Ownership
Importing an E-Type to the USA
Every E-Type is old enough to enter the United States under the age exemption, which makes this one of the easier cars to import and one of the most badly explained. This page gives the regulation that creates the exemption, the exact forms and the exact boxes, what duty is actually payable as at September 2026, and what happens afterwards at the state DMV, which is the part that catches people out. Where the position is genuinely unresolved, it says so instead of guessing.
Two things make an E-Type straightforward to import. It is comfortably over 25 years old, which exempts it from federal safety standards, and it is comfortably pre 1975, which puts it outside the emissions regime. What is not straightforward is the tariff position, which has moved three times since early 2025 and contains an unresolved question worth about 10 per cent of the value of the car, and the titling, which is a state matter and varies. For what happens once the car is here, see owning one in America.
The 25 year exemption, and what it actually exempts
The exemption is created by 49 CFR 591.5(i), which reads "The vehicle is 25 or more years old". It is administered by NHTSA under 49 CFR Part 591.
It exempts the car from the Federal Motor Vehicle Safety Standards. It does not exempt the car from duty, and it is not an emissions exemption, which is a separate declaration to a separate agency on a separate form.
The forms, and the exact boxes
Three federal forms are in play, issued by three different agencies. Each declares a different thing, and the entry that applies to an E-Type is fixed in each case.
| Form | Issued by | The entry that applies | What it declares |
|---|---|---|---|
| HS-7, Declaration | US Department of Transportation, NHTSA | Box 1 | That the vehicle is 25 or more years old and therefore outside the Federal Motor Vehicle Safety Standards. Confirmed from the form itself, revision 02-2020, and from NHTSA's own published guidance. |
| 3520-1, Declaration | US Environmental Protection Agency | Code E | The emissions exclusion or exemption. Confirmed from the current August 2024 form. |
| 7501, Entry Summary | US Customs and Border Protection | Not applicable, the whole form | The customs entry. The stamped copy is the document a state DMV will later want, so do not lose it. |
A Registered Importer is not needed. The bond and Registered Importer requirement sits in 49 CFR 591.5(f), which is a structurally separate provision from the age exemption at 591.5(i), and 591.6 does not extend the requirement to (i). A NHTSA interpretation letter of 2000 says the same. So the DOT conformance bond at 150 per cent of dutiable value, which is often quoted at people importing cars, does not apply to an E-Type entering under Box 1. A CBP entry bond is a different thing and may still apply.
Duty, and the part nobody explains correctly
An E-Type is a passenger motor car of HTS heading 8703. CBP's own published rate for a passenger car is 2.5 per cent, based on price paid or payable. The archive did not verify that rate line by line against the HTSUS itself, because the chapter file could not be read, and it notes that.
There is no age based reduction in that 2.5 per cent. The duty free antiques provision at HTS heading 9705 and 9706 is confined to collections, collectors' pieces and antiques of an age far greater than any E-Type. The archive attempted to verify CBP's antiques guidance directly and could not load it, so it prints no specific age threshold.
Presidential Proclamation 10908, published in the Federal Register on 3 April 2025, imposed an additional 25 per cent ad valorem tariff on imported passenger vehicles under Section 232 of the Trade Expansion Act of 1962. CBP implemented it through the 9903.94 series and created subheading 9903.94.04 for vehicles manufactured in a year at least 25 years prior to the year of the date of entry, at a 0 per cent additional rate. So an E-Type is excluded from the Section 232 automobile tariff. This is verified from two CBP primary sources.
On 20 February 2026 the Supreme Court decided Learning Resources, Inc. v. Trump, consolidated with Trump v. V.O.S. Selections, Inc., by 6 to 3, striking down the tariffs imposed under the International Emergency Economic Powers Act. The ruling did not touch Section 232, which rests on separate statutory authority. From 24 February 2026 a Section 122 balance of payments surcharge of 10 percentage points applied to most imports, with goods already subject to Section 232 excluded so the two did not stack. That surcharge expired by operation of law on 24 July 2026. On the same day a Section 301 action took effect covering 60 investigated economies, with the United Kingdom on the 10 per cent list, exempting all articles subject to tariffs under Section 232.
