Title and registration for foreign (gray market) vehicles in Wisconsin

​A foreign vehicle is defined as being manufactured for use in another country and not intended for use in the U.S. or as a vehicle last titled in a foreign country. Federal law requires that the title and registration of foreign vehicles must show that they meet U.S. standards, by either a Federal Certificate Label (FCL) or Registered Importer label (RI).​

​Federal certification label (FCL)
manufactured to U.S. standards
​Registered Importer label (RI)
brought up to U.S. standards
  • ​Vehicles originally manufactured to U.S. standards will bear a manufacturer’s FCL stating that it conforms to Federal Motor Vehicle Safety Standards (FMVSS).
  • An automobile, light truck, low speed vehicle or motorcycle of model year 1970 or newer must have a manufacturer’s FCL certifying the vehicle was manufactured for U.S. on-road use.
  • ​Vehicles manufactured for use in a foreign country can be imported into the United States and brought up to U.S. standards with the placement of a RI label.
  • The RI label identifies the RI importer and their certification that the vehicle complies with all Federal Motor Vehicle Safety Standards (FMVSS) for that vehicle.

  • Vehicles with a FCL or RI label can be titled and registered in Wisconsin for any plate type.
  • Vehicles without either label can be titled in Wisconsin but will display “NON USA STANDARD” on the title.
  • Vehicle titles with this brand may only be registered as a special interest vehicle (collector license plates), as stated in Wisconsin statutes s.341.10(6).
  • Vehicles, model year 1970 and newer, can be registered with regular auto or light truck license plates only if they were originally manufactured to conform to all applicable U.S. federal motor vehicle safety standards in effect on the date of manufacture or were brought into conformity with the applicable standards by an importer registered with the National Highway Transportation Safety Administration (NHTSA), per statute (341.10(6)).

The National Highway Traffic and Safety Administration (NHTSA) and the Environmental Protection Agency (EPA) allows for vehicles to be imported into the country once the vehicle has reached a certain age. However, NHTSA and EPA are not responsible for regulating the operation of motor vehicles on public roads in the U.S. or for titling or registering motor vehicles for such operation: that is the responsibility of the individual states.

Federal regulations 49 CFR 567 cover the requirements and placement of Federal Certification and/or Registered Importer labels.