Titling - Gray Market or Overseas Vehicle

​A gray market vehicle, also known as an overseas vehicle, is a vehicle whose owner has brought it into the United States from another country and wishes to have it titled and registered here. A gray market vehicle may or may not have been produced overseas, the distinguishing feature is that it has never been titled in the United States. Please see Appendix A (Titling Import/Gray Market Vehicles) which list the items needed to title a vehicle coming into the United States from overseas.

Before the vehicle can be titled in Maryland it must meet the safety, pollution control and other specifications imposed by three different federal agencies: U.S. Department of Transportation (U.S. DOT); U.S. Customs & Border Protection (US Customs), and U.S. Environmental Protection Agency (EPA). A vehicle that does not meet these specifications is referred to as "non-conforming." The owner of a non-conforming vehicle must have it modified so that it becomes a "conforming" vehicle, before applying to the MVA. The vehicle must be titled within 60 days of entry into the United States.

If the vehicle was previously titled in the United States, see New to Maryland - Titling and Registering Your Vehicle.

How do I title a gray market vehicle?

You can apply for a title and registration in person at any of the MVA's full service branch offices. You can also mail the documents to the MVA's Mail-in Title Unit in the Glen Burnie office, or go to an MVA licensed tag and title service where they will assist you in applying.

Typically, the title application documents needed (along with payment for taxes and fees) include:

  • Proof of ownership - This can be the vehicle's certificate of origin and/or your foreign or military registration documents. If you submit foreign registration documents you must have them translated into English through the embassy located in the country where the vehicle is registered or by the embassy located in Washington DC. The embassy seal must accompany the translation.
  • Application for Certificate of Title - Be sure to include your insurance information. Your policy must conform to Maryland's minimum liability insurance requirements.
  • Verification that the vehicle meets U.S. specifications -
    • US DOT Declaration - Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety Bumper and Theft Prevention Standards (US DOT form #HS-7) - either box 1 or 2A must be checked, verifying the vehicle meets U.S. specifications. Additional documentation is required if box 2B or 3 is checked. If any other box is checked, additional requirements will be listed on the EPA form #3520.
    • US EPA Importation of Motor Vehicles and Motor Vehicle Engines Subject to Federal Air Pollution Regulations (EPA form #3520) - all information must match the information that appears on the US DOT form #HS-7.
    • US Customs Entry/Immediate Delivery form - (U.S. Customs form 3461) the form must have the authorized stamp of the U.S. Customs.
  • Maryland Safety Inspection Certificate - This is a Maryland State Police form certifying that your vehicle meets Maryland safety standards. The inspection is valid for only 90 days from the date issued. This form is not required if the vehicle is new, meets all US specifications, and has never been registered.

Under certain circumstances, additional information may be required:

  • Bill of Sale - must be presented, if available, in order to determine your excise tax. This should be a bill of sale signed by both the buyer(s) and seller(s). The bill of sale must be notarized if the following conditions apply:
    • the vehicle is less than 7 years old; and
    • the purchase price is at least $500 below the book value; and
    • the new owner (buyer) wants to base the excise tax calculation (6% of the vehicle's value) on the sale price rather than the book value.
  • U.S. Environmental Protection Agency Letter Approving Release of the EPA Obligation on the Bond for the Vehicle (non-conforming vehicles only) - must be submitted when box 3 is checked on the US DOT Declaration (USDOT form #HS-7).
  • U.S. DOT National Highway Receipt of a Certificate of Compliance and Payment on the Bond for the Vehicle (non-conforming vehicles only).
  • Manufacturer's letter - must be presented if box 2B is checked on the US DOT Declaration (US DOT form #HS-7). The letter constitutes the manufacturer's certification that the vehicle meets all U.S. specifications.
  • Lien information - if you borrowed money to buy the vehicle, you may need to record your lien information on the Application for Certificate of Title. The MVA form titled Security Interest Filing must be used if a second lien is placed against the title. Make sure that your lien is transferable to the U.S.
  • Power of attorney - if someone other than you, the owner, is signing the titling forms, this document is required.
  • Certification for Multipurpose Passenger Vehicle - If you want your vehicle to be titled as a multi-purpose vehicle, a class "M" vehicle, but it is not on the list of recognized multi-purpose vehicles (most SUVs are on the list), you must submit the MVA certification form.

Note: If you also intend to register the vehicle additional forms are usually needed. Registration requirements vary greatly by the type and intended use of the vehicle. The requirements for most vehicles can be found in Registration - Common Vehicle.  If your vehicle is unusual, access the infoMVA homepage to find the applicable registration description.

Your title will be mailed to you regardless of whether you apply though a tag and title service, mail in your request or go directly to the MVA.

What can I do if my vehicle does not meet United States specifications?

You have two options. You can either ship your vehicle back overseas, or have your vehicle converted to meet United States specifications, if a conversion is possible. You must contact a company that performs conversions on gray market vehicles.