What an importer from Britain most likely pays as at September 2026 is the ordinary 2.5 per cent passenger car duty, plus possibly a 10 per cent Section 301 duty depending on the answer to that question, plus a merchandise processing fee and a harbour maintenance fee which the archive has not researched. It deliberately does not publish a total, because it cannot compute one honestly.
The documents to have
| Document | What it is for | Who says so |
|---|---|---|
| Original bill of lading | Release of the car from the carrier | CBP |
| Bill of sale | Proof of purchase and of value for duty | CBP |
| Foreign registration document, a V5C for a British car | Proof of ownership and identity of the car | CBP |
| DOT Form HS-7 with Box 1 ticked | Declares the age exemption from federal safety standards | NHTSA |
| EPA Form 3520-1 with Code E | Declares the emissions exclusion or exemption | EPA |
| CBP Form 7501, stamped | The entry summary, and later the document your state DMV wants | CBP and AAMVA |
| Jaguar Daimler Heritage Certificate | Not a CBP requirement. Recommended by this archive because the NHTSA test runs from the date of manufacture and the Trust's certificate is the cleanest available evidence of it | This archive |
Ocean shipping, roll on roll off against container, transit times and costs are outside what the archive has researched, and it will not describe them.
Titling, which is where it gets local
Importing the car and titling the car are two different problems with two different authorities. Federal law gets the car into the country. A state issues the title, and the requirements vary, so what follows describes mechanisms and gives one worked example rather than pretending there is a national rule.
The American Association of Motor Vehicle Administrators published Imported Vehicles guidance in March 2021. It is not law, but it is the document state DMVs work from. Its recommendations are these.
- A signed and stamped CBP Form 7501 is the only form that should be accepted as verification of a vehicle importation.
- Jurisdictions should require the HS-7.
- AAMVA recommends against requiring the EPA 3520-1, and says to accept the 7501 as evidence it was provided.
- Jurisdictions should require sufficient proof of ownership, noting that many countries do not issue a title at all, which is the position of a British V5C, a registration document rather than a title.
Virginia, as a worked example
Virginia DMV's Vehicle Licensing Guide VLIC-3.330, revision date 25 February 2025, requires one of CBP Form 7501, CBP Form 3299 or an ACE report; NHTSA Form HS-7; EPA Form 3520-1, which Virginia does require despite AAMVA's recommendation; the original ownership document; a bill of sale where the ownership document is not in the applicant's name; and English translations of any foreign language document. On the age exemption Virginia says vehicles less than 25 years old must provide acceptable proof of FMVSS compliance, so a car 25 years or older needs none.
Virginia is given as one example of the shape of the requirement. It is not a template. Check your own state.
A car with no US title
Three mechanisms exist for a car that has never been titled in the United States, and it is worth being clear about who each one is actually for.
- A bonded title. Texas is the documented example. TxDMV states the bond is equal to 1 and a half times the value of the vehicle, and that you have one year from the date of the notice to purchase the bond.
- An administrative hearing before a tax assessor collector, in Texas via Form VTR-130-ND.
- A court ordered title, which most states have an equivalent of.
A properly imported E-Type with a stamped 7501 and a V5C should not need any of this. The bonded route matters for the reader buying an already imported car from somebody who never titled it, which is a more common situation than it sounds.
The Vermont route is closed
What it was: Vermont did not title vehicles above a certain age, so a non resident could register such a car in Vermont by post on a bill of sale, and use that registration to title the car at home.
What happened: a Vermont DMV policy update dated 26 June 2023 stated that the Department will not process such transactions unless the owner can establish a legitimate connection to the State of Vermont. It was reported by Rob Siegel for Hagerty, who reports the DMV attributing the change to high volume commercial abuse, stolen and salvage vehicles and fraudulent documents. A Massachusetts RMV notice records that on 1 January 2024 Vermont changed its title law to title all vehicles regardless of age, and that the position was then revised so that a vehicle 2009 or older need only submit a bill of sale to obtain a Vermont registration. Vermont DMV's current title page states the age based titling exemption survives for a Vermont registered vehicle of 2009 or older, and notes Act 165 enacted on 1 July 2024.
The age based exemption still exists for Vermont residents. The residency screen closed the route to everybody else in 2023, and the law moved again in 2024. Anyone still recommending the Vermont route to a non resident is working from an out of date page.
What the archive has not established
- Whether a 25 year old car at 9903.94.04 counts as subject to Section 232 tariffs for the Section 301 exemption. This is the consequential one.
