What happens if my kei truck is 23 years old?

It cannot be registered for road use in Michigan. The 25-year threshold is stated plainly in the Secretary of State's guidance and there is no exception for equipment upgrades or inspections. You would be able to title it as an off-road vehicle only, and would need to wait until it crosses 25 years for on-road eligibility.

I read that Michigan classifies these as off-road vehicles. Is that right?

That was Michigan's position before late 2024, and it is now out of date. The Department of State reversed the ORV-only classification and began issuing on-road titles. A great deal of secondary material still describes the old policy, which is why it is worth going to the Secretary of State's own guidance.

Are there speed or road restrictions?

Michigan does not attach a posted-speed cap or road-class restriction to kei vehicles the way states with a dedicated mini-truck class often do. A qualifying kei truck is titled and registered as an ordinary vehicle. Be sceptical of claims about a federal rule barring kei trucks from highways — there is no such federal restriction, and that claim circulates widely without support.

What documentation do I need?

Import documentation is required if the vehicle has not previously been titled in the U.S. In practice that means your CBP Form 7501, HS-7 with box 1 checked, EPA Form 3520-1, and the Japanese export certificate with a certified translation. If the vehicle already carries a U.S. title, confirm it is an on-road title rather than an ORV title.

What about MCL 257.217i and 'gray market off-road minitruck'?

That provision excludes minitrucks from Michigan's assembled-vehicle titling pathway — the route used for kit cars, rebuilt vehicles, and off-road vehicles being converted to road use. It does not prohibit titling a kei truck generally. An imported kei truck is titled through the ordinary foreign-vehicle provisions instead, which is what the Secretary of State's kei guidance describes.

Do I need a special inspection?

Michigan does not operate a general periodic safety inspection programme the way some states do. Confirm current requirements for an imported vehicle with the Secretary of State when you book your appointment, since requirements for first-time titling of a foreign vehicle differ from ordinary transfers.

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Michigan · Kei truck guide

Michigan kei truck registration guide

On-road titles for vehicles 25 years and older

Michigan titles and registers kei trucks for on-road use, provided the vehicle is at least 25 years old. The Secretary of State states directly that kei-class vehicles, including mini-trucks and microvans 25 years old and older, can be titled and registered for on-road use — while mini-trucks and microvans under 25 years old are not eligible and can only be titled as off-road vehicles.

Bottom line for Michigan

The Secretary of State publishes an explicit answer: kei-class vehicles 25 years and older are eligible for on-road titling and registration.
The 25-year line is a hard cutoff. Under 25 years, the vehicle can only be titled as an off-road vehicle.
Import documentation is required if the vehicle has not previously been titled in the U.S.
Michigan reversed an earlier off-road-only classification in late 2024, so older guidance describing Michigan as ORV-only is out of date.
There is no posted-speed or road-class cap attached to the class — a qualifying kei truck registers as an ordinary vehicle.

Last reviewed July 20, 2026

Classification

How Michigan classifies a kei truck

Michigan's position is unusually clearly stated for this area of law. The Secretary of State's published guidance on titles answers the question directly: kei-class vehicles, including mini-trucks and microvans 25 years old and older, are exempt from federal regulations and can be titled and registered for on-road use if they were manufactured for on-road use in the U.S. or in another country. Import documentation is required where the vehicle has not previously been titled in the U.S.

The corollary is stated just as plainly. Mini-trucks and microvans less than 25 years old are not eligible for titling or registering on-road, and can only be titled as off-road vehicles. A kei truck built for the Japanese domestic market was manufactured for on-road use in another country, which is the condition the guidance turns on — but the age threshold is absolute.

This reflects a policy reversal. Michigan previously classified mini-trucks and kei vehicles as off-road vehicles and issued ORV titles accordingly. The Department of State changed that position in late 2024 and began issuing on-road titles. Guidance written before that change, including a good deal of what circulates online, describes the old position.

Registration

Titling & registration steps

1
Confirm the vehicle is at least 25 years old
This is the threshold question in Michigan and there is no discretion in it. A vehicle under 25 years old cannot be titled for on-road use no matter how it is equipped.
2
Clear federal import
Import the vehicle and retain CBP Form 7501, NHTSA Form HS-7 (Box 1), EPA Form 3520-1, and the Japanese export certificate with certified translation.
3
Assemble import documentation
The Secretary of State requires import documentation where the vehicle has not previously been titled in the U.S. If you are buying a kei truck that already carries a U.S. title, that requirement does not apply — but verify the existing title is an on-road title, not an ORV title.
4
Obtain Michigan no-fault insurance
Michigan requires no-fault insurance before a vehicle can be registered. Arrange coverage before your appointment.
5
Apply at a Secretary of State branch office
Bring your documentation to a branch office. Initial titling of an imported vehicle is an in-person transaction. Bringing a printout of the Secretary of State's own kei-class guidance is worth doing if you encounter uncertainty at the counter.