You cannot sell a gray market vehicle that does not meet United States specifications. Only a Registered Importer may import vehicles for resale. If you would like to bring vehicles into the U.S. for resale you must become a Registered Importer (RI). The responsibilities of an RI are defined in Title 49, Code of Federal Regulations Part 592, "Registered Importers of Vehicles Not Originally Manufactured to Conform to the Federal Motor Vehicle Safety Standards."

I purchased a vehicle overseas and want to give it as a gift to an immediate family member. Do Maryland's gift laws apply?

No, vehicles imported from overseas that have never been titled in the United States are not subject to the Maryland gift laws.


The Real ID Act requires that all Personal Identifying Information (PII) must be placed on the actual Driver License, Identification Card or Permit.  Therefore any name changes must be done through the Driver License System (DLS) prior to document changes.

Note: On July 1, 2015 all businesses wishing to title a vehicle will be required to show proof of the legal existence of the business.  The business will be given a number with a "Z" to identify it.


Contact Information:

Mail-In Unit

6601 Ritchie Highway, N.E.
Glen Burnie, MD 21062

MVA Customer Service Center:      1-410-768-7000
TTY/Hearing Impaired:                    1-301-729-4563

US Customs
Customs Inspectors - Vehicles
General Information: 410-962-2666 or Vehicle Imports/Exports: 410-288-3183

US Department of Transportation
Director Office of Vehicle Safety Compliance
National Highway Traffic Safety Administration
400 7th Street SW
Washington DC 20590
Phone: 202-366-5291
email: importandcertification@dot.gov

Environmental Protection Agency
Investigation/Imports Section
Manufacturer's Operations Division (6405-J)
401 M Street SW
Washington DC 20460
Phone: 202-564-9660

If you do not have the documents needed to complete the change of name through the DLS, the title transaction may be completed using your current name as it appears on your State issued identification. Maryland Vehicle Law requires the customer to apply for a corrected title within 30 days of a name change by completing the Application for Corrected Title Due to a Name Change form (VR-448). The fee is $50.00 for a corrected title.


​Titling Import/Gray Market Vehicles

The following items are needed to title a vehicle coming into the U. S. from overseas:

___ Foreign or Military registration /title or certificate of origin

___ Lien release (if applicable)

___ Maryland Safety Inspection (if applicable)

___ Proof of Maryland Insurance

___ Bill of Sale (notarized if non-dealer sale of vehicle less than 7 years old)

___ Application for Certificate of Title (Form VR-005​)

___ *U. S. Department of Transportation Declaration( Form HS-7) (Additional documentation may be required)

___ *U. S. Environmental Protection Agency ( Entry form 3520-1)

___ * U. S. Customs Entry Document (form 3461) (with delivery authorized stamp or electronic stamp)

____ *U.S. Customs Entry Summary (form 7501)

* These documents can be obtained from the broker/shipping company.  In the event there is no shipping company used, documents can be obtained directly from the U. S. Customs.

U. S. Customs

Port of Baltimore: (410)-865-2020

DOT Phone Number: (202) 366-5313

EPA Import Help Line: (734) 214-4100

International Auto Logistics: (410) 551-1239

National Highway Traffic Safety Administration: Import and Certification Division, Phone Number: (202) 366-5291

Email: importandcertification@dot.gov

For Active Military or Military Civilian Personnel assistance: (410) 631-5751

If further assistance is needed, you can contact the customer service center at 1-410-768-7000.


October 15, 2014

To Whom It May Concern:

Following this cover letter please find the following forms:

Customs and Border Protection Form 3461, Entry/Immediate Delivery

Customs and Border Protection Form 7501, Entry Summary

DOT HS-7 Form

EPA 3520-1 Form

These forms are to be used for the registration of this vehicle with the service member's state

Department of Motor Vehicles. The vehicle has been properly imported into the United States by a

returning U.S. Service Member and was transported under contract with the U.S. Transportation


In the lower right hand corner of the CBP 3461 Form you will find the Electronic Stamp from U.S. Custom

Border Protection (U.S. CBP). This shows that the vehicle was legally imported into the United States

and has been released by U.S. CBP for legal entry into the United States. This electronic stamp verifies

all information on the vehicle that Is to be found on the following forms. The stamp notes that the

vehicle has been Electronically Released in the port of entry and the proper release for the cargo was

received from U.S. Customs, The stamp also shows the release date of the vehicle.

This stamp is sufficient and accepted as the method to show proper release of a vehicle being registered

and no other stamps are necessary from U.S. CBP on the 3461 Form or any forms that follow it. The

vehicle can be legally registered in the United States with this proof of release along with the

Information found on these forms.

For reference of the validity of the release of cargo being properly noted on the CBP 3461 Form please

see Chapter 19 of the Code of Federal Regulations 142,3,142.16,142.22 and 142.24.

Doug Tipton/


International Auto Logistics,