- The specific age threshold in HTS heading 9705, because CBP's antiques guidance could not be loaded.
- The General column 1 duty rate verified line by line against the HTSUS itself, as distinct from CBP's own published statement of 2.5 per cent.
- The threshold at which a formal entry and bond become mandatory for a personally imported vehicle, and whether a private individual may file entry without a broker. Every source found on this was a customs brokerage marketing its own services.
- The treatment of a personally owned vehicle under the Importer Security Filing rules at 19 CFR Part 149. The filing exists and in practice the shipping agent or broker makes it, but the archive could not retrieve CBP's own guidance.
- Which states, if any, independently refuse to accept a Vermont registration as an ownership document.
- Whether the discrepancy in 40 CFR 85.1511(f)(2) has ever been raised with EPA.
Common questions
Can I import a Jaguar E-Type into the USA?
Yes, and easily. Every E-Type was built between 1961 and 1974, so every one of them is over 25 years old and enters under the age exemption at 49 CFR 591.5(i). You tick Box 1 on the DOT form HS-7 and declare Code E on EPA form 3520-1. You do not need a Registered Importer and you do not need a DOT conformance bond.
How much duty do I pay importing a classic car into the USA?
The ordinary passenger car rate, which CBP publishes as 2.5 per cent of the price paid or payable. The 25 year age does not reduce that, whatever shipping company websites say. What the age does is exempt the car from the additional Section 232 automobile tariff, at HTS subheading 9903.94.04. As at September 2026 there is an unresolved question about whether a 10 per cent Section 301 duty also applies to a British car. Get that confirmed by a broker before shipping.
Do I need a Registered Importer for a car over 25 years old?
No. The Registered Importer and bond requirement sits at 49 CFR 591.5(f), which is a separate provision from the age exemption at 591.5(i), and 591.6 does not extend it. A NHTSA interpretation letter of 2000 confirms it. A CBP entry bond is a different thing.
Does the Vermont registration loophole still work?
Not for a non resident. Vermont's DMV closed it on 26 June 2023 by requiring a legitimate connection to the State, and the title law changed again on 1 January 2024 and then in Act 165 of 1 July 2024. The age based titling exemption still exists for Vermont residents with a vehicle of 2009 or older. Any guide still recommending it to an out of state buyer is out of date.
Why does my imported car's title say Gray Market?
Because AAMVA, whose guidance state DMVs work from, recommends that age exempt imported vehicles be branded Gray Market followed by Exempt from Compliance. It describes how the car entered the country. It is not a defect brand like salvage, though it may affect resale.
Sources
- United States Code of Federal Regulations, 49 CFR Part 591, in particular 591.5(f), 591.5(i) and 591.6, and a NHTSA interpretation letter of 2000.
- DOT Form HS-7, revision 02-2020, and NHTSA's published import guidance.
- EPA Form 3520-1, August 2024 revision, and 40 CFR 85.1502 and 85.1511(f).
- US Customs and Border Protection, Importing a Motor Vehicle, and CBP message CSMS 64624801 and CBP's Section 232 frequently asked questions.
- Presidential Proclamation 10908, Adjusting Imports of Automobiles and Automobile Parts Into the United States, Federal Register, 3 April 2025.
- Learning Resources, Inc. v. Trump, No. 24-1287, consolidated with Trump v. V.O.S. Selections, Inc., decided 20 February 2026.
- The Section 301 action taking effect 24 July 2026, and its Annexes I and II.
- American Association of Motor Vehicle Administrators, Imported Vehicles, March 2021.
- Virginia Department of Motor Vehicles, Vehicle Licensing Guide VLIC-3.330, revision date 25 February 2025.
- Texas Department of Motor Vehicles, bonded title and Form VTR-130-ND guidance.
- Vermont Department of Motor Vehicles title guidance, and Act 165 of 1 July 2024; Massachusetts Registry of Motor Vehicles notice on the Vermont title law change; Rob Siegel writing for Hagerty on the 26 June 2023 Vermont policy update.
- Jaguar Daimler Heritage Trust, archive services.
- A note on verification: the HTSUS chapter file, CBP's antiques guidance and CBP's Importer Security Filing FAQ could not be retrieved during this research. Where that is so, the page says what it could not establish rather than filling the gap.
Last reviewed .
