In the past weeks, several HVIA members have raised questions about interactions between the updated Heavy Vehicle National Law, coming August 1, 2026, and existing Australian Design Rules. Two notable examples are ADR 43/04 (Vehicle Configuration and Dimension), and ADR 106/00 (Side Underrun Protection).
ADR 43/04 (Vehicle Configuration and Dimension)
The issue with ADR 43/04 is that it dictates a hard limit of 9.5 metres on trailer S-dimension. The updated HVNL will permit trailer S-dimension to exceed 9.5 metres, up to a maximum of 10.5 metres, provided specific conditions are met (see HVIA’s recent explainer article for more detail).
HVIA raised that issue with the Federal Department of Infrastructure and given the conditional nature of the extended trailer allowance, the Department has advised they are unable to change ADR 43, but there is a compliance pathway for manufacturers seeking to take advantage of the new limit in the HVNL.
HVIA understands that manufacturers should submit a ‘substantially comply’ approval through ROVER for vehicles with S-dimensions longer than 9.5 metres. The Department has explained that approach is also currently used to manage Performance Based Standards (PBS) applications, which often exceed one (or more) ADR dimensional limits.
ADR 106/00 (Side Underrun Protection Systems – SUPS)
The issue with ADR 106/00 is that it does not currently apply to any category of trailer, yet the updated HVNL will call for SUPS to be fitted to any trailer where the S-dimension exceeds 9.5 metres.
Naturally, the question for manufacturers is how to demonstrate compliance, and to which standard?
HVIA also raised that issue with the Department and was advised that there will again be no change to ADR 106. Therefore, manufacturers do not have to demonstrate compliance through the VTA application process, but the lack of ADR applicability does not prevent manufacturers from following the requirements of ADR 106/00 and its underpinning regulation, which is UN Regulation No. 73.
The Department also noted that the HVNL already includes other technical requirements not regulated by ADRs, and therefore not assessed by the Department as part of vehicle type approvals. One such example is the requirement for prime movers used in 26-metre B-double combinations to comply with UN Regulation No. 29 (Cabin Strength Requirements).
If you have any questions or feedback on this issue, send them through to HVIA via Adam Ritzinger (a.ritzinger@hvia.asn.au) or Rachel Michaud (r.michaud@hvia.asn.au) to raise with the Department and NHVR.
Or you can contact the Department via ROVERinfo@infrastructure.gov.au and the Vehicle Standards team at the NHVR via vehiclestandards@nhvr.gov.au.