This guide explains the requirements to title and register a vehicle that was manufactured for a market outside of the United States. The most important step is to determine if the vehicle is a "Grey Market" vehicle.
1. What is a "Grey Market" Vehicle?
A Grey Market vehicle was not originally built to meet U.S. safety (FMVSS) and environmental (EPA) standards.
How to check if a vehicle might be "Grey Market":
Missing U.S. Certification Label: Look on the driver's side door jamb. A vehicle built for the U.S. market will have a sticker stating it "conforms to all applicable U.S. Federal Motor Vehicle Safety Standards..."
Non-Standard VIN: The VIN has fewer than 17 characters (for 1981 and newer models).
Foreign Ownership Documents: The customer has a foreign country's title or registration.
Non-U.S. Parts: Headlights, taillights, and glass are not stamped with "DOT" (Department of Transportation).
2. The First Step: Check the U.S. Certification Label
This is the fastest way to determine the correct process. A Level I Inspection(EZ Title & Registration can perform this inspection for you!) can confirm if this label is present.
✅ Path A: The Vehicle is NOT Grey Market
If the vehicle HAS a manufacturer's label stating it conforms to U.S. standards, you can proceed as a normal out-of-country vehicle.
Process: Treat it as a standard out-of-state title and registration.
Requirements: Standard Title and Registration Application (Form 96-0236), foreign ownership documents, and a Level I Inspection. (EZ Title & Registration can perform this inspection for you!)
Language: All foreign documents must be accompanied by an original, certified English translation, which must include an Affidavit of Accuracy from the translator.
❌ Path B: The Vehicle IS (or might be) Grey Market
If the vehicle DOES NOT have a U.S. conformity label, it must be processed as a Grey Market vehicle.
This requires two key things:
Ownership Documents
All documents (foreign title, registration, bill of sale) must be in English.
If not in English, the customer must provide an original, certified English translation, which must include an Affidavit of Accuracy from the translator.
Required Vehicle Inspection
The type of inspection depends on the vehicle's age or the customer's status.
Level I Inspection is required for:(EZ Title & Registration can perform this inspection for you!)
Vehicles 25 years and older.
Foreign military (NATO) personnel.
Level II or III Inspection is required for:
All other Grey Market vehicles. This inspection must be completed by an ADOT officer to verify the vehicle's identity.
Note on Import Documents: While federal import documents (like Customs Form 7501 or DOT Form HS-7) are required to get the vehicle into* the U.S., ADOT does not require them to *title* the vehicle. However, they can be helpful to support the chain of ownership.
3. Special Cases
🇨🇦 Vehicles from Canada
A vehicle built for the Canadian market has a simpler process, if it meets these conditions:
It's a passenger vehicle, motorcycle, or SUV (under 10,000 lbs GVWR).
It is not for resale.
Required Documentation:
A letter from the manufacturer (not the dealer) verifying the vehicle complies with all U.S. FMVSS and EPA standards.
If the manufacturer's letter states the speedometer or headlights do not comply, the customer must provide documentation showing those parts were modified to meet U.S. standards.
🎖️ NATO (Foreign Military) Personnel
NATO personnel can get an Arizona Registration Only (ARO), but not a title.
Required Documentation:
Import Documents (Form OMB No. 2127-0002) with Box 12 marked, indicating the owner is foreign military.
Level I Inspection. (EZ Title & Registration can perform this inspection for you!)
