Disclaimer

I am not a customs broker or anyone else able to give legal advice, just a guy who wants to buy a mini truck. I have written this up to ensure that I have a good understanding of how the process works and have all my resources handy, and your experience may differ. Take everything here with a grain of salt, and do lots of research.

Background reading

Lots of folks have done this before, and my post is based off this Reddit thread, this blog post, and another person’s experience. Please read through these articles for additional details and other perspectives.

Process

The general process can be outlined as:

• Decide which kei vehicle you want to purchase
• Find one available for purchase
• Buy it
• Work with an exporter to get it on a ship
• Pick it up from the port, clear customs
• Register it for on-road usage

We’ll go through this process in more detail below! The process isn’t hard per se, but there is a reasonable amount of complexity and attention to detail required. Read a few guides, then jump in and give it a shot!

My plan and goals

I have a few goals with this project:

• Learn how to import an arbitrary product of reasonable complexity
• Build a kei vehicle import business (there is a nascent but growing market in Texas)
• Get a fleet of cool kei vehicles

My plan is to slowly ramp up the complexity of what I’m importing and how I import it, as follows:

• Import a kei vehicle on an informal entry
• Import a kei vehicle on a formal entry
• Import a container of kei vehicles (on a formal entry)
• Import a non-standard vehicle (e.g. fire truck, RV, etc.)
• Import parts for said vehicles

Researching

Each vehicle is going to have different requirements, and there are a million videos comparing different kei vehicles, so watch videos, read forum posts, etc. Your ultimate goal should be a precise make, model (and code), year range, color, auction grade, etc. that can be the input to a search feature, as this will let you create alerts.

25 year limitation

The critical thing to be aware of is that the vehicle needs to be > 25 years old, to the month, on the day it arrives in the US in order to be imported. As of right now (Oct 2024), you’re probably safe buying a 1999/12 vehicle, as it probably won’t arrive in the US before then (especially given the current port strike), but this is something to be aware of.

Historically, the seat belt has the month and year on it, though this changed in 1999 to just be the year; the export certificate will still have the month of manufacture (or will just be marked January, depending on the exporter). It’s better to be safe than sorry, so do your diligence.

Note that Japan often uses a different year system (year of the emperor’s reign), so the kei vehicles you can import will all have Heisei (平成) era dates on the auction sheets. The Heisei era started in 1989 (Heisei 1), so a 1999 vehicle is Heisei 11. Don’t import anything Heisei 12+ yet!

An example: buying a kei truck

For me, the first kei vehicle I want to import is a kei truck. My criteria look like:

• 4WD (w/4L or EL gearing)
• Fuel injected
• Manual
• A/C
• Mid or rear engine (vs engine under the seat); primarily for heat/noise
• Ample cab space
• As rust free as possible

This led me to the Subaru Sambar (TT2 [99+]), Suzuki Carry (DD51T[91-99], DB52T [99+]), Daihatsu HiJet (S210P [99+]); with the most restrictive requirement being fuel injection. The Wikipedia articles for all of these vehicles have a lot of detail about model codes, engines, etc., and you can always run a VIN lookup to verify this information.

My vehicle shortlist

My current short list is:

Buying

Where to buy

There are two primary ways to buy a kei car:

• Buying at auction (often via an exporter)
• Buying in stock (often via a dealership aggregator)

You can bid directly at auction and find an exporter, but I won’t cover doing that. You can also buy directly from a dealership (and avoid the middleman of the aggregator service), and I have listed Mitsui (which seems to be the most common one), though I’ve heard mixed reviews. This is not an exhaustive list by any means.

The most accessible ways to purchase at auction are:

• japancardirect.com
• ts-export.com

The most accessible dealership aggregators are:

• tc-v.com
• goo-net-exchange.com
• carfromjapan.com

Note: it’s common to see the same car listed across sites with different prices, so I recommend going directly to the dealership’s website or checking other aggregators to see how stable the price is.

