Roll-on/Roll-off (Ro-Ro) imports—whether complete vessels, vehicles, or rolling equipment—have unique customs procedures and requirements. From EPA emissions compliance to Coast Guard documentation, DOT safety standards to CBP entry procedures, Ro-Ro imports demand specialized knowledge to manage correctly.
This guide covers the customs aspects of importing Ro-Ro cargo and vessels, building on the vessel import foundation in our Vessel Import Documentation Checklist and the equipment procedures in our Maritime Customs Documentation guide.
Types of Ro-Ro Imports
Understanding the different categories of Ro-Ro imports:
Ro-Ro Vessels: The vessels themselves that carry roll-on/roll-off cargo, including car carriers, truck carriers, and multi-purpose Ro-Ro ships. These are subject to vessel import requirements, including Coast Guard documentation, with special considerations for entry and operation.
Vehicles and Cars: Personal and commercial vehicles imported via Ro-Ro. These are subject to EPA, DOT, and CBP requirements, with different rules applying to personal imports versus commercial shipments, including conformity and exemption procedures.
Heavy Equipment: Construction and industrial equipment that rolls on and off vessels, such as tractors, excavators, cranes, and specialized machinery. These may receive different regulatory treatment than highway vehicles and raise weight and dimension considerations.
Trailers and Rolling Stock: Cargo trailers, chassis, and similar rolling equipment. These may be cargo on a Ro-Ro vessel or Ro-Ro-capable equipment themselves, with specific registration and identification requirements.
Each category carries requirements beyond standard customs clearance.
EPA Requirements for Vehicles
Environmental Protection Agency compliance is critical:
Emissions Standards: All motor vehicles must meet EPA emissions standards, which vary by vehicle type and model year. Nonconforming vehicles generally cannot be imported permanently and may require testing or certification.
EPA Form 3520-1: Required for all motor vehicle imports. This form declares emissions conformity status and must be filed with the customs entry, using different codes depending on the situation.
Conforming Vehicles: Vehicles manufactured to U.S. specifications carry an EPA emissions label and can be imported using standard declarations, typically reported under Code “A” on Form 3520-1.
Nonconforming Vehicles: Vehicles that do not meet U.S. standards must be modified by an EPA-registered importer, imported temporarily for specific purposes, or exported. Each option involves additional cost and complexity.
Exemptions: Vehicles 21 years or older are exempt from EPA requirements. Racing vehicles, display or exhibition vehicles, and certain temporary imports may also qualify for exemptions with proper documentation.
DOT Safety Requirements
Department of Transportation safety compliance:
Federal Motor Vehicle Safety Standards (FMVSS): All motor vehicles must comply with FMVSS, covering safety equipment, crashworthiness, and related requirements. Compliant vehicles bear a certification label.
HS-7 Declaration: DOT Form HS-7 is required for all motor vehicle imports and must be filed with the customs entry, indicating the applicable compliance category.
Compliant Vehicles: Vehicles manufactured to U.S. safety standards carry FMVSS labels and follow a straightforward import process using standard HS-7 declarations.
Noncompliant Vehicles: Vehicles not meeting FMVSS must be imported through a DOT-registered importer for modification and testing, or otherwise exported or destroyed. This process adds time and expense.
Exemptions: Vehicles 25 years or older are exempt from FMVSS. Certain equipment not classified as motor vehicles and some temporary imports may also be exempt.
CBP Entry Procedures
Customs entry requirements for Ro-Ro cargo:
Standard Entry: Ro-Ro cargo follows standard merchandise entry procedures, including commercial invoice, packing list, bill of lading, CBP Form 7501, and proper tariff classification.
Vehicle Identification: VIN information is required and must match all documentation, including year, make, model, and engine specifications for EPA compliance.
Valuation: Transaction value is typically used. All dutiable costs must be included. Related-party transactions and used vehicles require additional scrutiny and documentation.
Duty Rates: Most passenger vehicles are subject to 2.5 percent duty, while trucks may be subject to 25 percent duty. Equipment duty rates vary by classification. Classification guidance is covered in our Tariff Classification article.
Coordination: EPA and DOT filings must align with CBP entry procedures. All agencies must clear the shipment before release, making coordination and timing essential.
Importing Ro-Ro Vessels
When importing the vessel itself:
Vessel Documentation: Coast Guard documentation requirements apply, as outlined in our Vessel Import Documentation article. Classification society certificates and marine surveys may be required, as discussed in our Marine Survey article.
Vessel Entry: CBP Form 3171 is required for vessel entrance. Crew and ship’s stores documentation must be submitted, along with cargo declarations where applicable.
Special Considerations: Ro-Ro vessels are large and complex assets, often subject to multiple regulatory requirements. Coordination is required when cargo remains onboard at import.
Jones Act: Vessels intended for coastwise trade must meet Jones Act requirements for build, ownership, flag, and crew. Most imported Ro-Ro vessels do not qualify. See our Jones Act Compliance guide for details.
