Vehicle Export Title Clearance & the CBP 72-Hour Rule

What the title clearance service covers

A used vehicle cannot leave the United States on paperwork alone. Under 19 CFR 192.2 the exporter, or an agent acting for the exporter, has to present both the vehicle and the document that proves ownership to U.S. Customs and Border Protection at the port of export. CBP checks that the document is genuine and that it describes the vehicle in front of it, marks the original, and only then lets the vehicle load. CBP calls the certificate of title the core requirement of the export process, regardless of the vehicle's value, physical condition or whether it runs.

We act as your agent for that step. The service is part of every vehicle export shipping and heavy equipment export shipping booking with us, and it covers:

• Reviewing the title, salvage certificate, manufacturer's statement of origin or bill of sale before the vehicle is booked, so a problem surfaces while there is still time to fix it.
• Matching the VIN, or the product identification number on a machine, on the document against the plate on the vehicle when it reaches us.
• Preparing the two complete copies CBP asks for, front and back, and any lien release or lienholder letter.
• Filing the Electronic Export Information (EEI) in AES and receiving the ITN that proves it was filed.
• Presenting the documents and the vehicle to CBP at the port at least 72 hours before the vessel sails.
• Returning the CBP-stamped original with your bill of lading and the rest of the shipping documents.

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Which vehicles the 72-hour rule applies to

The rule covers used self-propelled vehicles, and both words are defined more broadly than most exporters expect. In 19 CFR 192.1 a self-propelled vehicle includes any automobile, truck, tractor, bus, motorcycle and motor home, plus self-propelled agricultural machinery, self-propelled construction equipment, self-propelled special use equipment and any other self-propelled vehicle designed for running on land but not on rail. An excavator, wheel loader, combine, forklift, ATV or side-by-side is therefore inside the rule just like a sedan.

Used means that title has passed from a manufacturer, distributor or dealer to an ultimate purchaser, the first buyer who is not buying to resell. A brand-new car bought from a dealer by a private buyer, even with a few miles on it, is a used vehicle for export purposes and needs its manufacturer's statement of origin or title presented in the same way.

Vehicles that entered the United States in bond, under an ATA carnet, under a temporary importation bond or under the one-year personal exemption for non-residents are exempt. Boats are not land vehicles, so the hull itself is outside part 192, but we still need the registration or title to describe it on the bill of lading.

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Which ownership document CBP needs

CBP works through 19 CFR 192.2(b) in order and stops at the first case that fits the vehicle. In every case it wants the original, or a certified copy where the rule allows one, plus two complete copies; where there is writing on the back of the document, a complete copy shows both sides.

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Liens, leases and the lienholder letter

A title that shows a lienholder is the most common reason a car misses its sailing. If the loan has been paid, the clean answer is a lien release or a new title without the lien. If the loan is still open, or the vehicle is leased, CBP accepts the export only with a separate letter from the bank or leasing company that expressly says the vehicle may be exported. A payoff statement or a printout of the account does not meet the rule.

• It is printed on the lienholder's or lessor's letterhead.
• It describes the vehicle completely, including the VIN.
• It names the owner or lienholder and gives telephone numbers where CBP can reach them.
• It carries an original signature and the date it was signed.
• It expressly allows the vehicle to be exported.

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How the 72 hours are counted

For a vehicle that leaves by vessel or aircraft, 19 CFR 192.2(c) requires both the documents and the vehicle to be presented to CBP at least 72 hours before export. For a vehicle that leaves by land, the documents go in 72 hours ahead and the vehicle is presented at the border crossing. The port director decides where documents and vehicles are presented and during which hours, so the practical deadline is set by the port's office hours rather than by the sailing time alone.

The export record has its own 72-hour clock. Under 15 CFR 30.4 the EEI for a used self-propelled vehicle must be filed before departure and its filing citation, the ITN, given to CBP at least 72 hours before export. Postdeparture filing is not available for used vehicles, and if AES is down the vehicle simply waits until an ITN can be issued.

Some ports count the window in working hours, leaving out weekends and federal holidays. We plan for the title and the vehicle to be at the port the week before the sailing, which covers both ways of counting and leaves room for a CBP examination.

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How it works, step by step

1. 1

   Send us a photo of the title

   Before booking, send a photo of both sides of the title or other ownership document. We confirm it is the right document for 19 CFR 192.2 and flag liens, brands or missing assignments.

2. 2

   Sign the power of attorney

   A short power of attorney authorizes us to file the EEI and present the documents to CBP for you. Foreign buyers also send a passport copy; U.S. sellers send an ID and their EIN or other identifier for the filing.

3. 3

   Mail the original

   The original title, or certified copy, comes to us by tracked courier together with any lien release or lienholder letter. A copy or a photo is never enough for CBP.

4. 4

   VIN check at receiving

   When the vehicle or machine reaches us we photograph the VIN or PIN plate and compare it, character by character, with the document.

5. 5

   EEI filed, ITN issued

   We file the EEI in AES with the VIN, title number and title state, and the ITN goes on the dock receipt and the bill of lading.

6. 6

   Presented to CBP

   The original, the two copies and the ITN are presented to CBP at the port at least 72 hours before the sailing, while the vehicle is at the terminal. CBP may examine the vehicle before it releases it to load.

7. 7

   Stamped title returned

   CBP marks the original and, in most cases, returns it. It travels to your consignee with the bill of lading, because many destinations ask for the stamped U.S. title to register the vehicle.

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Excavators, tractors and other machines without a title

Most states do not issue titles for off-road construction and farm machinery, yet the machines are self-propelled vehicles under part 192 and still go through CBP. For these, CBP accepts the document that shows how the machine was acquired, usually the auction invoice, dealer invoice or bill of sale, plus two complete copies and a written certification from the owner that the purchase was a bona fide transaction and the machine is not stolen. Where a title was issued and is no longer in force, the same route applies.

The weak point is identification. CBP matches the document to the product identification number on the machine, so we check that the invoice carries the full serial or PIN rather than a lot number, and that the PIN plate is present and readable. A repainted or missing plate is worth sorting out with the seller before the machine leaves the auction yard. Container fit, dismantling and loading for machinery are covered on our machine dismantling page.

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Title problems we catch before the port does

• A VIN on the title that differs by one character from the plate, often a typing error at the DMV. It has to be corrected by the state before export.
• A title signed over to nobody, or passed through several owners without being retitled. CBP looks for an unbroken chain to the person exporting.
• An auction lot marked title pending. Copart and IAAI can take weeks to release some titles, and the vehicle cannot sail without one.
• An electronic title. States that keep titles electronically have to print a paper title before CBP can see an original.
• A replaced or duplicate title. Only the most recent title is in force; an older original that turns up later is void.
• A salvage, junk or non-repairable brand. CBP accepts these documents, but some destinations do not admit the vehicle, so we check the import rules before you book.