The most common dealership exporters are:

• mitsuicoltd.com

Differences

TL;DR: IMO, if you’re looking for something fairly common (e.g. most kei trucks), just buy it from an aggregator. If you need something very specific, are willing to scan listings, wait for a bit, and are OK with price variability (up or down), then buy from an exporter at auction.

Timing

In stock vehicles at dealerships will be faster to ship, as they are ready for export and typically, the only delay will be waiting for a suitable ship. If you buy from an auction, it will have to be transferred from the auction house to a warehouse/parking lot, wait for an export certificate, etc. (likely up to a month). This may or may not be an issue depending on your timeline, as well as ship sailing schedules.

Buying Costs and Fees

In stock vehicles at dealerships are more expensive, though I think this is a bit deceptive, as buying the car at auction isn’t the end of the story. Let’s take an example of a $1000 Suzuki Carry bought at auction (through e.g. japancardirect), vs a $1900 Suzuki Carry bought through a dealership (e.g. through tc-v).

The common fees to get an auction bought car ready for export are:

• Auction house fees: ¥20,000 - ¥40,000
• Transportation fees: ¥20,000 – ¥40,000
• Storage fees: ¥500 - 1000/day (assume 30 days)
• Export shipping charges: ¥25,000 - ¥45,000
• Any fees charged by the exporter (e.g. ¥79,000 for JCD and ¥50,000 - ¥100,000 for tc-v)

So in this scenario, we’re paying (at the low end), 20k + 20k + 30*500 + 25k + 50k = ¥130,000 in additional fees to get the car ready for export. At the current exchange rate (Oct 2024), that’s ~$900, meaning that the two trucks cost basically the same by the time you’re exporting them.

Quality

The auctions all provide an auction sheet and grade (S, 6, 5, 4, 3.5, 3, 2, R, etc.). You’re likely aiming for a grade 3, 3.5, or 4. I would recommend aiming for as little rust as possible (ideally none), and minimal dings/scratches, but obviously, the higher the quality, the higher the price. Information on reading the auction sheet can be found here.

Auction sheets should be treated as a starting point, as they can be altered or swapped. Many of the auction purchasing services will provide paid walkarounds to see the car in person at the auction and send photos/videos so you can confirm what you’re getting.

Paying the invoice

Dealership

When buying from a dealership (or dealership aggregator), you’ll be provided with a proforma invoice, and then once you pay, you’ll get the official invoice, marked as paid. Keep this invoice, as you’ll need it later in the process when it comes to determining import duties.

The invoice will include wire instructions (SWIFT code and account number). I used Wise to send USD (referral code), but they can also send JPY. Make sure to include the invoice number in the memo field, otherwise the recipient will have no idea who is paying them/for what. Mercury (referral code) also handles international wires for free.

In either case, if anyone asks for MoneyGram or Western Union, run.

Auction

Most of the auction sites require some amount of money up front for them to bid for you. You’ll get invoiced as per above for all additional costs once the vehicle is ready for export.

Exporting

Picking an export port

My recommendation is to let the exporter handle this, as they can best optimize getting your car from the auction house/dealership to the port of export.

Picking an import port

There are several considerations to picking a port to import to:

• Geographic proximity to you: the closer it is, the less you’ll have to pay to get your vehicle to you
• Frequency of shipping options: some ports have more RORO vessel journeys than others
• Access: some ports (most) require a Transportation Worker Identification Credential (TWIC) or an escort, which can cost ~$100; if there’s one nearby that doesn’t, you might save some time
• Fees: some ports (most) have a Harbor Maintenance Fee (HMF)

Texas has three valid options: Freeport, Galveston, and Houston; however, only Freeport and Galveston support RORO. Both are equally close to me, but I was advised to use Freeport vs Galveston, as it’s got a higher frequency of RORO vessels.

Free on Board (FOB) vs Cost, Insurance, and Freight (CIF)

TL;DR:

• FOB: The seller is responsible for the goods until they are loaded onto the ship, at which point the buyer takes on ownership and responsibility.
• CIF: The seller is responsible for the goods until they reach the buyer’s port, including the cost of shipping, insurance, and any necessary documentation, licenses, or inspections.

