The Show or Display Import Law for Dummies Part 3.1: The Red(tape)line
Maindrian Pace and Kip Raine had their Eleanor, Richard Hammond had his Oliver (no relation to yours truly), and I have my Astrid...and you as well, you lucky guy you, have found your own little four-wheeled version of amore! Well, assuming that sexy heartbreaker is a Show or Display-eligible car like a Midnight Purple 2 R34 Skyline you may now be wondering exactly how you go about getting the Feds to grant her a green card so that you can both enjoy a new wonderful life together in The Land of the Free (TM).
Just like most epic stories of dealing with the US Government it starts with a little piece of paper, specifically this one:
Application for Permission to Import a Motor Vehicle for Show or Display
That link will take you to a fillable version of the application you have to submit to the National Highway Traffic Safety Administration (NHTSA for short) in order for them to decide if your particular vehicle meets their standards to be let into the country to play with all the cool kids.
Some of the application is common sense but much of it can be confusing if you've never had to do it before – which you probably haven't, just like 99.9% of the US population - so to try and help everyone out I'll walk you through everything and give some tips.
It will also be a big help to you if you go to this other link and read the instructions NHTSA themselves have provided for prospective applicants:
So, on to the application. The first part - “1. Applicant” should be pretty straightforward. It just asks for your name, mailing address, phone, and email address. This part should need no further explanation unless you're the type who's proud of being able to count all the way up to “Potato!” - in that case, please do us all a favor and surrender your drivers license before you poke your eyes out with it.
Oh, by the way, make sure you give a good email address. Unlike olden times when our cave-dwelling ancestors still used that ancient technology called “letters”, the NHTSA no longer physically sends you your approval or any other correspondence in the mail. If they have questions or they've approved your car they'll be getting in touch with you through the magic of the internet instead.
“2. Vehicle Identification” should also be fairly easy assuming you've bought a car already. If your R34 still exists only in the realm of nocturnal imaginings then this'll probably be a lot harder. Anyway, if you do have a Midnight Purple 2 or M-Spec Nur R34 at the ready then you start with the year – 1999 for an MP2, 2002 for an M-Spec. “Make” is simple – that would be Nissan of course. “Model” is a bit trickier. If you have an MP2 don't be tempted to just put “R34 GT-R V-Spec” or even “R34 GT-R Midnight Purple 2”. Remember that on the Show or Display approval list the Midnight Purple 2 is identified as the “Skyline R34 GT-R V-Spec Early Model Limited Edition” so that's what you should put down. Yes, the NHTSA knows the MP2 is that same car but this is the government we're dealing with so you have to make sure you stick to the terminology they use for best results. For an M-Spec Nur you would put “Skyline GT-R M-Spec Nur”.
R34s don't have a VIN per se but the serial number on your chassis plate serves that purpose so you put BNR34-whatever on there. Well, you don't LITERALLY put “BNR34-whatever” – you need to put your car's actual serial number on there. If you don't have an R34 to import though and just want to send an application to NHTSA as an act of protest against the tyranny of the 25-year import rule then have at it with the BNR34-whatever-ness.
“Engine” can be a little confusing. Since it just says “Engine” you'd be excused for thinking you need to put the engine type such as “I6 gasoline” or “RB26DETT”. If you read the instructions though it actually asks for “engine number” therefore they want your engine's serial number, not just what type of engine the car has. For the date of manufacture they just need the month and year. You generally won't be able to get an exact date to the day from the manufacturer and NHTSA gets that. Current odometer reading should be self-explanatory.
On to “3. Where vehicle will be stored in the United States”. If you plan on keeping the car at your house then you just put your home address here but many people who import through Show or Display are car collectors with several cars and therefore may have a separate storage unit, garage, warehouse, museum, or supervillain lair inside a volcano they'll be tossing the car into so that's why this portion is included on the application. I'm glad the NHTSA didn't raise any eyebrows about my secret hideout being on 169 Evilsville Boulevard cor. J. Epstein Ave., just outside Las Vegas.
|Image credit: Buddy Loans|
On a side note, if you want a supervillain lair like mine be sure you get good financing because the costs can be enormous! Head to this link if you want more information on your own Gru-worthy Minion mansion.
“4. On-road Use” is usually the first part that can be really confusing. If you're just importing the car to put on a pedestal in your living room and never drive it to troll for honeys then feel free to check off “No”. If you're a normal gearhead though who can't imagine importing a car just to gawk at like it's a gigantic and much more smelly Jackson Pollock then you'll want to check the blank for “Yes, sir, I do want to awe other drivers with my swag ride!” The section where it asks you for an Independent Commercial Importer can be the confusing part though. ICIs are the “Registered Importers” I mentioned in Part 1 of this guide who convert cars to meet EPA standards if they're less than 21 years old. If you're importing an M-Spec Nur before 2023 then you'll need to hire one of them to write down in that blank space – plus have a couple of suitcases full of cash. There are two ICIs known to have prior experience with R34s – JK Technologies on the East Coast that handled the Motorex and Rivsu cars, and G&K Automotive on the West Coast that handled Toprank's vehicles. If you're a fellow Midnight Purple 2 owner on the other hand, join me in writing “Over 21 years old, EPA exempt” in that blank space then do the Dance of Joy as you've saved yourself tens of thousand of dollars and a year or two of waiting. Use that money for some celebratory hookers and blow instead – or maybe just blow what with the epidemic and all.
