Actually, gray market imports still occur, and non-emissions cars CAN be certified To that I would ask, then what the heck is a MINI? Grey market importation has been going on for decades, and it's a long and expensive process. Generally speaking, it works like this: 1) Car owner buys the car through a grey market importer. Sometimes the car owner buys the car directly then transfers it to the importer, but more often than not, the importer acts as a broker to purchase the car on the owner's behalf. 2) At this point, the importer usually does a preliminary first-phase conversion, depending on whether they carry US-spec parts in the country of origin, or if it gets shipped to a conversion facility in the US. If the former, the preliminary conversion is done there and sent to the US for the major remainder of the work to be done.. If the latter, the car is shipped to the US with paperwork stating that this vehicle is a grey market vehicle to be converted to US spec. US ICE will usually do a temporary, conditional exemption and allow the car entry, providing the car is not operated on US highways until conversion is complete, except under supervised testing. 3) Importer then finishes the conversion in the US. US spec lights, bumpers are installed. Instrumentation is likely converted to US instead of metric. A US spec dash is installed, and left hand steering installed. A US spec exhaust system is fitted if the engine is already certified for US sale - if not, a US spec engine is fitted along with US style pollution controls. This entire process takes months, and can cost anywhere from $20,000 to over $100,000. 4) After testing to ensure that the car meets US safety, lighting, and emissions standards, the vehicle receives EPA and Customs approval and can be legally operated in the USA. 5) Owner takes custody of the vehicle. As you can probably imagine, this whole process is way too expensive and time consuming for the typical US buyer. Grey market importation can easily double the purchase price of the vehicle, and there have been some extreme cases in which it took as long as two years for the converted vehicle to reach the buyer. 99 percent of US buyers for European makes just simply take delivery of dealer stock or order it through the dealer's regular channels. Most people that do take advantage of the grey market are either collectors of certain rare vehicles that the maker never certified for US (a few well known examples would be the 2002 turbo, the E21 320i/6 and 323i, the E30 "touring" wagon, and the 302hp early Euro-spec E36 M3 [US flavors of the E36 M3 got the 240 hp version], and my personal favorite - the SHORT wheelbase E32 750i !), or certain well-heeled buyers that are insistent on having a certain model and have the funds and patience to make it happen. Of course, this doesn't apply to the few clever souls who are able to take advantage of inattentive border guards and customs officials and simply drive their vehicles into the US from Canada or Mexico.