Updated September 22, 2026
California registration is a separate consideration when importing a vehicle. Before buying a non-U.S.-market car, establish which emissions requirements apply to that particular vehicle. An overseas registration document, a U.S. customs clearance, and a California emissions approval serve different purposes.
Updated CARB certification link
The California Air Resources Board (CARB, also called ARB) now publishes California Certification Procedures for 1975 and Later Model-Year Used Modifier-Certified Motor Vehicles on its current website. This replaces the old ARB FAQ link. The document is also embedded below for reference.
The document was adopted in 1988. CARB still lists it in its on-road light-duty certification requirements under used direct-import vehicles. Its old adoption date does not, by itself, make it obsolete.
1967 and older vehicles: direct-import emissions exemption
1967 model year and older: These vehicles are exempt from the direct-import emissions modification and testing requirements discussed here.
CARB’s published FAQ, “How do I register a NON-USA or Grey Market car in California?”, states:
“1967 and older: no modifications and testing are required to register the vehicle in California.”
This refers to emissions modification and testing, not an exemption from customs clearance, proof of ownership, or other applicable DMV registration requirements. Current DMV direct-import guidance identifies 1968 and newer automobiles and commercial vehicles as the model years requiring CARB referral when they do not comply with U.S. emissions requirements.
What about 1968 through 1974 vehicles?
The title can be confusing. The document excludes 1974 and older light-duty vehicles from these particular procedures, but directs them to the federal import provisions as they existed on November 15, 1972. For 1968 through 1974 vehicles, that exclusion does not mean the vehicle is exempt from direct-import emissions requirements.
“The 1974 or older model year vehicles shall follow the provisions under "Importation of Motor Vehicles and Motor Vehicle Engines", Subpart P, Part 85, Title 40, Code of Federal Regulations as they existed on November 15, 1972.”
The date is part of the requirement. Reading today’s version of the CFR alone does not establish what the incorporated 1972 provisions required. CARB’s FAQ separately identifies 1967-and-older vehicles as requiring no modification or testing, and 1968–1974 vehicles as subject to the dated federal requirements.
Finding the federal provisions dated November 15, 1972
The 1972 annual CFR edition shows Subparts N–R as reserved. That annual edition alone does not establish the text in effect on the later date CARB specifies. The November 15, 1972 Federal Register publishes Subpart P, “Importation of Motor Vehicles and Motor Vehicle Engines,” at pages 24314–24315. The 1973 CFR edition likewise gives its source as 37 FR 24314, November 15, 1972.
EPA’s explanatory text on page 24250 describes a republication in a new format to clarify which provisions apply to particular model years. It identifies the only substantive change as extending a model-year definition to the 1973 and 1974 model years. The appearance of Subpart P in this publication should therefore not be described as proof that the import requirements first began on November 15, 1972.
Section 85.1501 expressly includes certain used vehicles within its definition of “new motor vehicles,” tying coverage to the effective date of the applicable emissions regulation, including regulations that would have applied had the vehicle been manufactured for import into the United States. Subpart P does not itself state a simple “1967 and older” cutoff. The explicit model-year statement highlighted above comes from CARB’s FAQ; tracing its complete federal regulatory basis requires the earlier applicable emissions provisions as well.
Smog Check exemption and import certification are separate
BAR lists gasoline vehicles from model year 1975 and earlier as exempt from Smog Check. That is a Smog Check exemption, not proof that a foreign-market vehicle has met California's separate direct-import requirements. A 1975 car illustrates why the distinction matters: it falls within the model years named in CARB's used-import procedures while also falling within BAR's Smog Check age exemption. See BAR's current Smog Check requirements.
Used direct-import certification
For covered vehicles, CARB's procedures describe modification, exhaust and evaporative emissions testing by a licensed laboratory, a Certificate of Conformance, and referee involvement. A routine Smog Check pass does not replace the required certification. Confirm the current testing and equipment requirements for the specific vehicle with the laboratory before starting work.
R32 GT-R undergoing California certification.
Why the wording matters
CARB certification procedures, CARB’s public FAQ, DMV registration instructions, and BAR Smog Check guidance serve different purposes. Similar terms should not be assumed to describe the same approval. A Certificate of Conformance for a used direct import, a federal EPA certificate of conformity, and a Smog Check certificate of compliance are distinct documents.
The FAQ also discusses OBD and other manufacturer-level requirements. That wording should be read in its direct-import certification context; it should not be treated as a universal exemption from every diagnostic or inspection requirement. Where documents use different wording, this article identifies the source rather than assuming that an omission or wording change establishes a new exemption or prohibition.
What does DMV require?
DMV's direct-import registration guidance addresses ownership and registration documents, evidence of legal importation and customs clearance, federal safety and emissions compliance, and a Smog Check when required. The applicable compliance or exemption documentation must match the vehicle.
Do not assume that the passenger-car conversion process is available for every vehicle type. DMV states that there are no CARB conversion programs for new vehicles less than two years old, motorcycles, off-highway vehicles, or diesel-powered vehicles.
Historical DMV reference: HTVR 9A, September 2015
DMV’s brochure Register a Vehicle Imported From Another Country (Direct Import), marked “HTVR 9A (NEW 9/2015),” separated the requirements on its cover under “You May Also Need”:
- U.S. safety standards: vehicles 24 years old and newer.
- U.S. emission standards: vehicles 20 years old and newer.
- California emission standards: 1966-and-newer gasoline-powered vehicles and 1980-and-newer diesel-powered vehicles, as stated in that historical brochure.
The brochure’s U.S. Safety section also listed a “certificate of conformity issued by a CARB-licensed laboratory” among acceptable evidence. Its emissions section used that same term and stated that a separate smog certification was not required for original registration when that document was submitted. These are descriptions of DMV’s published 2015 instructions, not assertions that a CARB emissions certificate independently establishes federal safety compliance.
Current DMV Section 12.050 does not repeat the brochure’s 24-year and 20-year qualifiers in its safety and EPA evidence bullets. It also expressly corrects references to 1966-and-newer automobiles and commercial vehicles to 1968-and-newer. The wording differs; the difference alone does not establish that an underlying law or exemption changed.
The 2015 brochure is useful historical documentation and should be read alongside the applicable federal import provisions, CARB certification procedures, and current registration instructions.
Does registration in another state create an exemption?
An out-of-state title alone does not establish the exemption in Health and Safety Code Section 44210. That provision requires a federal EPA certificate of conformity and specific prior-residency and registration circumstances, with evidence acceptable to DMV. It is not simply a rule that any imported car becomes exempt after a year on another state's plates.
Before purchasing or shipping a vehicle for California use, confirm its model year, original certification status, engine configuration, required testing, and registration documents. Get a vehicle-specific answer before committing to the car.
California certification procedures document
Read the document below, or open the Google Drive copy in a separate window. The official CARB text is also available.
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