Used Vehicle Imports
Special considerations for used vehicles:
Valuation Challenges: Used vehicles require careful valuation support, as condition and mileage vary. Appraisals or surveys may be appropriate.
Condition Documentation: Photographs, inspection reports, and odometer verification help support declared value and condition.
Odometer Requirements: Federal odometer disclosure rules apply. Accurate mileage reporting is required, and documentation must be retained.
Title and Ownership: Clear title is required, including foreign registration documents and proof of ownership transfer. Any liens must be released.
These requirements mirror the documentation attention required for used vessel imports discussed in our Vessel Import Documentation article.
Personal Vehicle Imports
Individuals importing personal vehicles:
Returning Residents: U.S. residents returning with personal vehicles may qualify for exemptions, subject to documentation of foreign residence and use.
Gifts and Inheritance: Vehicles received as gifts or through inheritance may qualify for duty exemptions with proper documentation.
Diplomats and Military: Certain diplomatic and military personnel qualify for special exemptions with documentation of status.
Nonresident Imports: Nonresidents may temporarily import vehicles under tourist or business provisions, subject to time limits and re-export requirements.
EPA and DOT requirements still apply unless an exemption is available.
Commercial Fleet Imports
Importing multiple vehicles commercially:
Fleet Entry: Multiple vehicles may be entered on a single entry, though individual documentation is still required for each unit.
Importer of Record: The commercial importer assumes compliance responsibilities, including bonding and recordkeeping.
Conformity Programs: Registered importers may handle nonconforming vehicles in volume, coordinating modifications, testing, and certification.
Distribution: Vehicles must clear customs and regulatory requirements before domestic distribution, including state-level title and registration rules.
Heavy Equipment via Ro-Ro
Non-highway equipment imported on Ro-Ro vessels:
Equipment Categories: Construction, agricultural, and industrial equipment such as excavators, loaders, tractors, forklifts, and cranes.
Classification: These items typically fall under Chapter 84 rather than vehicle classifications. Duty rates vary, making classification analysis essential.
Entry Procedures: Standard merchandise entry applies. EPA Form 3520-1 and DOT HS-7 are generally not required, though engine regulations may still apply.
Valuation and Documentation: Commercial invoices, equipment specifications, and country of origin documentation are required.
Temporary Imports
Vehicles entering the U.S. temporarily:
TIB for Vehicles: Temporary Importation under Bond may be used for testing, demonstration, or short-term use, with export required within prescribed timelines. See our TIB article for details.
Carnet Entry: ATA Carnets may be used for certain temporary vehicle imports, offering a streamlined process under an international guarantee system.
Tourist Vehicles: Nonresident tourists may temporarily bring vehicles without duty, subject to time limits and mandatory export.
Show and Display: Vehicles imported for exhibitions or shows may qualify for specific exemptions with use and time restrictions.
Common Ro-Ro Import Problems
Issues that frequently cause complications:
EPA and DOT Rejections: Vehicles that do not meet U.S. standards may require modification, export, or destruction, resulting in high cost and delay.
Documentation Gaps: Missing VIN records, incomplete title chains, or insufficient value documentation can delay clearance.
Classification Errors: Misclassification of vehicles versus equipment affects duty rates and regulatory treatment.
Timing Issues: Delays in EPA or DOT approvals and poor inter-agency coordination can lead to storage and demurrage costs.
Advance research, complete documentation, and experienced support reduce these risks.
Working with Specialists
Professional assistance for Ro-Ro imports:
Customs Brokers: Handle entry filing, classification, valuation, and coordination with EPA, DOT, and other agencies.
Registered Importers: Manage compliance and modification for nonconforming vehicles, including certification and testing.
Vehicle Inspectors: Conduct pre-import inspections, document condition, and identify compliance issues before shipment.
Selection Criteria: Choose partners with Ro-Ro experience, regulatory knowledge, and strong coordination capabilities. As discussed in our How to Choose a Customs Broker article, specialization matters.
Conclusion
Ro-Ro imports—covering vehicles, vessels, and rolling equipment—require navigation of multiple regulatory regimes beyond basic customs clearance. Successful imports depend on EPA and DOT compliance for vehicles, accurate CBP entry procedures, proper classification and valuation, coordinated multi-agency approvals, and complete documentation.
Complexity increases for nonconforming vehicles and commercial fleet imports, making early planning and experienced guidance essential.
Ro-Ro shipping offers efficient transport for vehicles and rolling equipment, but only disciplined compliance management ensures smooth entry and regulatory clearance.
TLR Projects, Marine & Offshore assists with Ro-Ro customs clearance by coordinating CBP entry with EPA, DOT, Coast Guard, and other regulatory requirements to support compliant, efficient processing of vehicle and equipment imports. Contact us to discuss your Ro-Ro import needs.
About TLR Projects, Marine & Offshore
TLR Projects, Marine & Offshore specializes in customs brokerage, freight forwarding, and turnkey logistics solutions for the maritime and offshore industries. With deep expertise in vessel operations, shipyard services, and offshore compliance, we provide the specialized support that maritime companies require. Contact us to learn how we can support your operations.
