EPA and DOT import paperwork: Form 3520-1 and Form HS-7
Two US government forms sit at the centre of importing a car from Japan: EPA Form 3520-1 for emissions and DOT Form HS-7 for safety. Both are declarations. Even when a car is exempt because of its age, the exemption has to be claimed on the forms. This page explains what each one is for and where it is filed. It is general information, not legal advice.
Why there are two forms
A vehicle imported into the United States has to satisfy two separate federal regimes. Safety is handled by the National Highway Traffic Safety Administration (NHTSA) under the Federal Motor Vehicle Safety Standards. Emissions are handled by the Environmental Protection Agency (EPA) under federal air pollution rules. Each agency has its own declaration, and both are presented through US Customs and Border Protection (CBP) when the car enters the country.
DOT Form HS-7: the safety declaration
Form HS-7 is the NHTSA declaration for importing a motor vehicle or motor vehicle equipment subject to the Federal Motor Vehicle Safety Standards. The importer uses it to state the vehicle's details and the basis on which it is being imported. One of the options on the form is the exemption for a vehicle that is at least 25 years old, which is what most Japanese imports rely on.
Filing HS-7 does not itself make a car legal. It is a declaration that the car meets a standard or qualifies for an exemption. If the car is younger than 25 and does not conform, HS-7 is where that is declared too, and the car normally has to be imported by a registered importer and brought into compliance.
EPA Form 3520-1: the emissions declaration
Form 3520-1 is the EPA declaration for importing a motor vehicle or motor vehicle engine subject to federal air pollution regulations. As with the safety side, the importer declares the vehicle and the exemption claimed. For older cars, the relevant option is the exemption for vehicles that are at least 21 years old, which applies only to vehicles in their original configuration, not modified from the manufacturer's original design.
Because the EPA age threshold (21 years) is lower than the safety threshold (25 years), a car that qualifies under the 25-year rule has already cleared the EPA age requirement. The two checks are separate even when both are met.
The age exemptions, side by side
| Agency | Form | Age exemption |
|---|---|---|
| NHTSA (safety) | DOT Form HS-7 | 25 years old or older |
| EPA (emissions) | EPA Form 3520-1 | 21 years old or older (original configuration only) |
The two exemptions do not share one date. The EPA exemption for vehicles at least 21 years old is based on the vehicle's original production year, while the NHTSA/DOT exemption for vehicles at least 25 years old is based on the vehicle's date of manufacture. The EPA exemption applies only to vehicles in their original configuration, not modified from the manufacturer's original design. The 25-year import rule page explains how to check that date and why it decides eligibility. Confirm current requirements with the EPA and NHTSA, and see the EPA's official vehicle-import guidance.
Where the forms are filed
The forms are presented with the customs entry at the US port where the car arrives. A CBP entry is filed, duty and fees are paid, and the EPA and DOT declarations are submitted at the same time. Most first-time importers use a customs broker to do this, and a customs bond may be required. The broker keeps the paperwork moving so that the car is released rather than left sitting at the port.
The forms are usually completed by the importer or the broker, using the vehicle's details and the claimed exemption. Accuracy matters: a mismatch between the chassis number, the build date and the exemption claimed is the kind of thing that delays a clearance.
If the car is younger than 25 years old
A vehicle under 25 years old normally does not qualify for the safety age exemption. It has to be imported by a registered importer and brought into conformity with the applicable standards, unless another exemption applies. That route can work, but it is slower and more expensive, and it is not the one beginners should start with. The simplest imports are cars that clear both age thresholds: the NHTSA/DOT test on the date of manufacture and the EPA test on the original production year.
Related guides
EPA and DOT paperwork: common questions
What is EPA Form 3520-1?
It is the EPA declaration for importing a motor vehicle or engine subject to federal air pollution regulations. Importers use it to declare the vehicle and the exemption they are claiming, including the exemption for vehicles 21 years old or older, which applies only to vehicles in their original configuration, not modified from the manufacturer's original design.
What is DOT Form HS-7?
It is the NHTSA declaration for importing a motor vehicle or equipment subject to the Federal Motor Vehicle Safety Standards. Importers use it to declare the vehicle and the basis on which it qualifies, including the exemption for vehicles 25 years old or older.
Where do I file the EPA and DOT forms?
The forms are presented with the customs entry at the US port of entry, normally by a customs broker. US Customs and Border Protection collects them as part of clearing the vehicle, along with the entry summary and duty.
Does a 25-year-old car need EPA and DOT forms?
Yes. Even when a vehicle is exempt from the standards because of its age, the exemption is declared on the forms. A car is not cleared simply because it is old; the importer still files the paperwork that claims the exemption.
What if the car is younger than 25 years old?
Then it generally does not qualify for the age exemption. A nonconforming vehicle is normally imported by a registered importer and brought into compliance with the applicable standards, or imported under a different exemption if one applies. This is a more involved and more expensive route.
General information only — not legal advice. Forms, exemptions and filing requirements can change. Always check the current requirements with the EPA, NHTSA and US Customs and Border Protection, or a licensed customs broker, before importing.