By Farhad Musazada, owner of Skyline Kei Trucks. Last updated: October 21, 2026. Based on 49 U.S.C. §30112, 49 CFR 591.5, NHTSA and EPA import guidance, CBP entry rules and TxDMV bulletin RTB 001-24; statute, regulations, NHTSA, EPA, CBP and TxDMV pages verified October 2026; eligibility months computed for 2026 and 2027 (sources at the end). General information, not legal advice.
Key facts
- The statute: Federal law bars importing a vehicle never certified to U.S. safety standards, then exempts, in 49 U.S.C. §30112(b)(9), "a motor vehicle that is at least 25 years old." Box 1 of DOT Form HS-7 claims that exemption.
- Counted from the build date: NHTSA: "the 25 year period runs from the date of the vehicle's manufacture," not the model year. A truck built in December 2001 is not eligible until December 2026.
- Two agencies, two clocks: DOT counts 25 years from the build date. EPA (Form 3520-1, code E) counts 21 calendar years, so its test is always met first.
- Import is not road use: The exemption gets a truck through U.S. Customs. Road use is state law: Texas says yes under SB 1816 (2025) once the truck is titled and registered; our laws map covers the rest.
- No shortcut for newer trucks: NHTSA's Registered Importer eligibility list has no kei truck on it, and Show or Display is for rare vehicles driven under 2,500 miles a year.
- 2026 and 2027: 2001 builds qualify as their build month passes in 2026; 2002 builds follow month by month in 2027. The eligibility checker below does the count for any build date.
What does the 25-year rule actually say?
The rule is one line in a federal statute. 49 U.S.C. §30112(a)(1) says a person may not import a motor vehicle built after a federal safety standard took effect unless it "complies with the standard and is covered by a certification." A kei truck was built for Japan and never certified to the Federal Motor Vehicle Safety Standards (FMVSS), so that sentence alone keeps it out.
Subsection (b) lists the exceptions. It opens with "This section does not apply to—" and paragraph (9) reads, in full, "a motor vehicle that is at least 25 years old." That is the whole rule: the compliance requirement simply stops applying.
NHTSA's regulation turns that into a declaration. Under 49 CFR 591.5, the importer must file, when the vehicle is offered for importation, a declaration "which declares one of the following," and paragraph (i)(1) is simply "The vehicle is 25 or more years old." NHTSA's importation FAQ puts it plainly: "A motor vehicle that is at least 25 years old can be lawfully imported into the U.S. without regard to whether it complies with all applicable FMVSS."
How are the 25 years counted?
NHTSA's FAQ says how: "the 25 year period runs from the date of the vehicle's manufacture." Not the model year, not January 1 of the build year. A Hijet built in October 2001 turned 25 in October 2026 and could be entered that month. One built in December 2001 waits until December 2026, though both are "2001 trucks."
U.S. Customs checks the date at entry. If the build date "is not identified on a label permanently affixed to the vehicle by its original manufacturer," the FAQ lists other proof: "an invoice showing the date the vehicle was first sold," a registration document showing "that the vehicle was registered at least 25 years ago," or "a statement from a recognized vehicle historical society identifying the age of the vehicle."
For a kei truck the document that does this work is the Japanese export certificate, issued when the truck is deregistered in Japan. It records the month and year of first registration, which errs on the safe side: a truck first registered 25 years ago was built at least that long ago. Every truck we sell comes with that certificate and an English translation, and it is why our listings show the build year and, when we have it, the build month.
The EPA counts differently. Its Form 3520-1 defines its exemption as a "vehicle at least 21 years old (calendar year of manufacture subtracted from year of importation) and in original unmodified configuration." A calendar-year count four years shorter means a truck at NHTSA's 25-year mark has always cleared the EPA mark.
What paperwork does an imported kei truck carry?