“5. Basis For Application:” is relatively easy since it's multiple choice – like those high school exams you used to go “eeney-meenie-miney-moe” on. You have three choices here – the vehicle is of technological significance, it's of historical significance, or it's of exceptional significance. The only real wrong answer here is the third one since neither the MP2 or M-Spec Nur had more than 500 examples made. Technological significance is obvious given the amount of hi-tech wizardry in the R34 for its time while historical significance is easy to see if you read Part 2 of this series. Either way you don't have to justify your choice really to NHTSA since the original petitioners did that for us. I checked off both historical and technological on my application and it went through just fine.
Well, that's a lot to digest already and it's made this post quite long so I'll stop here for now and we'll pick this up with part 6 of the application next week - that section alone takes an entire article to thoroughly explain properly so prep your peepers for another lengthy read! Drive safe and see you then!
Thank you for these write ups. Looking to import an M Spec Nur and had no real clue how to go about the process.ReplyDelete
I think I already know the answer, but what are the chances of me applying for on road use without converting the car to meet EPA standards on the argument that there are already hundreds of not thousands of RB26s in the country that are exempt on older, possibly less environmentally friendly GTRs and other swapped cars? What if I promise to go solar to offset the carbon?
Unfortunately, as you probably already guessed, unless you have some incriminating videotapes to blackmail somebody high up in the government it's a no go with bringing in a car before 21 years old without meeting the emissions requirement. The 21 year exemption is a long-standing EPA policy and it's not judged on a case to case basis - basically you meet it or your car stays out of the country. You'd have to basically initiate a review by the EPA on the highest level of that entire policy to get it removed entirely - there's no process to exempt a single car.Delete
You won't have much luck arguing on the basis that there are RB26s already in the country because those engines that are here are all grey or black market imports since the RB was never sold here officially and hence never certified by the EPA - so as far as the EPA is concerned they don't meet emissions standards and are only here because they're either illegal, meet the 21 year exemption, or were brought in as just an engine instead of a whole car. Therefore trying to argue that your car should be let in earlier because it's no worse than other cars already here would be like trying to tell a CBP officer that you're an illegal alien but you should be allowed to stay in the country because there's plenty of illegal aliens already here - I'm sure you already know how that's going to fly.
If you want your M-Spec Nur in the States before 21 then you can either pay the money to have it modified to meet EPA standards or import it strictly for non-road use. Doing the latter means however that you can only display the car basically and/or drive it on private land - if you ever get caught driving it on public roads the car is subject to seizure.
Hope that's helpful and good luck with your car!
Thank you for the in depth response! Everything you said makes sense. I never read/heard about being able to drive the car on private land. Do you know if that means solely my private land AKA my 20x20' garage and driveway, something like a privately owned business, the grounds of a racetrack, etc?Delete
I'll comply with the letter of the law when the day comes, but it's also good to know the bounds of said law...
Technically private land would be anywhere that's not a public roadway so it could be your driveway, a racetrack, or a Walmart parking lot. There's several potential problems with that approach though. First, NHTSA will likely be VERY skeptical about an application that claims it won't be for on-road use especially for an R34 Skyline unless it's from a museum or other verifiable established collection. The bad rep from Motorex, Kaizo, and other bad importers still haunts the R34 at the DOT so they won't just take someone at their word that pinky promise they won't drive such a car. So there'll be a lot of extra scrutiny I bet on such an application. Second, assuming you get approved by DOT, bringing it in and claiming it won't be driven publicly means it won't have a valid EPA form 3520-1 when it's imported. That'll be a big problem come 25 years if you do try to register it since state DMVs now know to ask for that as part of the proof the car was legally imported. Without one the car couldn't be legally titled and registered. In short, the off-road thing is a whole 'nother kettle of fish that I can't claim I'm an expert on since most Show or Display entries are for cars people actually intend to drive and on the whole is probably more trouble than it's worth overall.Delete
Living and residing in Arizona you probably have not had to deal with the offshoot terrorist group called CARB. However perhaps you have friends that imported a Show and Display car that needed to be converted to comply with post 1996 OBD II standards. I know TopRank imported a V Spec MP2 SnD car and paid nearly $70K to get it OBD II compliant. Supposedly they and or G&K are working on a cheaper compliance standard for post 1996 R33 and R34 cars that would be in more line with the current R32 CA compliance cost ($10K ish).ReplyDelete
Wondering if you’ve heard any insight from your contacts or network stuck in the fascist state of CA.
Hi and thanks for checking out the blog. I covered the start of TopRank's effort to get their MP2 R34 OBDII compliant a while back in this old blog post: http://www.23gt.net/2016/06/time-to-sell-some-vital-organs-ivi-is.htmlDelete
Unfortunately from what my contacts have told me although G&K was able to get the car EPA compliant they were ultimately unsuccessful in getting it CARB compliant. I'm told it was sold as basically a 49-stage legal car and as of now G&K is only doing R32 compliance work with no word on whether they're going to continue to pursue the later models still. The people that I know or have heard of having legit R33s or R34s in Cali are generally getting them registered outside the state to avoid the CARB headaches.
I have a question - we are looking to import an M Spec Nur in 2023. Do you know if we have to wait until the month of manufacture to submit our application so that it is 21 years old to the month and year or can we submit the application as of January 1, 2023? Thanks for all your helpful tips!ReplyDelete
You don't have to wait until the exact month to submit the application but you do want to wait until it's close - like a month or two before since NHTSA likely won't process it until the car is close to being importable. For example, with my MP2 I was advised by someone very knowledgeable with S&D that I should wait until late December or January of 2019 to submit since my car was a February 1999 build. Unfortunately I wasn't the only one waiting to import an MP2 and the influx of applications delayed things and I didn't get approval until April. The agent I talked to at NHTSA said it normally doesn't take that long but they had never seen so many applications come in all at once before.Delete
Hope that helps and thanks for checking out the blog!
Great tip Oliver. I was searching for this.Delete