OT:RR:BSTC:CCR H345045 JLE
Martin W. Bloch
Dell Will Customs Brokers (USA), Inc.
25810 Northline Commerce Dr.
Taylor, MI 48180
RE: Requirements for Exportation of Used Self-Propelled Vehicles; Racing; 19 C.F.R. § 192.
Dear Mr. Bloch:
This is in response to your February 10, 2025, ruling request. In your request you inquire
whether proposed cross-border transportation of sports vehicles for a racing event would require
compliance with 19 C.F.R. § 192.
Facts
These facts have been supplied in your ruling request. On the weekend of June 13, 2025,
the National Association for Stock Car Auto Racing, LLC (“NASCAR”) has scheduled a race in
Mexico City, Mexico. Around 180 race teams will transport their cars and related equipment
using their own trucks from the United States to Mexico. You state the cars are U.S. owned but
not titled due to their status as off-road vehicles. After the race, the trucks, cars, and equipment
will return to the U.S. to participate in a U.S. race the following weekend.
You state that you intend to provide AES filings. Additionally, a broker in Mexico will
prepare the entries for Mexico and the Pre-Arrival Processing System for the return. You will
prepare Customs entry. The request asserts that you have previous Customs rulings that state the
vehicles, in some circumstances, are cleared under 9817.60.000 or they may move under ATA
carnets.
Issue
Whether the transportation of U.S.-owned race cars from the U.S. to Mexico for the
purpose of participating in a race event with the intent to return would require compliance with
19 C.F.R. § 192.
Law and Analysis
Title 19 C.F.R. § 192 pertains “to procedures for the lawful exportation of used
selfpropelled vehicles, vessels and aircraft, and the penalties and liabilities incurred for failure to
comply with any of the procedures.” 19 C.F.R. § 192.0. Export is defined as “the transportation
of merchandise out of the U.S. for the purpose of being entered into the commerce of a foreign
country.” 19 C.F.R. § 192.1.
According to your request, the purpose for transporting the vehicles out of the U.S. is to
use them in a race in a foreign country and then return them to the United States. There is no
indication that the purpose of transporting the vehicles out of the U.S. is to enter them into the
commerce of Mexico. Therefore, it is our position, under the above-mentioned circumstances, 19
C.F.R. § 192 is not applicable to the transportation of these vehicles out of the U.S.
Holding
In the present matter, the vehicles are not being transported out of the U.S. for the purpose
of entering them into the commerce of Mexico, therefore the provisions of 19 C.F.R. § 192 are
not applicable.
Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the
assumption that all of the information furnished in connection with the ruling request and
incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and
complete in every material respect. The application of a ruling letter by a Customs Service field
office to the transaction to which it is purported to relate is subject to the verification of the facts
incorporated in the ruling letter, a comparison of the transaction described therein to the actual
transaction, and the satisfaction of any conditions on which the ruling was based.” If the facts at
hand vary from the facts stipulated herein, this decision shall not be binding on CBP as provided
for in 19 C.F.R. § 177.2(b)(1), (2) and (4), and § 177.9(b)(1) and (4).
Sincerely yours,
W. Richmond Beevers. Chief
Cargo Security, Carriers, and Restricted
Merchandise Branch
Office of Trade, Regulations and
Rulings
U.S. Customs and Border Protection