Nobody needs to file any of this to buy a truck from our lot; our customs broker does it when the ship docks. But the forms explain the folder that comes with the truck.
| Document | Who files it, and when | What it does |
|---|---|---|
| DOT Form HS-7 | The importer or its broker, with U.S. Customs and Border Protection (CBP) at entry | The safety declaration. Box 1 begins "The vehicle is 25 or more years old." |
| EPA Form 3520-1 | Same filer, same time; it "must be submitted to the U.S. Customs and Border Protection" | The emissions declaration. Code E is the 21-year exemption; "Customs may require proof of vehicle age." |
| Importer Security Filing (ISF, "10+2") | The importer or an agent, before the truck is loaded on the ship in Japan | CBP's security filing for cargo arriving by vessel. |
| CBP entry summary (Form 7501) | The broker, at entry; duty is paid with it | The "customs entry." Harris County's form RTS-046 lists CBP 7501 among the entry documents it accepts. |
| Japanese export certificate | Issued in Japan at deregistration | Chassis number, model code and first-registration month and year. We supply an English translation. |
On duty: CBP's general rates are 2.5 percent for autos and 25 percent for trucks, on the price paid. The Section 232 automobile duties effective April 3, 2025 added 25 percent on passenger vehicles and light trucks, but CBP's guidance carves out vehicles "manufactured in a year at least 25 years prior to the year of the date of entry" under heading 9903.94.04 at 0 percent. Duty is part of what we pay to land a truck, not a line item for you.
What does the 25-year rule not do?
The exemption answers one question: can the truck enter the country. It says nothing about driving it; titling, registration and road use are state matters, and the answers range from full street use to off-road only. Our 50-state laws map has each state's rule and source.
Texas has no age test of its own. Senate Bill 1816 (2025) defines a "miniature vehicle" as one that, among other things, "complies with applicable federal law," and a truck entered under Box 1 does, because at 25 the safety standards no longer apply to it. TxDMV's mini-vehicle bulletin, RTB 001-24, says the same: "Vehicles that are 25 years old or older are exempt from Federal Motor Vehicle Safety Requirements (FMVSS) and are imported under Box 1 of the USDOT Form HS-7." It asks for proof of U.S. Customs entry and, for a vehicle last titled abroad, a VTR-68-A identification number inspection by law enforcement. The steps are in our Texas title and registration guide; the law is in Are kei trucks legal in Texas?
One trap lives in the same bulletin. HS-7 Box 8 declares that "The vehicle was not manufactured primarily for use on the public roads." A kei truck entered under that box, whatever its age, is documented as off-road equipment, and TxDMV says that where the documents indicate off-highway use, the vehicle "must be titled with the off-highway use only remark applied to the record, but it is not eligible for registration." Before buying any imported kei truck, from anyone, look at which box is checked on its HS-7. On ours it is Box 1.
Why can't you import a newer kei truck?
People ask us for a 2005 Hijet. There are two legal routes for a vehicle under 25, and neither fits a kei truck.
Registered Importers. NHTSA approves businesses as Registered Importers (RIs) to bring in vehicles not built to the FMVSS and modify them; "Only an RI may import nonconforming vehicles for resale." An RI can only import a model NHTSA has first determined eligible, usually because a U.S.-certified version of the same model year exists that it can be altered to match, and HS-7 Box 3 demands a bond of "150 percent of the entered value." NHTSA's list of eligible vehicles (as of December 1, 2015) has no Hijet, Carry, Acty, Sambar or Minicab on it, and we know of no U.S.-certified version of any of them to compare against.
Show or Display. Box 10 covers a vehicle "being imported solely for the purpose of show and display." NHTSA's Show or Display guidance requires the applicant to "establish that the vehicle is of such historical or technological significance" that importing it is justified; where more than 500 were built, it must show "exceptional technological and/or historical significance." Even then, "The odometer must not register more than 2,500 miles in a 12-month period" (about 4,000 km). A mass-produced work truck does not fit.
Importing too early. NHTSA's FAQ is blunt: an uncertified vehicle under 25 "cannot be lawfully imported into the U.S. on a permanent basis unless NHTSA determines it eligible for importation." CBP says vehicles that do not meet U.S. safety standards "must be brought into compliance, exported, or destroyed." A truck that lands a month early gets no waiver.
What does the rule mean in 2026 and 2027?
Count forward from the build month. As of October 2026, every kei truck built in 2000 or earlier is eligible, and so is anything built from January through October 2001. November and December 2001 builds follow in November and December 2026. From January 2027, 2002 builds qualify month by month; 2003 builds begin in January 2028.
| Build month and year | Eligible from | Status in October 2026 |
|---|---|---|
| Any month, 2000 or earlier | Already passed | Eligible |
| January to October 2001 | January to October 2026 | Eligible |
| November and December 2001 | November and December 2026 | Weeks away |
| January to December 2002 | The same month in 2027 | Not yet |
| 2003 and later | 2028 or later | Not yet |
Model lines move with the calendar. The first Suzuki Carry DA62T trucks, built from late 2001 with the K6A engine, are only now reaching 25; the Carry buyer's guide tracks that.
