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What is the RVSA?
The RVSA is the “Road Vehicle Standards Act” which is a federal act managed by Vehicle Safety Standards Branch of the Federal Department of Infrastructure, Transport, Cities and Regional Development. The RVSA will replace the current Motor Vehicle Standards Act 1989. The RVSA will provide a modern regulatory framework for the Australian Government to regulate the importation of road vehicles into Australia, and the first provision of road vehicles in Australia.
Into the future vehicles are set to become even smarter, more autonomous, and more connected to each other and to infrastructure. The RVSA will provide a flexible and responsive legislative framework for ensuring that Australia can access and make use of technological advancements while still meeting safety, security, and anti-theft standards expected by the Australian community.
Who will the RVSA affect?
The RVSA will affect all trade sectors of the Recreational Vehicle industry in some way as briefly summarised under each sector below.
Towable Recreational Vehicle Manufacturers or Importers:
All Towable Recreational Vehicle Manufacturers or Importers (supplying more than 4 units per year) will need to register with the Federal Department and obtain a type approval for the type of trailer they wish to supply or manufacture. Furthermore, the details of each and every Towable Recreational Vehicle will need to be recorded on the online Register of Approved Vehicles (RAV). Towable Recreational Vehicles (identified by VIN) which do not appear on the RAV will not be able to be registered by State Transport Authorities.
Motorised Recreational Vehicle Manufacturers or Importers:
Motorised Recreational Vehicle Manufacturers and Importers (Campervans and Motorhomes) will need to transition their current IPA approvals (under the MVSA) to RVSA Approvals. Over time, the evidence for renewed RVSA approvals will need to come from an approved test facility only.
Furthermore, each and every vehicle will need to be recorded on the online Register of Approved Vehicles (RAV). Motorhomes and Campervans (identified by VIN) which do not appear on the RAV will not be able to be registered by State Transport Authorities.
Recreational Vehicle Dealer:
Under the RVSA, it may be an offence to modify or change the ADR compliance aspects of a Recreational Vehicle prior to registering it. This may affect the way in which dealers currently fit a number of options/ accessories to a Recreational Vehicle prior to handing it over to the consumer.
The RVSA is also likely to affect the Registration Process of all Vehicles including Trailers at a dealer level. This means the dealers may have to understand a new process for registering their Recreational Vehicles. Each State and Territory transport authority is working to incorporate the RVSA requirements and RAV database into their registration systems.
Component Supplier/ Component Manufacturer or Importer:
If you manufacture, supply or import a component, accessory or assembly which is governed by a relevant Australian Design Rule (ADR) then (if applicable) under the new act you may need to obtain a Component Type Approval (CTA) in place of any existing CRN‘s or SARN’s. Over time, to obtain an approval (to be called Component Type Approvals) your evidence or testing for the relevant component will need come from a federal government approved test facility.
Recreational Vehicle Service/ Repairers:
Recreational Vehicle Service and Repair agents will need to be aware of the changes through the RVSA and understand the implications of modifying a Recreational Vehicle – particularly prior to registration.
Is the RVSA a good thing?
Yes! The RVSA once fully in force will provide Towable Recreational Vehicle Manufacturers and Importers a level playing field, create a barrier to entry for newcomers and start-ups, improve the safety and compliance of Recreational Vehicles being manufactured and arm federal government regulators with greater enforcement powers to assist in stamping out non-compliant and more importantly, unsafe Recreational Vehicles making it onto Australian roads.
When will the RVSA start?
The RVSA will commence in full on 1 July 2021 remembering also that when the RVSA commences, there will be a 12-month transitional period during which some MVSA approvals will continue to be in force including Low ATM Trailers (light trailers). More information on the timeline head to the Timeline section of this site.
How much will the RVSA cost me?
The Department has now published the fees and charges associated with administering the Road Vehicle Standards Act (RVSA). This information has subsequently been incorporated into the Road Vehicle Standards Rules 2019 and the Cost Recovery Implementation Statement – Road Vehicle Standards 2020 – 21.
The fees associated with applying for these approvals and for entering Vehicles (including trailers) onto the RAV are summarised in the table below. This summary only outlines the fees and charges associated with some industry relevant approvals under the RVSA via the type approval pathway (not the Concessional RAV Pathway).
