Certain Filings Not Required for Used Car Exports to Puerto Rico, CBP Says

Exporters of certain used vehicles from the U.S. to Puerto Rico don’t have to electronically file or provide the vehicle’s certificate of title prior to the shipment, CBP said in a July 21 ruling that was released Sept. 24. The agency ruled that shipments of used, self-propelled vehicles from the continental U.S. to Puerto Rico don’t constitute an export under U.S. regulations because the regulations define “export” as the “transportation of merchandise out of the U.S. for the purpose of being entered into the commerce of a foreign country,” CBP said in the ruling. “It is clear, however, that Puerto Rico is not a foreign country, as it is an unincorporated territory of the United States.”

The ruling stemmed from a determination request from a company that transports used vehicles between the U.S. and Puerto Rico. The company, which isn’t named in the ruling, buys most of its used vehicles at auction and usually isn’t “provided with a vehicle title at the time of purchase,” CBP said. The title is instead issued by the state in which the auction occurs, and it sometimes takes more than a month after the sale for the title to be issued, the company told CBP. The company said it doesn't “have the title for every used vehicle by the time the subject transportations occur.”