If you already own one

Owners holding an older ORV title

Michigan's 2024 reversal affected vehicles that had already been forced onto off-road titles:

The Department of State moved affected owners from ORV titles to on-road titles following the policy change, and issued instructions for returning previously issued ORV titles.
If you hold an ORV title issued under the old classification for a vehicle that is now 25 years or older, contact the Secretary of State about converting it rather than assuming it converts automatically.
Verify which kind of title you actually hold before buying a kei truck already titled in Michigan — an ORV title does not give you road use.

A statutory footnote

The 'gray market off-road minitruck' exclusion

Michigan's vehicle code mentions minitrucks in exactly one place, and it is worth understanding so it does not alarm you. MCL 257.217i creates a titling pathway for 'assembled vehicles' — vehicles built from parts, kit cars, heavily modified vehicles, and off-road vehicles being brought onto the road. Subsection (5) excludes certain things from that pathway, including a gray market off-road minitruck.

That exclusion says a minitruck cannot be titled through the assembled-vehicle route. It does not say a minitruck cannot be titled. An imported kei truck at least 25 years old is titled as a foreign vehicle through the ordinary registration provisions, not as an assembled vehicle, which is the route the Secretary of State's published kei guidance describes. Read out of context the exclusion looks like a prohibition, and it is occasionally cited as one.

Official sources

Michigan law & agency links

Michigan Secretary of State — Titles FAQ (kei-class vehicles)
Official sourceAgencymichigan.gov
The controlling agency statement. Answers directly that kei-class vehicles including mini-trucks and microvans 25 years and older can be titled and registered for on-road use, and that those under 25 years can only be titled as off-road vehicles.
MCL 257.217i — Assembled vehicles; titling requirements
Official sourceStatutelegislature.mi.gov
The assembled-vehicle titling pathway. Subsection (5) excludes a gray market off-road minitruck from that specific route — an exclusion from one pathway, not a general prohibition.
MCL 257.216 — Vehicles subject to registration
Official sourceStatutelegislature.mi.gov
The general registration requirement for vehicles driven on Michigan highways.
Michigan Vehicle Code — Act 300 of 1949, Chapter 257 (full text)
Official sourceStatutelegislature.mi.gov
Complete published vehicle code. Useful for confirming that Michigan has no separate mini-truck vehicle class and no speed or road-class cap for one.
Michigan Secretary of State — Vehicle services
Official sourceAgencymichigan.gov
Official titling and registration portal, including branch office locations and appointment booking.

FAQ

Common questions

Are kei trucks street legal in Michigan?: Yes, if the vehicle is at least 25 years old. The Secretary of State states that kei-class vehicles including mini-trucks and microvans 25 years old and older can be titled and registered for on-road use. Vehicles under 25 years old can only be titled as off-road vehicles.
What happens if my kei truck is 23 years old?: It cannot be registered for road use in Michigan. The 25-year threshold is stated plainly in the Secretary of State's guidance and there is no exception for equipment upgrades or inspections. You would be able to title it as an off-road vehicle only, and would need to wait until it crosses 25 years for on-road eligibility.
I read that Michigan classifies these as off-road vehicles. Is that right?: That was Michigan's position before late 2024, and it is now out of date. The Department of State reversed the ORV-only classification and began issuing on-road titles. A great deal of secondary material still describes the old policy, which is why it is worth going to the Secretary of State's own guidance.
Are there speed or road restrictions?: Michigan does not attach a posted-speed cap or road-class restriction to kei vehicles the way states with a dedicated mini-truck class often do. A qualifying kei truck is titled and registered as an ordinary vehicle. Be sceptical of claims about a federal rule barring kei trucks from highways — there is no such federal restriction, and that claim circulates widely without support.
What documentation do I need?: Import documentation is required if the vehicle has not previously been titled in the U.S. In practice that means your CBP Form 7501, HS-7 with box 1 checked, EPA Form 3520-1, and the Japanese export certificate with a certified translation. If the vehicle already carries a U.S. title, confirm it is an on-road title rather than an ORV title.
What about MCL 257.217i and 'gray market off-road minitruck'?: That provision excludes minitrucks from Michigan's assembled-vehicle titling pathway — the route used for kit cars, rebuilt vehicles, and off-road vehicles being converted to road use. It does not prohibit titling a kei truck generally. An imported kei truck is titled through the ordinary foreign-vehicle provisions instead, which is what the Secretary of State's kei guidance describes.
Do I need a special inspection?: Michigan does not operate a general periodic safety inspection programme the way some states do. Confirm current requirements for an imported vehicle with the Secretary of State when you book your appointment, since requirements for first-time titling of a foreign vehicle differ from ordinary transfers.

Michigan's on-road pathway rests on Secretary of State classification policy rather than a statutory kei or mini-truck class, and the department reversed its position once in late 2024. Individual branch offices may also apply the guidance inconsistently, particularly for first-time titling of an imported vehicle. Confirm current policy and the 25-year eligibility of your specific vehicle with the Michigan Secretary of State before purchasing. This page is informational only and not legal advice.

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