Many exporters offer a C&F option (no insurance), so it’s up to you if you want to save the $50 or so for maritime insurance. Most of the time, this is going to be the default for dealership aggregators.

My recommendation is to use C&F or CIF and let the exporter handle the shipping, unless you have strong preferences on how to do ocean freight.

Roll-on/Roll-off (RORO) vs Container

RORO is what it sounds like: vehicles are driven on to the ship and then off the ship. It’s the easiest method, but also the slowest, as there are fewer RORO vessels on any given route than there are container ships. ROROs will also make more stops (because there are fewer ships), further increasing delivery time. Luckily for me, Texas is one of the first stops after the ship clears the Panama canal.

Note: “inner cargo” (e.g. additional wheels, spare parts, etc. shipped inside the vehicle) is no longer allowed in vehicles shipped RORO. If they somehow get included, they may present issues for customs (as you may have to file additional line items on your entry forms, pay additional import tariffs, etc.).

A container is also what it sounds like: vehicles are strapped down inside the container. It requires more preparation, but is much faster and allows you to ship additional things vs just the vehicle. I would only recommend this if you have enough vehicles (or spare parts) to justify the additional work of packing and unpacking the container, and have a team on the shipping end willing to make this happen. Most of the dealership aggregators won’t provide this service, though folks like JapanCarsDirect may. On the receiving end, you may also need a loading dock to unload at, which might be difficult if you’re not operating out of a warehouse with one.

Shipping Costs and Fees

Note: shipping costs are constantly fluctuating and are influenced by all sorts of things: the weather, the time of year, geopolitical events that reroute ships, etc. Any costs referenced here made sense when it was written, but may not make sense when you look. I’ve included some ways to check current prices.

RORO charges by the cubic meter (m^3), and $100/m^3 is a reasonable “low end” starting point, though with additional fees, etc., it can look more like $150/m^3. The typical kei truck is 9-10m^3 (cars will be a bit smaller, vans might be a bit larger, etc.).

Container costs are for a 20-40 ft container, and can vary considerably (get your Bloomberg Terminal ready). Some benchmark rates that I’ve seen: $1,500-3,500 for a 20' container (2-3 kei vehicles) and up to $10,000 for a 40' container (which people can get 6-7 kei vehicles in, depending on how they’re stacked). Freightos (among others) has a calculator, at the time of writing, a 40' container from Kobe to Houston was listed at $7,300-9,000, so I don’t think it makes sense unless you can pack the container full (and full of spares, etc.) or container prices crater.

Post purchase status check

By this point, you’ve selected a vehicle, purchased it, and it’s loaded on a ship bound for the US. Let’s quickly do a status check, file some paperwork, and prepare for the long boat ride.

Received forms

You should have received multiple copies of each of these documents:

• Purchase invoice
• Export certificate (and English translation)
• Bill of Lading

Typically these will be airmailed to you once the vehicle is loaded onto the boat. You will need all of these in the future, so take good care of them!

File your ISF (10+2)

An ISF, or Importer Security Filing, also known as a 10+2, is a required document for all ocean cargo entering the US. It should be filed 24 hours before the vessel departs for the United States. Non-compliance can result in a $5,000 fine, increased inspections and/or a cargo delay.

You can file your ISF via eezyimport.com for $15 or easyisf.com for $25. I used eezyimport because they can do some of the other forms as well (and I think their interface is nicer), but either seems to work. You will need your Bill of Lading to fill this out.

Tracking your ship

Use Marine Traffic or Vessel Finder to track your ship every now and then. As the reddit thread states, refreshing the page every five minutes doesn’t make the ship move faster, but YMMV.

Importing

Customs

Informal vs formal entry

There are actually three common types of entry:

• De minimis: Goods valued at less than $800, brought in by you on one day (e.g. coming back from vacation)
• Informal: Goods valued at less than $2500 (or $250 from China); doesn’t require a customs bond
• Formal: Goods valued at over $2500 (or $250 from China), regulated/restricted items (food, drug, firearms, textiles), etc.; requires a customs bond

Informal entry is easier and less expensive; formal entry is more of the “best practice”. Technically, for informal entry, the customs officer can fill out the forms (including picking the right HTS code) and you don’t need to do a CBP 7501 as they will do it all, but I think you should do all of this regardless and come as prepared as possible. In my opinion, the only difference here is the lack of need for a customs bond.

