OrientationThe short version
A Sur-Ron is legally a motorcycle under Colorado law (C.R.S. 42-1-102(55)) - too fast and too powerful to be an e-bike, moped, or low-power scooter. Colorado has a real, documented process for converting a two-wheel off-road motorcycle into a street-legal one: equip it to road standards, get a P.O.S.T-certified VIN inspection and an equipment-compliance certification, then title and register it in person at your county.
Nothing in that process prohibits electric bikes. Two things trip people up: an inspector wrongly refusing to certify an electric bike, and the ownership paperwork on an imported bike. This guide solves both.
The switchback“Colorado doesn't allow electric bikes to be street-legal”
You may hear this. I heard it from a Colorado State Patrol trooper who agreed to do my VIN inspection but refused to sign the DR 2686, saying the Department of Revenue doesn't permit electric conversions.
“The Department of Revenue doesn't allow electric bikes to be made road legal in Colorado.”
He could not cite a statute, a rule, or a written policy - because none exists. Here's why it's wrong:
· The DR 2686 and every statute behind it - head lamps, tail lamps, stop lamps, brakes, horn, mirrors, tires - are about equipment. Not one mentions gas versus electric.
· The definition of “motorcycle” printed on the form itself (42-1-102(55)) is propulsion-neutral. It excludes farm tractors, low-speed electric vehicles, and low-power scooters. A Sur-Ron is none of those.
· The “roadworthy” standard (42-6-102(15)) asks whether parts and systems function. Also propulsion-neutral.
P.O.S.T certification attaches to individual officers, not agencies. A refusal is one person's comfort level, not the law. Find a different certified inspector - a county sheriff's impound unit is often your best bet.
Call the DOR Title & Registration section at (303) 205-5608 and ask them to point to any statute or rule barring electric conversions. Get the answer by email. Useful ammunition if a clerk balks later.
Before you startIs your bike actually eligible?
You need a bike that is a two-wheel off-road motorcycle - Sur-Rons qualify; the Chinese conformity certificate usually says 电动摩托车 (“electric motorcycle”) right on it, with an off-road restriction.
It also needs a VIN you can inspect. Newer bikes (the Ultra Bee, for instance) ship with a proper 17-character VIN - good. Some older Light Bees carried short, non-conforming serial numbers, which is a much harder and occasionally fatal problem for on-road titling. Check your frame stamp before you spend money.
And you need to be able to prove you own it - which, for an import, takes some deliberate assembly.
ImportsBuilding the ownership chain
Grey-market imports don't come with a US Manufacturer's Certificate of Origin, and one is never coming. What you have is enough - you just have to assemble it on purpose.
What you'll already have
The foreign Certificate of Conformity (产品合格证) - the factory cert. It identifies make and model and, crucially, carries the VIN. It will also say off-road or closed-course use only. That's fine: converting an off-road bike to on-road is the entire point of the process.
The commercial invoice - your Alibaba or reseller receipt showing buyer, item, price, and date. This functions as the dealer's invoice that Colorado lists as acceptable proof of ownership.
What you have to create
A bill of sale. This is the connective tissue: your receipt has no VIN, and your conformity cert has no buyer name. Write one that ties them together - your name, the VIN from the cert, the make and model, and the price and date from the receipt.
The foreign-seller signature problem
A bill of sale normally carries two signatures, and your seller is a company in China that will never sign a US document. This is not a dealbreaker. Colorado explicitly accepts a bill of sale signed under penalty of perjury - your sworn attestation is the legal substitute for the seller's signature. So:
Include the penalty-of-perjury certification (C.R.S. 42-6-125), get it notarized, and annotate the seller line so an empty signature reads as intentional rather than forgotten - e.g. “Seller signature: not applicable - foreign commercial seller. The sale is evidenced by the attached invoice No. ______ in lieu of the seller's signature. Buyer attests under penalty of perjury.”
Assembled, your chain is: notarized bill of sale + commercial invoice + certificate of conformity + CPW OHV registration. That cleared both Colorado Parks & Wildlife and the DMV for me.
You do not need a bonded title
A bonded title (DR 2922, roughly a 2× value surety bond) exists for when you can't prove ownership. You can. It also still requires the same VIN inspection and does nothing to make the bike street-legal - so it solves none of your actual problems while costing money.
HardwareWhat the bike needs
The certified inspector verifies each of these works. Install and test before you book anything.
On mufflers: the noise-control statute is effectively moot on an electric - there's nothing to muffle. Don't let it be cited as a reason electric bikes “can't comply.”
The routeStart to plate
Register it as an OHV with Parks & Wildlife
Different agency, different document. CPW registration (about $25/year) is permission to operate on trails - it is not a title. But it's easy to get with a bill of sale and it strengthens your ownership footing before you ever walk into the DMV.
This step has to be done in person at a CPW office - it isn't available online for a bike with no prior Colorado registration. Bring your bill of sale; that's what they'll use to register it to you. It's also worth bringing the bike itself if you reasonably can, so staff can check the VIN on the frame against the VIN on your ownership documents before anything's issued. You get a temporary sticker immediately, decals by mail.
