This was borrowed with permission from Jason Cook off of the Facebook NA Rally page of his recent experience with importing a car from Canada of a car newer than the magical 25 years.
TLDR: I did it successfully. Fully imported, insured, licensed and with a state issued title. Import as personal vehicle, obtain compliance letter from the manufacturer, understand the process/procedure/paperwork inside and out and still hope for the best. Canadian sellers can obtain the compliance letter to help expedite the process and increase their chance of selling successfully over the border.
There have been some favorable rally car deals, especially considering the CAD/USD exchange rate. Against better judgement I decided to buy and import one. I talked to several people beforehand and nobody seemed to have all of the answers I was looking for. Some had tried and failed, some had been successful with a registered importer, others chickened out and never even tried. Below is my experience and recommendations.
I think the best and perhaps only option is to import the vehicle for personal use as a "normal" car. Complete the transaction in Canada and bring through customs and border patrol (CBP) yourself. Don't try to import as a race car. Don't use a registered importer (I talked with a few and they're apparently required to send photos of vehicle safety features to the DOT while the car sits in impound). Don't import it to sell. Just import as a regular car for personal use and .
There are essentially four documents you need to have when entering US CPB:
Note regarding the Subaru compliance letter:
- Canadian registration signed over (Canada does not have titles like we have in the US)
- Bill of sale. It appears each Province has an "official" bill of sale document that can be printed for use
- DOT form HS-7. I chose option 2B which indicates that the vehicle is comparable to similar models sold in the US and I provided an accompanying letter from Subaru Canada stating this.
- EPA form 3520-1. I chose option EE which similarly indicates that it's comparable to similar models sold in the US. The same compliance letter noted above also satisfied this requirement.
Subaru of America was no help with this and I mistakenly contacted them and waited for a reply before reaching out to Subaru Canada. Subaru Canada was very helpful though. The basic process is to provide them the vehicle VIN, a copy of the registration and bill of sale (proof of ownership), and your contact info. (mailing address, email, phone number) and they'll email you a PDF compliance letter within 3-5 days. I tried to request this letter before we had completed the transaction and it didn't work. However once I had the proof of ownership they were spot on with their 3-5 day response time. If you wanted to expedite the importation process I'd see if the seller could request this compliance letter in advance, as a seller you could really make our life easier having this letter in your possession at the time of the transaction then we could go straight to the border.
CBP/Crossing the Border:
I trailered the car across in an enclosed trailer. I wouldn't recommend driving it in case the deal goes south and I think you'd likely draw a lot more unwanted attention anyway. CBP will greet you through their window and ask you standard questions (How long have you been in Canada? What was your purpose? Do you have alcohol, tobacco or cannabis? Etc.). I'd encourage you to be polite and truthful. This probably isn't the best time to try any funny stuff since it seems you need all the goodwill possible for success related to the car. They'll ask you to park and enter their office to complete the paperwork.
Inside they will have you complete CBP Form 7501. I really stressed over this form in advance because it's fairly complex but most isn't applicable to importing overland. Thankfully the Pembina, ND location had a laminated cheat sheet to help with this and even some of the form sections were pre-populated. It was fairly straightforward and the CBP personnel were helpful for a couple entries I didn't understand entirely (for instance the section for "Title" following my name I nearly wrote "Mr." but they clarified and had me write "owner" which makes more sense, I guess).
Generally duty appears to be 2.5% for general passenger, internal combustion engine cars. This is based on USD price but my bill of sale was in CAD. They didn't have any special conversion CAD/USD formula, in fact she just pulled out her phone and used Google currency conversion and a calculator app to calculate the duty owed (2.5% of purchase price in USD). I paid in credit card and in fact they had signs posted indicating a preference for CC payment (could have been COVID related).
I brought the car over in an enclosed trailer. CBP did look over the car. My car did not have any DOT or EPA (or Canadian equivalent) stickers in the door jambs or under the hood, but they looked. They did look over quite thoroughly inside and out. Not entirely sure what they're looking for but they did not appear to confirm any of the safety, theft or emission features (because this car did not have any of these OEM features being a purpose built rally car). They did not start the car nor even ask if it runs/drives. They did not even verify the VIN matched any of my paperwork, which was surprising. This inspection was the portion of the whole process I was most stressed about since I literally had a letter from Subaru Canada indicating that it met safety, theft and emissions requirements of the US but it obviously didn't have these. Afterward CBP even asked if I was going to race the car. I was careful with my response and waited to have all of the paperwork completed and in my possession before really offering some information in response. In the end I think they were more personally curious rather than asking as an authority figure.
CBP glanced at the four documents (plus the compliance letter noted above) I brought with me but didn't really scrutinize these. Having these substantially prepared and generally understanding the process seems to help improve your chances here. If you didn't know how to fill out these forms and had lots of questions you'd probably draw some unnecessary attention and may not have been as successful.
Going into the process I didn't understand who got to keep the paperwork. I incorrectly assumed CBP would keep all of the importation documents or at least keep a copy but they do not. I got to keep all of the original copies of the documents, including the CBP Form 7501 that I completed on-site. All of this paperwork gets surrendered at the state DMV/DVS for title transfer/registration.
Title and License at the State DMV/DVS:
I had previously obtained a guide/brochure for titling/registering a foreign vehicle that was published by our DMV/DVS; this document was crucial to success since they're not commonly titling/registering Canadian vehicles. The first person reviewed my paperwork and seemed to imply that I needed a separate inspection from CBP personnel at our international airport. I question this because 1. I really didn't want another inspection and the additional scrutiny and 2. the published brochure didn't say anything about this inspection. I explained everything and walked him through the brochure but he eventually turned me over to somebody with some more authority. She thought the additional airport inspection was required also but I told her it was inspected at the border when I brought it over. She also agreed that brochure was pretty clear about the steps necessary so accepted my paperwork and gave me plates for the car. I did have to pay state taxes on the USD price (6%). I did eventually receive my title in the mail several weeks later to successfully conclude the whole process.
Racing a Canadian car in the US:
Both ARA and NASA allow Canadian Association of Rally Sport (CARS) log booked cars to race. NASA General Regulations for Rallies section 184.108.40.206 indicate that that the vehicle will be inspected according to the CARS rules and NASA rules govern safety gear worn by the racer. I have not raced at a NASA event but I will plan to bring a copy of CARS rules along but I suspect it won't be necessary. ARA Rally Technical Rules section 5.2.6 simply note that the CARS (and others) log books will be accepted but must pass ARA scrutineering.
I had more stress and anxiety over the process than I needed. Although, I don't think this is for the faint of heart but it's also my opinion that if you have all of your ducks in a row the success rate would be pretty high. I'd consider doing it again if the right deal presented itself. Lastly, all of my interaction with CBP was wonderful. Very good people working up there. They'll answer questions over the phone so don't be afraid to call!