Import tariffs and duties

TL;DR: cars and vans are taxed at 2.5% of the purchase price (which may also include shipping insurance) and trucks at 25%.

Trucks (Suzuki Carry, Honda Acty, Daihatsu HiJet, Subaru Sambar, etc.) are classified under the HTS code 8704.31.0120 (“Motor vehicles for the transport of goods: Other, with only spark-ignition internal combustion piston engine: G.V.W. not exceeding 5 metric tons: G.V.W. not exceeding 2.5 metric tons”), per ruling N340640. This is true for deck vans (see ruling N331360) as well as trucks with dump beds (see ruling N338708).

The only potential exception I see is kei fire trucks, which might be considered under HTS code 8705.30.0000 (“Special purpose motor vehicles, other than those principally designed for the transport of persons or goods (for example, wreckers, mobile cranes, fire fighting vehicles, concrete mixers, road sweepers, spraying vehicles, mobile workshops, mobile radiological units): Fire Trucks”), though there is no current ruling on this. Importing under this would be considered duty free; however, most kei fire trucks are significantly more expensive than standard kei trucks, so you’re probably not saving anything.

Non-deck vans (Suzuki Every, Subaru Sambar Dias, etc.) are classified under HTS code 8703.21.0150 (“Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 8702), including station wagons and racing cars: Other vehicles, with only spark-ignition internal combustion reciprocating piston engines: Of a cylinder capacity not exceeding 1,000 cc: Other”), per ruling N340362, and subject to a 2.5% tariff. See this Reddit thread for more information.

Cars and small SUVs should fall under HTS code 8703.21.0150 (“Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 8702), including station wagons and racing cars: Of a cylinder capacity not exceeding 1,000 cc: Other”) as well, though I haven’t found example rulings beyond this one for the original Suzuki Samurai 954720, referencing a code that no longer exists.

Submitting the paperwork

You’ll need to submit three forms:

• CBP 7501
• NHTSA HS-7
• EPA 3520

If all else fails, you’ll submit paper copies of this in person, but you should be able to do one of two paths to submit electronically, depending on which port of entry you use:

• Email customs these forms (likely through the regional field office; this seems to be getting phased out and varies by CBP office)
• File an entry via your customs broker of choice

The field office for Freeport is Houston, which only lists a phone number (+1 713-387-7200). After getting shuffled around on the phone for a bit, I got directed to the Houston Seaport office (+1 713-387-7200), who confirmed that:

• Informal entry of vehicles is allowed, so no customs bond is required
• In order to file my entry, I would have to either:
  • File in person at 2350 N. Sam Houston Parkway, Houston, TX 77032 (where all sea cargo processing and releases occur)
  • File electronically via a customs broker

They also gave me the phone number for the sea cargo processing and release office (+1 281-985-6700 x 6854/6858/6861). I was unable to call an extension from the main phone tree, but after calling +1 281-985-6700,3#,1 several times, I was finally able to speak to a human who confirmed the above.

My recommendation is to file an informal entry with all the associated paperwork electronically; doing it in person (especially if you’re asking the customs official to handle gathering the paperwork), is a recipe for disaster.

Clearing customs

After you submit the paperwork, you’ll have to wait for it to be processed. This may be “instant” (especially if you do it in person), or it may take some time, depending on the specifics of your vehicle, and CBP wouldn’t give firm details on how long it usually takes.

Picking up the vehicle

After your vehicle clears customs, and there are no holds (customs or otherwise), you’ll go pick up your vehicle. I am including the general instructions, and will fill in specifics for Freeport when I pick up my truck.

