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2011-05-10-moving-to-us-letter-of-compliance.md (6503B)


      1 +++
      2 title = "Moving to the US: Importing a Canadian Vehicle"
      3 date = "2011-05-10T00:00:00Z"
      4 slug = "moving-to-us-letter-of-compliance"
      5 tags = ["Canada", "Howto", "USA"]
      6 +++
      7 
      8 A big difference between the last time I moved to the US and this time is that
      9 this time, I've got a lot more stuff. One of those things is a Nissan Rogue
     10 that's been quietly living its life in Canada. Faced with the prospect of
     11 selling the car and buying a new one, I chose instead to import the one I know
     12 and love.  Here is my story.  But be forewarned, it is not for the faint of
     13 heart.
     14 
     15 {{< figure src="/post/2011-05-10-futile.jpg"
     16     alt="Scrawny kid vs sumo wrestler" >}}
     17 
     18 To import a vehicle to the US from Canada, you need to undertake a series of
     19 quests. These are detailed on the [NHTSA website][nhtsa] under the heading
     20 *Vehicle Importation Guidelines (Canadian)*. As of May 2011, you need the
     21 following items in increasing order of difficulty:
     22 
     23 **[easy]** The following information about your car:
     24 
     25 1. VIN
     26 1. Make/Model/Year
     27 1. Month/Year of manufacture
     28 1. Registration & ownership information
     29 
     30 **[easy]** [EPA Form 3520-1][form_35201]. You will likely be importing your
     31 vehicle under *code EE: identical in all material respects to a US certified
     32 version*.
     33 
     34 **[easy]** [NHTSA Form HS-7][form_hs7]. You will most likely be importing your
     35 vehicle under box 2B, for vehicles that complied with Canadian CMVSA
     36 regulations at their time of manufacture and where the manufacturer attests
     37 that, with a few exceptions, it meets US regulations; see final item.
     38 
     39 **[medium]** A letter on the manufacturer's letterhead from the Canadian
     40 distributor, stating that there are no open recalls or service campaigns on the
     41 vehicle. I'm not sure if this is required, but Nissan Canada thought it would
     42 be.
     43 
     44 **[hard]** A letter from the vehicle’s original manufacturer, on
     45 the manufacturer’s letterhead identifying the vehicle by vehicle identification
     46 number (VIN) and stating that the vehicle conforms to all applicable FMVSS
     47 "except for the labeling requirements of Standards Nos. 101 *Controls and
     48 Displays* and 110 *Tire Selection and Rims* or 120 *Tire Selection and Rims for
     49 Motor Vehicles other than Passenger Cars*, and/or the specifications of
     50 Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*,
     51 relating to daytime running lamps."
     52 
     53 Items 1-3 are left as an exercise to the reader. I will focus here on items 4
     54 and 5 to save you the 14 hours of accumulated hold time and multiple phone
     55 calls. Prepare yourself friend, for here begins a journey of hurt and
     56 frustration, but you will prevail.
     57 
     58 Let's start with item 4. I gave [Nissan Canada][nissan_canada] a ring at
     59 1-800-387-0122 and managed to make it through the phone navigation system to a
     60 human operator. I told them I was importing a Canadian Nissan into the States
     61 and needed a *Letter of Compliance*. After a bit of digging, they stated that
     62 such letters are only provided by *Nissan North America,* but they would
     63 instead mail out two other letters on Nissan letterhead:
     64 
     65 1. A letter stating the VIN and that the vehicle has no pending recalls or
     66    service campaigns on it.
     67 1. In place of a *Certificate of Origin* (which Nissan Canada does not
     68    provide), a letter stating the VIN and that the vehicle was manufactured for
     69    sale in the Canadian market and complied with all safety and emission
     70    regulations at the time of manufacture.
     71 
     72 We're almost there, but your next and final mission is also the most
     73 challenging: the *Letter of Compliance*. Call [Nissan North
     74 America][nissan_usa] Consumer Affairs Department at 1-800-647-7261. Navigate
     75 through the phone system to an operator - get their name and extension. They
     76 may ask for your VIN only to find it's not in their system. Canadian VINs are
     77 not in their system. Some operators thought they were, others were sure they
     78 weren't. They're not. Many operators tried and failed to find it. Ask them to
     79 open a file, give them the vehicle information and your info and get the file
     80 number. Use this number whenever you call.
     81 
     82 Here are the five steps to success:
     83 
     84 1. Tell the operator that you're importing a Canadian Nissan vehicle to the US
     85    and that you need a *Letter of Compliance* stating the VIN and that the
     86    vehicle was built to conform to Canadian and United States EPA emissions
     87    standards and all US Federal motor vehicle standards except for daytime
     88    running light brightness. There is a very good chance they've never heard of
     89    this. Get them to talk to their supervisor, and their supervisor. Anyone.
     90    Someone will know.
     91 1. They will tell you that the vehicle needs to have its daytime running lights
     92    disabled before they will issue the letter of compliance. All the government
     93    rules seem to specifically exclude the daytime running lights, and the
     94    letter they issue even states that the vehicle doesn't meet that standard,
     95    but for whatever reason they want a copy of a work statement showing the
     96    work was done. Remember to get the operator's name and extension and the
     97    fax number for the work statement before you hang up.
     98 1. Get the daytime running lights disabled. It's a setting change in the
     99    on-board computer; your local dealer will do this in under 30 mins for \$50
    100    or so. 
    101 1. Fax your the work statement and put your name, return fax number and a
    102    request for the *Letter of Compliance* on the cover sheet. Phone Nissan
    103    North America Consumer Affairs back. The phone navigation system will give
    104    you hope that you can input an extension directly, only to find it only
    105    accepts 5-digit extensions but your rep has a 6-digit extension. You'll end
    106    up back in the queue. Ask whoever you get to put you through to your
    107    previous rep, by extension. When you get through, say that you sent the fax
    108    and request the letter. Ask them to phone you back when they've faxed it.
    109 1. You'll get the fax eventually - *check the information!* On my letter, the
    110    year, model and VIN were all incorrect, though they got my name right. If
    111    it's incorrect, try again.
    112 
    113 You now have everything you need to import your Nissan to the States. Good
    114 luck my friends, I don't envy you, but know that I am with you and that victory
    115 will someday be yours too.
    116 
    117 [nhtsa]: http://stnw.nhtsa.gov/cars/rules/import/
    118 [form_35201]: http://www.epa.gov/oms/imports/
    119 [form_hs7]: http://www.nhtsa.gov/cars/rules/import/
    120 [nissan_canada]: http://www.nissan.ca/common/footer/en/contact.html
    121 [nissan_usa]: http://www.nissanusa.com/apps/contactus