Cargo Systems Messaging Service

CSMS #49161237 - Headquarters Ruling HQ H318727 – Pursuant to 19 CFR 192 - Used Vehicle requirements for United States to Puerto Rico or Puerto Rico to United States

Pursuant to CBP Ruling HQ H318727 dated July 21, 2021, it has been determined that the shipment of used self-propelled vehicles from the continental United States to Puerto Rico does not constitute an “export” as contemplated in 19 CFR 192.2. Puerto Rico is an unincorporated territory of the United States and 19 CFR 101 defines the “Customs Territory of the United States” to “include the only the states, District of Columbia, and Puerto Rico”. As a result 19 CFR 192 does not apply to the shipment of used vehicles from the United States to Puerto Rico. Although HQ H318727 does exclude the requirements of 19 CFR 192 it does not exclude the requirements of 15 CFR 30. Electronic Export Information (EEI) will still be required for vehicles with a value above $2,500.00. Vehicles with values $2,500.00 or less will not require EEI submission.

When the Electronic Export Information (EEI) is required, the exporter must submit the Title Number, Vehicle Identification Number (VIN) or Product Identification Number (PIN) and a valid Title State Code for the used vehicles being exported from the U.S. The EEI submitted in the Automated Commercial Environment (ACE) will not accept the EEI if these data elements are not present when the Harmonized Schedule Number specifically references a used vehicle. Until CBP can disable the validations for used vehicle exports from U.S. to Puerto Rico the following guidance is being issued.

• CBP will cease and desist enforcing the requirements of 19 CFR 192 for used vehicles shipped from United States to Puerto Rico or from Puerto Rico to United States

• Exporters will continue to enter the true Vehicle Identification Number (VIN) for each vehicle

• Exporters will enter as the Title State Code where the vehicle was exported from to Puerto Rico. Ex. If vehicle was exported from Miami the state for the title will be FL (Florida)

• In lieu of the title number when unavailable at the time of filing, exporters will be allowed to enter the Title State Code followed by 12345. Ex. FL12345 for used vehicles going to Puerto Rico.

• If alerted CBP Officers will continue to interdict for the export of stolen vehicles. Stolen vehicles are not exempt from being inspected.

• For exports covered by HQ H318727. Exporters will not be required to update the EEI when and if the correct information becomes available

• This ruling does not change exports to the US Virgin Islands

If you have any questions, please contact David Garcia Program Manager or Brian Semeraro Branch Chief, Outbound Enforcement and Policy via email at cbpvehicleexports@cbp.dhs.gov.