Recall Verification and Tracking for Registered Importers

By Michael Roessler, Founder of VIN2. Former RI satellite operator and author of three Registered Importer license applications.

Last updated: November 2026

Short answer: A Registered Importer must confirm that every vehicle it brings into conformity has no outstanding safety recalls before release. It must also notify owners if a safety defect or noncompliance is found later. Under the Safety Act, an RI takes on a manufacturer's recall obligations, but it has none of a manufacturer's systems. VIN2 gives RIs those systems.

What the law requires

NHTSA treats a Registered Importer as the party responsible for a nonconforming vehicle's compliance with the Federal Motor Vehicle Safety Standards (FMVSS). For recalls, that means two duties:

Before release: confirm that the vehicle has no open recalls, and document it in the conformity package submitted to NHTSA. An RI must make sure there are no outstanding recalls on the vehicles it brings into conformance.
After release: notify owners when a safety-related defect or noncompliance is later identified on vehicles the RI imported, and keep records showing it did so.

This sits on top of the other import obligations: the HS-7 declaration, a DOT conformance bond of 150% of the vehicle's declared value, and bringing the vehicle into conformity within 120 days of entry.

Why recall checks on imported vehicles are hard

The data is split across the border. Transport Canada's recall database covers only vehicles built for and originally sold in Canada, and US lookups are built around US-market VINs. A vehicle crossing the border can fall through the gap between the two.
Recall lists change. NHTSA publishes a quarterly list of vehicles that may be subject to recalls. A vehicle that was clear on import day can show up on it later.
Notification is permanent. An RI's duty to notify owners doesn't expire when the bond is released, and the records have to stand up to an audit years afterwards.
Manual processes don't scale. Spreadsheets, emailed OEM letters and screenshots break down once you're handling hundreds of VINs a month.
Nobody can automate the last step. Every major manufacturer's VIN-level recall lookup is a web form behind a bot wall. That is true for VIN2 and for every other platform. What can be fixed is that the manual check goes unrecorded.

How VIN2 handles recall compliance

VIN2 is neutral compliance software for Registered Importers. It is not an RI, a customs broker, a bond provider or a dealer.

Automated type-level triage. VIN2 runs NHTSA's bulk recall data once per distinct make, model and model year across your fleet, and reports which types carry open campaigns. This is the part a computer can do, and it runs without anyone asking.
A recorded per-VIN check. Triage produces a worklist, not a result. The per-VIN confirmation is done by a person on the manufacturer's own tool, and VIN2 captures it with coverage proof — evidence that the source recognised that specific vehicle. A model year with no campaigns is reported as not yet checked at VIN level, never as clear.
Substantiation inside the package. The triage result and the recorded per-VIN check travel with the conformity package, so NHTSA reviewers see complete substantiation the first time instead of a folder assembled from email.
Quarterly reconciliation. VIN2 matches NHTSA's quarterly may-be-recalled list against your full certified-vehicle history at make, model and model-year scope, and names the vehicles that need a fresh per-VIN check.
Owner-notification records. VIN2 identifies which owners need to be notified, prepares the notice, and keeps a permanent, defensible record. The RI sends the notice, as the law requires, so the RI stays in control and VIN2 does the heavy lifting.

Get a free recall exposure report

Send us your certified-vehicle list. VIN2 will run it against current NHTSA campaign data at make, model and model-year scope and show you which vehicles need a per-VIN check, at no cost.

Frequently asked questions

Does a Registered Importer have to check for recalls?

Yes. An RI must confirm that a vehicle has no outstanding safety recalls before it is released, and document it in the conformity package.

Do RIs have to notify owners about recalls after import?

Yes. RIs carry ongoing owner-notification responsibilities for safety defects and noncompliance found on vehicles they imported.

Can I rely on Transport Canada's recall database for a Canadian vehicle imported to the US?

Not on its own. It covers vehicles built for and originally sold in Canada, so you need VIN-level manufacturer data to see the full picture.

Can VIN2 check recalls for a specific VIN automatically?

No, and neither can anyone else. Every major manufacturer's VIN-level recall lookup is a web form behind a bot wall. VIN2 automates the make, model and model-year triage, then records the per-VIN check a person performs, with proof that the source recognised the vehicle.

Can VIN2 send recall notices for me?

No. The notice must come from the RI. VIN2 identifies the affected owners, prepares the notice and keeps the record.

Do vehicles 25 years or older need recall checks through an RI?

Vehicles at least 25 years old are exempt from FMVSS and don't need an RI, so the RI recall duties don't apply to them.