Overview
If you are a Vehicle Connectivity System (VCS) hardware importer or a connected vehicle manufacturer, engaging in a transaction involving covered software in which there is a foreign interest or importation of VCS hardware, you must submit a Declaration of Conformity to the Bureau of Industry and Security’s Office of Information and Communications Technology and Services (OICTS) pursuant to 15 C.F.R. § 791.305.
Declarations of Conformity must be submitted as follows:
- VCS Hardware Importers: At least 60 days prior to importing VCS hardware, unless otherwise specified.
- Connected Vehicle Manufacturers: At least 60 days prior to importing or selling in the United States completed connected vehicles that incorporate covered software, unless otherwise specified.
Frequently Asked Questions (FAQs)
The Declaration of Conformity form will be made available for download on this subpage the day the Connected Vehicles Rule goes into effect, March 17, 2025.
Download and complete the fillable PDF Declaration of Conformity form below. Once completed, email the Declaration of Conformity form to: [email protected]. Please entitle the subject of your email: Declaration of Conformity Submission: Declarant Name.
Any form-related questions should be submitted to [email protected].
You will receive an automated confirmation email after emailing the Declaration of Conformity form to [email protected]. OICTS will only follow up directly if additional information is required.
While third-party assessments are not required, you are permitted to utilize assessments produced by third parties to assist with and prepare a Declaration of Conformity, in addition to ensuring ongoing compliance with the Connected Vehicles Rule, as long as such third parties conform to 15 C.F.R. § 791.315. If you do utilize a third-party assessment, you must indicate so in Section A of the Declaration of Conformity form.
Yes, as long as you have taken all possible measures, either contractually or otherwise, to ensure any necessary documentation and assessments from suppliers will be furnished to OICTS upon request either by you or directly by the supplier.
Any information or material submitted to OICTS which the declarant or any other party desires to submit in confidence as a part of a Declaration of Conformity should be contained within a file beginning its name with the characters “CBI.” Any page containing Confidential Business Information must be clearly marked “CONFIDENTIAL BUSINESS INFORMATION” on the top of the page. Any pages not containing Confidential Business Information should not be marked. By submitting information or material identified as Confidential Business Information, the declarant or other party represents that the information is exempted from public disclosure, either by the Freedom of Information Act (5 U.S.C. § 552 et seq.) or by another specific statutory exemption. Any request for Confidential Business Information treatment must be accompanied at the time of submission by a statement justifying non-disclosure and referring to the specific legal authority claimed.
If you discover an omission, inaccuracy, or error in the information provided to OICTS in a prior Declaration of Conformity that could reasonably mislead as to the true source of the VCS hardware or covered software in question (i.e., discovery of a material change), you will need to update the previously submitted Declaration of Conformity. You can do this by resubmitting the Declaration of Conformity in its entirety with the omission, inaccuracy, or error corrected within 60 days of the discovery of such change. In the updated Declaration of Conformity, you must indicate in Section B the date of the previous Declaration of Conformity that you are correcting, along with the description of the material change.
If you have determined that articles subject to a Declaration of Conformity are no longer eligible, you must, within 30 days, cease any prohibited conduct. If you wish to resume engaging in imports or sales of the relevant articles, you must submit a specific authorization application, pursuant to 15 C.F.R. § 791.307(m) and may only proceed if your application is granted. You can find the specific authorization application form on the Specific Authorizations page.
Connected vehicle manufacturers and VCS hardware importers shall submit Declarations of Conformity prior to the first sale of the subject connected vehicle in the United States, prior to the import of VCS hardware, and following discovery of a material change that makes a prior Declaration of Conformity no longer accurate, according to the timelines below.
Connected vehicle manufacturers shall submit a Declaration of Conformity at least 60 days prior to the first import or first sale of each model year of completed connected vehicle that incorporates covered software. Connected vehicle manufacturers may submit a single Declaration of Conformity for all connected vehicles incorporating covered software, grouped by make, model, and Vehicle Identification Number (VIN) series.
VCS hardware importers shall submit a Declaration of Conformity at least 60 days prior to the first import of VCS hardware for each model year for units associated with a vehicle model year, or calendar year for units not associated with a vehicle model year. VCS hardware importers may submit a single Declaration of Conformity detailing all VCS hardware models that will be imported in the model year or calendar year.
Connected vehicle manufacturers and VCS hardware importers must notify OICTS of any material change to the information conveyed in a previously submitted Declaration of Conformity by submitting a revised Declaration of Conformity in its entirety within 60 days following the discovery of such change. Your obligation to inform OICTS of material changes to the information in a Declaration of Conformity ceases 10 years after submission of the original Declaration of Conformity for that model year or calendar year.
OICTS expects to make the Declaration of Conformity form available on this subpage the day the Connected Vehicles Rule goes into effect, March 17, 2025. After this time, OICTS will accept Declarations of Conformity on a rolling-basis. However, due to the separate implementation timelines for the covered software and VCS hardware prohibitions, OICTS will initially prioritize processing Declarations of Conformity for covered software transactions.
As of 2025, OICTS recommends you prioritize the submission of Declarations of Conformity for covered software transactions due to the separate implementation timelines for the covered software and VCS hardware prohibitions.
Connected vehicle manufacturers and VCS hardware importers, in lieu of submitting a new Declaration of Conformity, may, if applicable, submit a confirmation that the previously submitted Declaration of Conformity remains accurate and that associates the relevant new model year vehicles or VCS hardware units to the existing Declaration of Conformity. You can fill out this information in Section B of the Declaration of Conformity form and proceed to Section F to input a signature. No other areas of the form need to be filled out.
Connected vehicle manufacturers and VCS hardware importers, in lieu of submitting a new Declaration of Conformity, may, if applicable, submit a confirmation that the previously submitted Declaration of Conformity remains accurate and that associates the relevant new model year vehicles to an existing Declaration of Conformity. This means that all information in a new Declaration of Conformity would be identical to a previously submitted Declaration of Conformity, apart from the model year information. If there is information beyond the model year that has changed, then you will need to submit a new Declaration of Conformity in its entirety.
No, a Declaration of Conformity is not required when the only foreign interest arises from a foreign person’s non-controlling ownership of equity.