The Road Vehicle Standards Act (RVSA) is now in force and will increasingly play a large role in the activities of many HVIA members.
The RVSA has replaced the Motor Vehicle Standards Act (MVSA) which has governed first entry to the Australian heavy vehicle marketplace since 1989.
The Department of Infrastructure, Transport, Regional Development and Communications (DITRDC) launched the new ROVER system last week with promises of progressively increased functionality to support the new legislation.
HVIA members will have up to twelve months to changeover to the new system but need to start planning how they will manage the transition now.
There are a number of pitfalls members may encounter if they make the wrong decisions.
In particular, manufacturers of vehicles need to make a decision within the next couple of months as to whether they want to choose to convert their existing Identity Plate Approvals (IPAs) to Vehicle Type Approvals (VTAs).
Most manufacturers are likely to choose to opt-in, but if they do they will need to have the changes in place by 31 December 2021
Summary of changes under the RVSA
Changes brought about by the transition from the MVSA to the RVSA will have different impacts on different parts of the heavy vehicle industry as they are progressively phased in.
The most important part of the phase-in process commenced on 1 July 2021 with the full RVSA arrangements in place on 1 July 2022.
The key visible changes from the perspective of heavy vehicle manufacturers and component suppliers:
|Register of Approved Vehicles (RAV)|
|Road Vehicle Compliance System (RVCS)||ROVER|
|Identity Plate Approvals (IPA)||Vehicle Type Approvals (VTA)|
|Sub Assembly Registration Numbers (SARN) and |
Component Registration Numbers (CRN)
|Component Type Approvals (CTA)|
|Tightening of rules related to the use of ECE approvals|
|New requirements for registration of Testing Facilities|
|More rigorous requirements for demonstration of control of production (Quality Management Systems)|
|Changed requirements for concessional vehicle imports through the Specialist and Enthusiast Vehicles Scheme (SEVS), including Registered Automotive Workshops (RAW) and Authorised Vehicle Verifiers (AVV)|
|The introduction of Model Reports as an alternative mechanism for demonstrating compliance for SEVS scheme vehicles and heavy trailers.|
|The introduction of new fees and charges based on a cost recovery model.|
Use ROVER to access and interact the with the RAV.
The introduction of the Register of Approved Vehicles (RAV) provides a publicly searchable online database of approved vehicles. The RAV hold similar information to the current compliance plate.
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).
ADR 61/03 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 RAV will provide information on what a vehicle was like when it first entered the Australian market which will assist enforcement staff in situations where a compliance plate has been removed or damaged.
The online tool for manufacturers and importers to access and interact with the RAV database is called ROVER.
Impact on vehicle manufacturers
Vehicle Manufacturers will be able to choose to continue to produce vehicles under IPAs approved under the MVSA until 30 June 2022.
From 1 July 2022 they must have a valid VTA to be able to continue to provide vehicles to consumers.
Manufacturers will be able to process variations to existing IPA’s during the 12-month transition period, but the closer it gets to 30 June 2021 the less cost effective this will be.
Once a Manufacturer starts producing a vehicle under a VTA the details of this vehicle must be loaded onto the RAV.
There are two possible ways to obtain a VTA. The first of these is to use the opt-in provisions of the legislation. This process requires the applicant to:
- provide details of the IPA approval
- make some declarations
- specify an effective date (which must be before the end of calendar year 2021) and
- pay a fee
More details are available in the Guide to the Opt-in arrangements
The second mechanism is to apply for a new Vehicle Type Approval using the processes defined under the new legislation (see Guide to Vehicle Type Approvals)
This requires the manufacturer to provide all of the required evidence under the new RVSA rules. This guide includes information on changes to requirements for evidence of compliance with ADRs through CTA’s and ECE approvals and new requirements for demonstration of control of the production process.
