Do manufacturers, importers and component suppliers have reason to be nervous?
The Road Vehicle Standards Act (RVSA) has gone live this week following a much delayed, somewhat controversial development, and serious concerns about its ambitious rollout.
The RVSA replaces the Motor Vehicle Standards Act (MVSA) which has governed first entry to the Australian heavy vehicle marketplace since 1989.
But it’s a done deal now. Once the Act went through Parliament, the Department of Infrastructure was hellbent on launching by the legislated “go live” date.
They say they had to – because Parliament has set it in stone. But what if it doesn’t work? What will be the consequences?
Industry has a right to be nervous when Government implements wholesale changes to ongoing processes. The National Heavy Vehicle Regulator went through a long period managing reputation damage after a couple of false starts.
Why? And why now?
When it announced its intentions in late 2017, the Australian Government said it was replacing the Motor Vehicle Standards Act to “reform the regulatory framework.” It has been called a “once in a generation” reform.
HVIA National Manager Policy and Government Relations Greg Forbes says the introduction of the RVSA was intended to provide an instrument which is more flexible and responsive to the changing road vehicle market, to improve transparency in decision making and provide a more robust framework for ongoing regulation.
“In practice much of the changes seem to be driven by trying to align Australia’s system with international regulatory frameworks and standards and in particular whole of vehicle type approvals,” Mr Forbes said.
“I expect that the changes will help the Department make the system more rigorous and will give Government increased flexibility and better enforcement powers.
“From industry’s perspective, however, the implementation seems likely to be costly.”
The key focus will be on replacing the current system of Identity Plate Approvals (IPA) with new Vehicle Type Approvals (VTA) and tightening up the requirements for demonstrating compliance with Australian Design Rules.
It will also incorporate the creation of a new Register of Approved Vehicles (RAV) – an online, publicly searchable database of vehicles approved for use on Australian roads.
“The RAV will hold similar information to the current compliance plate, which will provide information on what a vehicle was like when it first entered the Australian market and will assist enforcement staff in situations where a compliance plate has been removed or damaged” Mr Forbes explained.
“Along with the RAV, the Department is changing the requirements for vehicle markings with the release of a new version of the Australian Design Rule for Vehicle Marking (ADR 61/03).
“ADR61/03 will replace compliance plates with secure vehicle identification markings in the form of self-adhesive labels for most vehicles however trailers will still be required to fit a metal plate.”
The online tool for manufacturers and importers to access and interact with the RAV database is called ROVER.
“Industry has serious concerns with the uncertainties surrounding the level of performance of the ROVER system from 1 July, and the turnaround time for applications received by the Department,” Mr Forbes added.
Once ROVER is let off the leash everyone is going to be asking ROVER to do things, all at the same time. How is ROVER going to respond to that?
“The go-live version of the ROVER system has not been through a user-testing process and may not work as planned at go live.”
“Users of the ROVER system should expect that there will be teething problems with the system during the initial period after roll-out,” Mr Forbes warned.
Vehicle manufacturers are still able to supply vehicles to market under their existing IPAs after 1 July. While there is no immediate change, manufacturers must decide very soon how and when to make the transition to VTAs.
The Department has provided two options for converting to VTA’s:
- There is an opt-in process which must be completed by 31 December this year or
- alternatively manufacturers can continue to produce under their existing IPA until 30 June 2022 and put in a new application for a VTA to apply from 1 July 2022.
“If there are significant faults in the go live version of the system, there may be delays in processing applications over and above the Department’s normal sixty working-day turnaround time for applications,” Mr Forbes said.
“That effectively means that the phase-in periods for the new legislation will be cut by more than three months, when you allow for the Department’s processing time.
“Most manufacturers are likely to choose to opt-in, but they need to plan how they will manage the transition because there are a number of pitfalls they may encounter if they make the wrong decisions.
“In practice, vehicle manufacturers need to be acting on their transition plans by August at the latest, and should have VTA opt-in applications in the system by October.”
Mr Forbes said vehicle manufacturers who put in a new application have a little longer, but they should be having conversations with their component suppliers to inform their decisions on transitioning to VTA’s.
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