CPW registration says where you can ride. A DMV title says who owns it. OHV titling exists but is optional for private sales - and you don't need it as a separate step. Your bill of sale is the proof of ownership; the DMV issues a motorcycle title at the end.
Equip the bike and get insurance
Install and test everything in the hardware list above. Then get motorcycle insurance - Sur-Rons are cheap to insure. You'll need proof of it at the county counter.
Fill out the forms
Three of them: DR 2395 (application for title and registration), DR 2686 (equipment compliance - you fill the top, the inspector signs the rest), and DR 2444 (statement of fact, to declare the bike has no odometer). Details in the form-by-form section.
The certified VIN inspection - where electric bikes get refused
You need a Certified VIN Inspection (DR 2704) - not the basic VIN verification (DR 2698). Only a P.O.S.T-certified inspector can do it. Emissions stations, dealerships, and the county counter can do the verification but not the certified inspection. Don't waste the trip.
Who can: Colorado State Patrol does them by default. Some local law-enforcement agencies have their own certified inspectors - in the Denver metro, the Denver Sheriff Vehicle Impound Facility takes appointments. Your county office can also refer you to one.
When you book, be explicit: say it's a two-wheel off-road electric motorcycle being converted to highway use, and that you need the DR 2686 equipment certification, not just a VIN check. Most certified inspections are for salvage and kit cars, so confirm the inspector will complete the motorcycle roadworthy checklist before you load a trailer.
The inspector verifies the VIN, completes the checklist, signs the DR 2686, and issues a signed DR 2704. Budget $55 (the fee rose from $50 on July 1, 2026).
Title and register - in person, at your county
The online myDMV flow will not work for an import. It wants a “Title Complete Notice” postcard carrying a title number and letter ID - a document that only exists after a dealer submits title work. No dealer, no postcard. Colorado's own rules say third-party and private purchases must be handled in person.
Book an in-person appointment and choose the category “New Colorado Resident / Out of State Purchase (Dealer or Private) / In-State Private Party Purchase.” Not “Colorado Dealer Purchase.” Not “Title Bonds.” At least one owner must be present.
Your DR 2704 already satisfies the VIN-verification requirement, so you shouldn't be sent off for a separate DR 2698. The county creates the title and registers the bike in the same visit, assesses use tax (no US sales tax was collected on an import - budget for this), and issues your plate. The witness line on the DR 2395 gets signed at the counter.
Describe the bike - imported, converted off-road electric motorcycle, signed DR 2686 in hand, ownership by bill of sale and invoice - and confirm they'll title and plate it in one visit. Two minutes on the phone beats a wasted trip with a trailer.
After you're plated
Add the motorcycle (M) endorsement to your license before you ride on the road - titling doesn't require it, riding legally does. And keep your CPW registration current (or buy an OHV permit) if you still want designated trails. A plate and trail access aren't mutually exclusive.
Counter dayThe packet
What to walk in with. Tick as you go.
AppendixForm by form
Application for title and/or registration
- VIN: hand-write it into the character boxes at the top of all three pages - it isn't a fillable field on the PDF.
- Body: Motorcycle. Fuel type: Electric. Plug-in electric: Yes.
- Odometer:
EXEMPT- no true odometer (see DR 2444). - Empty weight (CWT): weigh the bike. Don't guess - you're signing under penalty of perjury.
- Off-Highway Vehicle? → NO. This is the one people get wrong. You are registering a highway motorcycle. Your CPW registration is a separate system; marking Yes here misclassifies the bike.
- Everything else - flex fuel, commercial, hazmat, registrant only, lease buy-out, joint tenancy - No.
- Sign page 2. The witness line is signed at the counter, not before.
Certification of equipment compliance for motorcycles
- You fill: year, make, model, VIN, and your name and address in the certification block. Sign it (penalty of perjury).
- Leave blank for the inspector: the entire “Verification of Certified VIN Inspector” section and all of page 2, the roadworthy checklist.
- Proof of ownership it accepts - you need only one: an MSO, a bill of sale (notarized or under penalty of perjury), a dealer's invoice, an off-highway title, or a DR 2444.
Statement of fact
- Use it to state: “This motorcycle has no odometer mechanism. A trip meter is not an odometer mechanism.”
- Optionally also check the actual purchase date/price line and enter yours - it corroborates the use-tax basis.
- Sign (penalty of perjury).
Forms you'll hear about but can skip
DR 2698- basic VIN verification. Superseded by your certifiedDR 2704.DR 2922- surety bond / bonded title. Only if you can't prove ownership. You can.
BudgetWhat it runs
| Item | Approx. |
|---|---|
| CPW OHV registration | ~$25 / yr |
| Certified VIN inspection | $55 |
| Notary | ~$10–15 |
| Title fee | $7.20 |
| Use tax - the one that surprises importers | local rate × price |
| Registration & ownership tax | varies |
| Motorcycle insurance | often cheap |
Use tax is the big variable. No US sales tax was collected on an import, so the county assesses it at titling. Budget for it so it isn't a surprise at the counter.