Clarification on vehicle marking requirements for Heavy Trailers under RVSA

An anomaly spotted by an HVIA member has highlighted that the new Road Vehicle Standards Act (RVSA) is still teething as its first month closes out.

HVIA’s National Manager Policy & Government Relations Greg Forbes was pleased with the prompt and considered response from the Department of Infrastructure, Transport, Regional Development and Communications.

“Members are always encouraged to contact HVIA with these types of policy issues so we can get them resolved quickly,” Mr Forbes said.

ADR 61/03 applies to all manufacturers who have obtained a Vehicle Type Approval (VTA) under the RVSA which came into effect on 1 July 2021 regardless of whether they have chosen to “opt -in” or apply for a new VTA.

Section 7 details the situations where vehicles must include a metal marking plate and section 7.4 deals with the requirements for specific types of trailers.

Clause 7.4.2 requires manufacturers of trailers over 4.5 tones ATM to include the words “BRAKE SYSTEM COMPONENT TYPE APPROVAL NUMBERS” followed by the relevant numbers or “N/A” if there isn’t an applicable component type approval.

The problem arises where a trailer manufacturer uses the “opt-in” approach outlined under the RVSA to obtain their VTA.

In these circumstances the manufacturer may not have Component Type Approvals for the brake system components it has used on the trailer.

Where a Manufacturer has used the opt-in approach they can continue to rely on the Component Registration Numbers (CRNs) or Sub Assembly Registration Numbers (SARNs) issued under the previous Motor Vehicle Standards Act.

“The Department of Infrastructure has advised that although the wording of the ADR is not ideal, they do not believe that the ADR prevents the inclusion of additional relevant information – for example, referencing a braking SARN,” Mr Forbes said.

“In the case of manufacturers who opt-in and wish to continue to rely on SARNs (and CRNs), The Department has suggested that the manufacturer would still need to include the wording outlined in section 7.4.2 but would add “N/A”, and also list the relevant braking SARN – e.g. “BRAKE SYSTEM COMPONENT TYPE APPROVAL NUMBERS: N/A – SARN xxx.”

“The Department has acknowledged that this is an interim solution and has referred to matter to the Technical Liaison Group (TLG) to consider amending the ADR to provide absolute clarity.”

HVIA is one of the industry groups which attends the TLG and will provide an update if the ADR is amended.

If you are having issues with the RVSA and are having difficulties in getting a timely response please contact Greg Forbes at g.forbes@hvia.asn.au or 0437 923 755.