Component Manufacturers and Suppliers
For vehicle type approval applicants under the Road Vehicle Standards Act 2018 (RVSA), a number of road vehicle components, accessories, or assemblies (e.g. lamps, drawbar, coupling, etc.) are required to demonstrate compliance to the relevant Australian Design Rules (ADRs). In effect, vehicle manufacturers and importers may require supporting information from component manufacturers and suppliers as evidence of compliance with the ADRs. This evidence can be in the form of, but not limited to, Component Type Approval (CTA), a UN ECE Approval, a test report from an RVSA approved testing facility, or compliance to an alternative standard within an ADR.
What is a road vehicle component?
RVSA defines a road vehicle component as a component used in the manufacture of a road vehicle, including an assembly.
Components that are road vehicle components under the RVSA are intended to cover:
- a component capable of being assessed for compliance with a national road vehicle standard (Australian Design Rule (ADR)) or an equivalent standard, or
- an assembly of one or more components capable of being assessed for compliance with the applicable national road vehicle standards or an equivalent standard.
Importantly, the component or assembly is capable of being assessed for compliance with a relevant standard only if the standard provides for the assessment of that particular kind of component or assembly and is independent from an assessment of a broader system of the vehicle.
A component that is intended primarily for general sale directly to consumers is not expected to be approved under the RVS legislation.
What is a Component Type Approval (CTA)? Do I need one?
A Component Type Approval (CTA) is one of the options that may be used by applicants of a road vehicle type approval or approval of a Model Report to demonstrate compliance to the ADRs.
A CTA is not mandatory and is something that a manufacturer or supplier can choose to apply for. However, one of the benefits of having a CTA is to streamline applications for road vehicle type and Model Report approvals. Having a CTA is one way you can demonstrate compliance with the applicable ADRs for vehicle components used in manufacturing or modifying a road vehicle.
Under the RVS legislation, a person may apply for a CTA of a road vehicle component of a particular type that is intended for use in:
- the manufacture of a road vehicle that has a vehicle type approval, or
- the manufacture or modification of a road vehicle in accordance with an approved Model Report.
An application for the granting of a CTA may be made in relation to a:
- single component, or
- system consisting of multiple components (assembly). An assembly may be a combination of components that when combined constitute a road vehicle component.
What will be my responsibilities if I am to be a CTA Holder?
CTA holders have certain responsibilities to ensure the following requirements are met by every approval holder for every road vehicle component or system type:
- the road vehicle component or system complies with the applicable ADRs in force at the time it is provided for use or installation in a road vehicle,
- conformity of production systems are maintained,
- requested information or inspections are responded to appropriately,
- records of the original and any subsequent versions of supporting information will be kept up to date for the period the CTA is in force and for 7 years after it expires or is revoked, and
- installation instructions provided to an installer must be the latest version and appropriately detailed to ensure compliance with the applicable ADRs.
An approval holder must comply with all of the conditions within their approval. In addition to standard conditions, a CTA holder may also need to satisfy any specified conditions that may appear separately on the approval notice and relate to the approval holder’s specific or unique circumstances.
All CTAs will be subjected to the following specified conditions related to recall action of the approved road vehicle component:
- reporting recall action that you become aware of that is being undertaken outside of Australia to the department, and
- reporting systemic safety or non-compliance issues to the department.
More details about the department’s expectations for each of the standard and specified conditions are listed in Appendix 4 of the Guide to Component Type Approvals.
What if I had a CRN or SARN in the RVCS?
If you hold or have held a CRN (Component Registration Number) or SARN (Sub-Assembly Registration Number) in the RVCS (Road Vehicle Certification System) and you wish to supply approved road vehicle components to vehicle manufacturers, you may choose to apply for a CTA under the RVS legislation. However, there will be circumstances where CRNs and SARNs can continue to be used for some RVS legislation approvals.
If an applicant is applying for a CTA for a component covered by a CRN, or sub-assembly covered by a SARN registered in RVCS, and relying on results of testing, but is not able to provide results of testing from an RVS approved testing facility, the applicant must make a declaration at the time of application declaring that:
- the test facility that performed the testing no longer exists or is otherwise unable to meet the criteria to become a RVS approved testing facility,
- the information in the test report is current and includes all the information required by the relevant national road vehicle standards,
- the road vehicle component complies with the national road vehicle standards (or substantially complies and the non-compliance is only in minor and inconsequential respects or to a minor and inconsequential extent,)
- the road vehicle component being produced at the time of the application is identical to the component tested in the test report, and
- there is no safety benefit in re-testing the road vehicle component.