This summary is provided as a guide only, with industry businesses encouraged to make their own investigations with regards to the fees/ charges contained in the Road Vehicle Standards Rules 2019 and the Cost Recovery Implementation Statement – Road Vehicle Standards 2020 – 21.
|Low ATM Trailer (Light Trailer – ATM of 4,500kg or less)||$50||n/a||$0.75||$50|
|Goods Vehicle (NA, NB, NV), e.g. Motorhome/Campervan||$330||n/a||$6.60||$140|
|Component (Component Type Approval [CTA])||$35||n/a||n/a||$0|
Can I just keep operating as I do now when the RVSA commences?
No – the RVSA will affect most businesses in some capacity as briefly summarised in the above question “Who will the RVSA effect”. If you are not prepared and ready for the commencement of the RVSA then you will be impacted. For example, if you are a Towable Recreational Vehicle Manufacturer or Importer you will need to hold the required Vehicle Type approvals and be authorised to enter your trailer on the online Register of Approved Vehicles. Your trailer under the RVSA must be entered into RAV database for it to be successfully registered.
What can I do now?
Right now, businesses need to be preparing for the RVSA by ensuring they have all the required evidence and documentation to support any approvals required. Furthermore, businesses are encouraged to start trialling the Register of Approved Vehicles (RAV) within their operations (if possible) to be prepared for the commencement of the act.
Low ATM Trailer (light trailer) Manufacturers/ Importers may also wish to use the Am I RVSA Ready? Self-Evaluation Tool to determine what they can be doing now to prepare.
Do I have to use components that have a Component Type Approval (CTA)?
No. However, if you use a road vehicle component that does not have a CTA, there will be an obligation on you to demonstrate the ADR compliance of the component to support your Vehicle Type Approval application. You will also become responsible for the compliance of the component. Using a component with a CTA will streamline the process, as you can simply hold on file the CTA number for the component rather than having to retain all the supporting evidence.
Who is responsible for compliance of a vehicle component?
If a road vehicle component has a Component Type Approval, the holder of the Component Type Approval will be responsible for the compliance (or any non-compliance) of the component.
If a Vehicle Type Approval is granted using a component(s) that does not have a Component Type Approval, the holder of the vehicle approval will be responsible for compliance of the component.
Do I have to get a Component Type Approval for my road vehicle component?
No. Component type approvals are not mandatory. However, it is expected that vehicle manufacturers will be attracted to components with a Component Type Approval as it will streamline their Vehicle Type Approval applications and ongoing responsibilities.
If I don’t get a Component Type Approval for my component, what will I need to supply as supporting documentation to my customer for their Vehicle Type Approvals?
Appropriate supporting documentation would typically be a test report from an approved test facility. A declaration of compliance may be accepted in some cases, however the Department could ask for the full test report or supporting information at any stage and it would be a requirement of the Vehicle Type Approval holder to have ready access to that information.
Can I reduce my RVSA obligations by not obtaining a Component Type Approval?
Yes …and No. If you decide not to apply for a Component Type Approval, you are choosing not to participate in the RVSA regulatory framework, therefore would not be bound by the legal obligations of the RVSA.
However, if you supply components to vehicle manufacturers who obtain Vehicle Type Approvals, those manufacturers will need to ensure that they have access to information and premises in order to satisfy the conditions of their approval. This will extend to information and premises relating to components that form part of the Vehicle Approval. Component suppliers may retain better control of their designs and IP by managing a Component Type Approval themselves rather than providing access to the necessary information and manufacturing sites to a 3rd party.
Can I convert my existing MVSA Approval into RVSA?
Yes. An opt-in arrangement is provided that allows the holder of an eligible MVSA approvals to apply for an vehicle type approval on the basis of the existing evidence and information.
Approvals granted under this opt-in arrangement will remain in force for a period of 5 years (rather than the 7 years of a new vehicle type approval).
Note that an eligible approval holder may choose either to use the opt-in arrangements or to apply for a new vehicle type approval.
Who is eligible to use the opt-in arrangements?
A holder of a current MVSA approval that is in force and up to date at the commencement of the RVSA transition period is eligible for the opt-in process.
Note that the current approval must be up to date and correct. It is important that any corrections or updates are completed within the MVSA systems prior to applying to opt-in to RVSA.
When are opt-in arrangements available?
Applications for a vehicle type approval under the opt-in arrangements will only be available via ROVER (Road Vehicle Regulator IT system) for the 6-month period from 1 July 2021 until 31 December 2021.