Accessing the port

Port hours are published on the port’s website, e.g. Freeport is M-F 0600-1700. Most ports close fo 60-90 minutes over lunch; Freeport is closed 1200-1300 for lunch. Note that Freeport also has “last truck entry” hours 15 minutes before closing (1645), and I recommend showing up as early as possible to get your vehicle.

Transportation Worker Identification Credential (TWIC)

“The Transportation Worker Identification Credential, also known as TWIC, is required by the Maritime Transportation Security Act for workers who need access to secure areas of the nation’s maritime facilities and vessels.”

For ports that require a TWIC, which is most of them, you can either apply for one ($125 for five years, also works for TSA Precheck) or use a TWIC escort service (available at the port). I chose to apply for one, and was able to get an appointment for the next day. The card itself takes 4-6 weeks to ship, so plan ahead.

You can check if your chosen port requires a TWIC by visiting the port’s website, e.g. Freeport requires TWIC: “Security: TWIC card required for entry”.

Other items

Bring a safety vest (this one has a handy ID card pocket for the TWIC card), a battery starter or set of jumper cables (the battery will almost certainly be dead after a month plus at sea), as well as all your paperwork (in particular, any delivery orders, port fee receipts, shipping company fee receipts, etc.).

Finding your vehicle

Ports are large, and there are often multiple lots where your vehicle could be parked.

Getting your vehicle home

If you have a truck that can tow, the recommendation is to use the 6’x12' U-Haul Utility trailer. Kei vehicles are legally mandated to be no larger than ~5’x11', so they fit perfectly. Bring a set of ramps and some ratchet straps to properly secure the vehicle.

If you don’t have a truck that can tow, or the distance is too great, you’ll want to arrange for overland transportation from the port to your destination of choice. I won’t cover how to do that here, as I live close enough to a port and have a truck that can tow.

Legal

Texas

As of April 4, 2024, kei vehicles are fully legal in Texas per Title and Registration Procedures for Mini Vehicles.

Vehicle inspection

Texas law requires that all vehicles previously registered and titled or registered in another state or country be inspected for safety and the vehicle identification number verified before such vehicles may be registered in Texas. These inspections must be made by a state appointed safety inspection station that will complete a Texas Vehicle Inspection Report. This form must be submitted to a county tax assessor-collector with your application for registration and Texas title.

You can learn more about the Vehicle Inspection Program, and find an inspection station near you. You will need to complete this before you title the vehicle.

Title and registration

In order to title and register a vehicle, you will need:

• Properly assigned evidence of ownership may include:
  • foreign evidence in the name of the owner/dealer or assigned to the owner/dealer,
  • a bill of sale,
  • an out of state title in the name of the owner or assigned to the owner, or
  • a registration receipt in the name of the owner or assigned to the owner, if the vehicle was last registered in a state that does not title these vehicles.
• Application for Texas Title and/or Registration (Form 130-U);
• Government issued photo identification;
• Law Enforcement Identification Number Inspection (Form VTR-68-A) if last titled or registered in another country or VIN verification if last titled or registered in another state;
• Proof of US Customs Entry/Clearance, unless the vehicle was last titled and/or registered in another state;
• Proof of Form HS-7, unless the vehicle was last titled and/or registered in another state.

Restated, bring the following to the DMV:

• Photo ID
• Export certificate (and English copy)
• Purchase invoice
• Form 130-U
• Form VTR-68-A; Austin PD provides this service
• CBP 7501
• DOT HS-7 Short
• Vehicle Inspection Report from above

Elsewhere in the US

This Reddit thread details per-region legality of Kei vehicles.

Maintaining

This section will be updated once I figure out spare parts availability and maintenance.

Appendix

Costs

Paperwork

This section is a deep dive into the paperwork involved in importing a kei vehicle. It will also include information on how I have filled out certain forms.

Purchase Invoice (or Bill of Sale)

What it is: Proof of purchase for the vehicle.

Where you get it: From the exporter (who gets it from the seller).

What you will need it for: Clearing customs, registering the vehicle in the US.

Bill of Lading (BoL)

What it is: The “shipping notification” for your shipment.

Where you get it: From the exporter.

