CBP Says Non-Repairable Transfer Certificate Proves Ownership, Exportability of Used Car

A “Transfer of Non-Repairable Vehicle to a Demolisher” certificate issued by the District of Columbia, along with a bill of sale, is enough to prove eligibility for export of a used car through the Port of Baltimore, CBP said in a recent customs ruling. Though the exporter did not provide a title for the vehicle, the documents provided “are sufficient to show that the requestor has ownership of the subject vehicle,” CBP said in HQ H308498.

Under documentation requirements for used cars found in 19 CFR 192.2, exporters of cars for which a junk or scrap certificate has been issued are required to submit the original and two copies to CBP. But there is no national requirement concerning the titling of junk or salvage vehicles. CBP has clarified that, because local authorities “have inconsistent or varying certification requirement for such vehicles, Customs must require of these vehicles the most authentic documents available to establish ownership of the vehicle to be exported.”

In cases in which no junk or scrap title or certificate was issued or remains in force, CBP will accept a bill of sale establishing ownership, the agency said. The bill of sale will be accepted only if “(1) the owner certifies to Customs in writing that the government-issuing authorities for the jurisdiction has no registration/certification requirements for such vehicles, and (2) the owner attests in writing to the bona fides of the sale and that the vehicle presented for export is not stolen,” CBP said.

In the case of the used car exported out of Baltimore, the subject “'Transfer of Non-Repairable Vehicle to a Demolisher’ is sufficient to establish ownership of the vehicle by the requestor,” CBP said. “This document, which is issued to the requestor, contains the subject vehicle’s VIN number and is signed by an employee of DC DPW - Abandoned Vehicles Operations,” it said. And though it is not marked specifically as a junk or scrap certificate, it does say it transfers ownership of the vehicle. While, taken together, the bill of sale and the DC certificate are enough to prove ownership, the exporter may still be required to provide original documents or certified copies at time of exportation, CBP said.