The following table summarises some of the key issues that need to be considered in deciding which path to pursue.
|VTA Opt-in||New VTA Application|
|Cheaper ($20 fee plus time to fill in forms)||More expensive. Department fee (depends on vehicle type) plus cost of preparing data for submission. See VTA guide|
|Must complete opt-in by 31 December 2021 (allow for 60 working days processing time)||To maintain continuity new VTAs must be in place by 30 June 2022 (allow for 60 working days processing time, possibly longer if issues)|
|Can continue to rely on CRNs and SARNS provided no Variations. (Variations must have CTA’s and have QMS in place)||Needs to use CTA’s and ECE approvals plus testing from Authorised Testing Facility. (Check availability with suppliers). Need to have QMS in place|
|Lasts 5 years before renewal required||Lasts 7 years before renewal required|
|After opt-in Variations under RVSA may carry a charge (see VTA guide)||No charge for Variations under MVSA. After VTA approved Variations under RVSA may carry a charge (see VTA guide)|
|Commence loading RAV from opt-in date||Vehicle produced under VTAs must be loaded onto RAV|
In addition, the Department has indicated that it has a 60 working day turnaround time for applications which effectively means applications for opt-in will need to be made by the start of October if they are to take effect by the end of the Calendar year.
Manufacturers also need to be aware of changes to the provisions for Second Stage Manufacturers (SSM) and the addition of Model Reports as a new mechanism for demonstrating compliance for SSM and heavy trailer manufacturers.
The Department has indicated it was hoping to have the Model Report documentation available by 1 July but the guidance material that has been published so far is very limited.
Implications for component manufacturers
Under the RVSA, the CRN and SARN schemes have been subsumed under Component Type Approvals.
Because the previous schemes did not have support in the legislation the Department is requiring component manufacturers to apply for Component Type Approvals from scratch with no mechanism for migrating CRNs and SARNs to CTA.
The Department is also tightening the rules on the evidence that they will accept for CTA applications. In particular, they are requiring that evidence in support of the application should come from a testing facility approved under the RVSA.
Where a component supplier can justify that the cost would be excessive, it may under some circumstances accept declarations from industry along with test evidence previously provided in support of a SARN or CRN as an alternate method of demonstrating compliance.
- on component type approvals can be obtained here Component type approvals (infrastructure.gov.au)
- The Guide to Component Type Approvals on this page has not been updated since January and does not reflect the latest information on Component type Approvals.
- Component suppliers should also read the position paper on test reports not supplied by a testing facility Position Paper – CTA Test Reports not supplied by a Testing Facility v2 (infrastructure.gov.au)
The RVSA also introduces new more stringent requirements for testing facilities here:
- Testing facilities (infrastructure.gov.au).
- A list of approved testing facilities is available on the ROVER system.
Specialist and Enthusiast Vehicles.
In addition to the type approval pathway, the RVSA offers a second pathway for vehicles to be supplied to the Australian market is through the Specialist and Enthusiast Vehicles Scheme (SEVS).
Vehicle that are supplied using this method will typically use a Model Report and use the services of a Registered Automotive Workshop and an Authorised Vehicle Verifier to have their vehicle placed on the RAV which will allow the vehicle to be supplied to market.
HVIA recommends anyone intending to bring a vehicle into Australia using the SEVS scheme employ the services of a consultant that specializes in this work.
It is important to be aware that vehicle manufacturers are still able to supply vehicles to market under their existing IPAs. While there is no immediate change, manufacturers must decide very soon how and when to make the transition to VTAs.
conversations with your component suppliers
- You need to understand where the component manufacturers are at with respect to registering CTAs or providing ECE approval information.
- This will help to inform decisions on transitioning to VTA’s
need to be acting on your transition plans by August at the latest,
- have VTA opt-in applications in the system by October.
- Vehicle manufacturers that decide to put in new VTA’s should be aware of possible teething issues and take the response times into account when planning the transition.
Users of the ROVER system should expect that there will be teething problems with the system during the initial period after roll-out.
The Department of Infrastructure has given a commitment to provide additional resources for the Rover Help Line and has indicated that it should see an improvement in turnaround times on inquiries.
Any members that are having trouble getting a response from the Department or are experiencing delays in getting approvals should contact HVIA so we can escalate issues with the Department.
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