What you will need it for: The BoL number (in particular) will be used on the paperwork for import (ISF, CBP 7501, etc.).

Export Certificate

What it is: The vehicle’s title. Since Japan doesn’t provide the actual title on export, this is used in place of the title.

Where you get it: From the exporter.

What you will need it for: Registering the vehicle in the US.

Make sure to ask for an English copy if it’s not immediately provided, as you will need this for customs and registration.

ISF (10 + 2)

What it is: Notification to the US government that you have cargo arriving.

Where you get it: You fill it out > 24 hours before the ship departs for the US.

What you will need it for: Legal compliance for cargo entering the US by ship.

I recommend using eezyimport.com ($15) since it’s the cheapest, but easyisf.com ($25) and turboisf.com ($110) are valid options.

CBP 7501

What it is: This is the “entry summary” that contains all items entering the US, where they have come from, who delivered them, and what duties are due.

Where you get it: On the CBP website: CBP 7501.

What you will need it for: Releasing your goods from customs, calculating duties and fees.

Filling it out: Instructions are included at the bottom of the form linked above. You will need to fill out fields 1, 2, 6, 8, 10, 11, 12, 14, 16, 17, 23, 26, 27, 28, 29A, 30A, 30B, 31, 32A, 33A, 33C, 34, 35, 36, 37, 38, 39, 40, and 41.

Port codes (6, 19, 20)

Import port code can be found via CBP Schedule D - US Port Codes. Common Texas port codes are: Houston: 5301, Galveston: 5310, Freeport: 5311.

Export port code can be found via CBP Schedule K - Foreign Port Codes document. Common Japanese port codes are: Nagoya: 58857, Kobe: 58840, Yokohama: 58895.

HTS codes & duties (27-30, 32-24)

As discussed in Import tariffs and duties, you will use the following codes and duties:

• 8704.31.0120: Trucks, deck vans, dump beds, etc.; 25% import tariff
• 8703.21.0150: Cars, vans, SUVs, etc.; 2.5% import tariff

You can use the HTS lookup tool to get more information on these codes.

You will calculate duty via:

• 32A (Entered Value): Vehicles purchase price. For my first kei truck, this was $1,700.
• 32B (CHGS): Charges for shipping, insurance, etc. Per the form instructions, we prefix it with the letter C. For my first kei truck, this was $1,300.
• 33A (HTSUS Rate): From above, either 25% or 2.5%. For my first kei truck, this was 25%.
• 34: Multiply 32A by 33A. For my first kei truck, this was $1,700 * 0.25 = $425.

Other fee summary (for Block 39)

You will also need to add the following fees for informal entry:

• Harbor Maintenance Fee/HMF (code 311): 0.125% fee on commercial value. For my first kei truck, this was $1,700 * (0.125/100) = $2.125 = $2.13.
• Merchandise Processing Fee/MPF (code 501): $2.62 (if automatically filed by you), $7.85 (if filed in person by you at CBP), $11.78 (if filed in person by the CBP). These numbers com from the federal register, and may change on an annual basis.

Formal entry fees would be:

• HMF: same as informal entry.
• MPF: 0.3464% of merchandise price, with a minimum of $32.71 and maximum of $634.62.

Formal entry would cost me about $30 more ($32.71 vs $2.62) in fees (not to mention the customs bond).

NHTSA HS-7

What it is: Federal motor vehicle safety standards declaration (or, in our case, an exemption due to age).

Where you get it: On the NHTSA website: HS-7.

What you will need it for: Clearing customs, registering the vehicle in the US.

Use box 1 (“The vehicle is 25 or more years old or the equipment item was manufactured on a date when no applicable Federal Motor Vehicle Safety Standard or Theft Prevention Standard was in effect."). Enter the month and year (e.g. 02/1999).

EPA 3520

What it is: EPA certification for vehicles entering the country.

Where you get it: On the EPA website: EPA 3520-1.

What you will need it for: Clearing customs.

Use exemption E (“Vehicle is at least 21 years old”) in box 9; check the box as well. For the storage contact in box 12, use the port information.