN). You are also required to present the internal transaction number (ITN) for the AES filing, which you receive upon submitting the filing.
The vehicle and this required documentation must be presented to customs at the port of export at least 72 hours prior to departure.
This article is meant to be a basic introduction to what you need to keep in mind when exporting vehicles in the U.S. There are exceptions to some of the general rules I have described, and other more nuanced details that I have not mentioned.
For example, you may authorize a freight forwarder or some other outside agent to file the EEI through AES on your behalf. In this case you would not need to create an ACE account, and instead would need to provide the agent with your EIN so they can file on your behalf.
And don’t forget that there will be additional requirements—and fees—imposed by the customs authority in the country of import.
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