When making your application, the following information must be provided:
- a copy of the test report from the RVCS registered test facility,
- information that demonstrates that the test facility that performed the testing is no longer operational or is otherwise unable to meet the criteria to become a RVS approved testing facility,
- information that demonstrates that for the elements of the design that are relevant to compliance with the ADRs, the design of the component tested is identical to the component to be covered by the CTA,
- information that demonstrates that testing of the component by a RVS approved testing facility, in addition to the results of testing already undertaken, would not provide any additional safety, environmental or anti-theft benefits. This information must include a record of all field service feedback in relation to the road vehicle component and rectification action taken, and
- details of the cost and estimated timeframe for testing if undertaken by a RVS approved testing facility.
How do I apply for a CTA?
From July 1, 2021, all applications for approvals will be managed through ROVER (Road Vehicle Regulator) which is the Department’s administration system for the RVSA.
ROVER provides a single integrated system for all approvals and activities under the Road Vehicle Standards legislation, allowing you to:
- Submit and pay for an application,
- Monitor the progress of your application,
- Receive and respond to requests for information regarding your application, and
- Be notified of the decision outcome of your application.
The application fee associated with obtaining a CTA is $35.
How long will it take to decide an application?
The decision maker must decide your application for approval of a road vehicle component within 60 business days after receiving the application. If there is a need to request further information or an inspection of premises or components, then the time to make a decision may be longer.
At the time of making your application, you may specify a date for commencement of the approval. You can choose a date within the 60 business days, however if the decision to grant an approval is made after this date (decision date), then the decision date will become the date of commencement.
You may also specify a date of commencement of the approval beyond the 60 business days, allowing you to submit an application well in advance of the specified date that you would like the approval to become effective.
If a decision maker is not satisfied on the basis of the information provided, the decision maker may:
- request further information to assist in deciding whether to grant a CTA — this may be results of testing from an RVS approved testing facility or additional information relevant to the matters declared in the declaration, or
- refuse to grant a CTA.
Can I change details in my application?
When you start a new application, ROVER will allow you to save your work, exit the system and return to your saved work as and when you need to. At any time before submission, you can change the details of your saved application.
If you need to make changes after submitting your application, the following scenarios cover how changes are managed:
- if the application has been submitted but not paid, you can withdraw the application and commence a new application, or
- if the application has been submitted and paid, it will return a status of ‘in progress’. You can either:
- notify the department that a change is required and provide further information when requested (noting this may delay the process), or
- withdraw the application and start a new application (please note that a new application fee is payable in this instance), or
- if the assessment has been completed and an approval issued, then you need to apply for a variation of the approval and pay any applicable fees.
Now that I am a CTA Holder, what’s next?
Once an approval is granted, a CTA holder must ensure that they fully comply with all of the conditions within their approval. In addition to standard conditions, a CTA holder may also need to satisfy any specified conditions that may appear separately on the approval notice and relate to the approval holder’s specific or unique circumstances.
The Department monitors and enforces compliance with the RVS Legislation under both the RVSA (applying penalties) and the Rules (obligations of an approval holder). The department aims to encourage voluntary compliance and undertakes informed risk-based compliance activities to confirm compliance with the RVS legislation. These compliance activities may involve:
- asking you to provide information in writing to assess whether you are complying with RVS legislation, and/or
- appointed inspectors physically entering premises to confirm compliance with RVS legislation (monitoring powers)
Appointed inspectors may also physically enter premises to gather material at your premises that is evidence of a contravention of RVS legislation (investigation powers).
What if there are changes to the technical specifications of the vehicle component?
There may be instances where a technical change to the vehicle component occurs where that component has been used in combination with other components or systems and results in:
- an increase or decrease in a specification or value that results in a new worst case,
- a change to physical fitment/dimensions or change in material used in construction, or
- a change in compatibility with other components or interface (different voltage/plug type/sensor requirements).
An assessment must be made to decide if the technical changes affect compliance of the component as a whole when used in combination with other components or systems. In these instances, a variation of an approval would not be granted and a new application for a road vehicle CTA would need to be submitted.