The eligibility checker below (also on our FAQ page) counts the 25 years for any build month and year. It is for people importing a truck themselves or watching for a newer model year to open up; for the trucks on our lot and on the ship the question is settled, because we buy only trucks already past the mark. What happens next is in our kei truck buyer's guide.
Is a vehicle old enough to import yet? Check its build date
Enter the month and year the vehicle was built (from the maker's label, or the first-registration date on its Japanese export certificate). The tool counts 25 years forward, the way the federal rule does.
Federal rule: a vehicle that was never certified to U.S. safety standards can be imported once it is at least 25 years old, counted from its date of manufacture (49 U.S.C. 30112(b)(9); DOT Form HS-7, box 1). EPA's separate 21-year exemption (Form 3520-1, code E) is already met by then. Every vehicle we sell has cleared U.S. Customs under this rule, so for our listings the question is settled; the tool is for a truck you are thinking of importing yourself, or for checking when a newer model year opens up. General information, not legal advice.
Frequently asked questions
Does the 25-year rule go by model year or by build date?
By build date. NHTSA's FAQ says "the 25 year period runs from the date of the vehicle's manufacture." A truck built in December 2001 is a 2001 truck, but it is not 25 until December 2026.
Can a 2002 kei truck be imported in 2026?
No. The earliest 2002 builds turn 25 in January 2027, and each later build month follows during 2027. Arriving early earns no waiver: NHTSA says such a vehicle "cannot be lawfully imported into the U.S. on a permanent basis unless NHTSA determines it eligible for importation."
What is HS-7 Box 1?
Form HS-7 is the DOT safety declaration filed with U.S. Customs at entry. Box 1 begins "The vehicle is 25 or more years old." TxDMV's bulletin names Box 1 as the route for vehicles 25 and older, and every truck we sell comes with its HS-7 showing it.
Does the 25-year rule make a kei truck street legal?
No. It is a federal import rule and it ends at the port. Texas allows road use once the truck is titled and registered under SB 1816; other states differ, so check the laws map. In Texas, also watch for the "off-highway use only" remark, applied when the import documents say off-highway: titled, but not registered.
Is the EPA's 21-year rule separate from the 25-year rule?
Yes. It is claimed on Form 3520-1 with code E and covers a "vehicle at least 21 years old (calendar year of manufacture subtracted from year of importation) and in original unmodified configuration." Any truck old enough for the DOT rule has already met it. A replacement engine must be "the same model as originally installed" or a newer certified unit.
Sources
- 49 U.S.C. §30112 (Cornell LII)
- 49 CFR 591.5, Declarations required for importation (Cornell LII)
- NHTSA: Importation and Certification FAQs
- NHTSA/DOT Form HS-7, Declaration (Rev. 02-2020)
- NHTSA: Registered Importers
- NHTSA: List of nonconforming vehicles determined eligible for importation (as of December 1, 2015)
- NHTSA: How to Import a Motor Vehicle for Show or Display (October 15, 2012)
- EPA Form 3520-1, Importation of Motor Vehicles and Motor Vehicle Engines Subject to Federal Air Pollution Regulations
- CBP: Importing a Motor Vehicle
- CBP CSMS #64624801, Guidance: Import Duties on Certain Automobiles (April 2, 2025)
- CBP: Importer Security Filing (10+2)
- TxDMV Registration and Title Bulletin 001-24, Title and Registration Procedures for Mini Vehicles (April 4, 2024)
- Texas SB 1816 (89th Legislature), enrolled text
- Harris County Tax Office form RTS-046 (rev. 08/2025)
Written by Farhad Musazada, owner of Skyline Kei Trucks
Farhad imports more than 300 kei trucks a year to Houston and meets buyers at the lot at 6100 Harvey Wilson Dr. He writes these guides from the paperwork our buyers take to the county tax office and the official sources listed on each page. Spotted something out of date? Email us and we will check it.
Ready to look? Browse kei trucks for sale in Houston, see what is in Houston now or arriving soon, or call or text (713) 385-9798.
All vehicles are sold by Wideway Motors LLC as is, with no warranty.