Are Kei Trucks Legal in New Mexico?
New Mexico's MVD procedures manual requires a U.S. Customs vehicle release and a NHTSA bond release letter before a vehicle built for sale outside the United States can be titled, and makes no provision for the 25-year federal exemption that imported kei trucks enter under.
The second type of foreign-manufactured vehicles are those manufactured outside of the United States, to be sold outside of the United States. These vehicles do not meet the federal standards. Upon importing foreign manufactured vehicles, owners must conform to safety and emission standards established by the USDOT and the EPA prior to applying for New Mexico Title and Registration. The applicant must provide a vehicle release from U.S. Customs and Border Protection (CBP), indicating the vehicle has met the following requirements: Vehicle meets Department of Transportation requirements per DOT HS-7 Declaration form. Vehicles must be held for at least 30 days from the import date and include a NHTSA Bond Release letter confirming the vehicle safety. Vehicle meets EPA standards. Vehicle meets U.S. Customs and Border Protection (CBP) requirements ... Do not process imported vehicle transactions without a Vehicle Release.
New Mexico has no mini-truck or kei vehicle category. We checked the Motor Vehicle Division's published Vehicle Procedures Manual, including Chapter 1 (Vehicles Definitions) and Chapter 18 (Other "Vehicles"), and found no definition of a mini-truck, no 660cc class and no reference to kei vehicles anywhere. So the question is not what a special rule says, but how the general rule for imported vehicles is applied.
That general rule is in Chapter 8, Section U. It splits foreign-manufactured vehicles into two kinds: those built abroad for sale in the United States, which conform to USDOT and EPA standards, and those built abroad for sale abroad, which "do not meet the federal standards." A Japanese kei truck is squarely in the second group. For that group, the manual requires a CBP vehicle release establishing four things, one of which is that the vehicle "must be held for at least 30 days from the import date and include a NHTSA Bond Release letter confirming the vehicle safety," and it instructs offices not to process imported vehicle transactions without that release.
Here is the problem, and it is the heart of why we are not giving New Mexico a confident status. A NHTSA bond release letter is produced by the Registered Importer process, in which a non-conforming vehicle is imported under bond and brought into FMVSS compliance. A kei truck 25 years or older is not imported that way: it enters under the age exemption, is declared on DOT form HS-7 under that exemption, and is never bonded, never conformed and never issued a bond release letter. Read literally, the MVD manual asks for a document that a lawfully imported 25-year-old kei truck does not and cannot have. Read more loosely, the same bullet list also asks only that the vehicle "meets Department of Transportation requirements per DOT HS-7 Declaration form," which an exempt vehicle does.
We could not establish which reading New Mexico MVD applies in practice. We found no MVD bulletin, rule or published statement addressing the 25-year FMVSS exemption, no New Mexico Attorney General opinion on kei vehicles, and no statutory kei or mini-truck provision in the Motor Vehicle Code. The manual section itself is dated 9 May 2018, before the 2021 wave of state-level kei activity, so it was not written with these vehicles in mind. Anyone planning to register a kei truck in New Mexico should get a written answer from MVD on the bond release point before transferring money, and should not treat either outcome as settled.
What you can do in New Mexico
Ownership and off-highway use are not in doubt. You can buy, import and keep a kei truck in New Mexico and use it on land you own or have permission to use. Nothing we found restricts that.
For road use, do the paperwork question first and the purchase second. Ask a New Mexico MVD field office, in writing, whether it will accept a DOT HS-7 declaration claiming the 25-year exemption in place of a NHTSA bond release letter for a vehicle manufactured for sale outside the United States, and keep the answer. Expect also to need your CBP vehicle release and entry documents (CBP Form 7501 is one of the two the manual names), a certified English translation of the Japanese ownership document, a VIN inspection and NCIC clearance. If MVD will not waive the bond release requirement, there is no route we could source, and no amount of inspection or insurance changes that.
How this fits the national picture
Importing a vehicle twenty-five years or older is a federal matter and is settled. Registering one for the road is decided state by state, which is why the answer changes when you cross a line on a map. Our state-by-state guide covers all fifty, including why states disagree and the AAMVA guidance most restrictions trace back to.
We are based in Goshen, New York, and New York is one of the states that will not register these for road use. We say so on our own state's page because it is true, not because it helps us. We will not tell you a kei truck is street legal in the USA.
Common questions
Are kei trucks legal in New Mexico?
New Mexico has no kei or mini-truck vehicle class, and we could not establish from any published state source whether an imported kei truck can be titled and registered for road use there. The MVD procedures manual requires a NHTSA bond release letter for vehicles manufactured for sale outside the United States, which a 25-year-exempt import does not receive.
Does New Mexico have a mini-truck category?
No. We reviewed the New Mexico MVD Vehicle Procedures Manual, including its vehicle definitions chapter and its chapter on other vehicles, and found no mini-truck definition, no 660cc class and no reference to kei vehicles.
What does New Mexico require to title an imported vehicle?
The MVD Vehicle Procedures Manual, Chapter 8 Section U, requires a vehicle release from U.S. Customs and Border Protection showing that the vehicle meets DOT requirements per the HS-7 declaration form, has been held at least 30 days from the import date with a NHTSA bond release letter, meets EPA standards and meets CBP requirements. It instructs offices not to process imported vehicle transactions without a vehicle release.
Why is a NHTSA bond release letter a problem for a kei truck?
A bond release letter is issued through the Registered Importer process, in which a non-conforming vehicle is imported under bond and brought into compliance with federal safety standards. A kei truck 25 years or older is imported under the federal age exemption instead, so it is never bonded or conformed and no bond release letter is issued for it.
Can I use a kei truck off-road in New Mexico?
Nothing we found in New Mexico's published motor vehicle materials restricts owning a kei truck or using one on private land with the landowner's permission. The uncertainty concerns titling and registration for use on public roads.
This page describes what we could establish from the source above on the date shown. It is not legal advice, and kei registration rules have moved in both directions every year since 2021 — confirm with the New Mexico registering authority before you buy. Payment for an imported vehicle is by bank transfer and is not reversible.