Low ATM Trailers
Under the RVSA, all Low ATM Trailers (Towable Recreational Vehicles with an Aggregate Trailer Mass (ATM) of 4.5 tonnes or less) provided to the Australian market for the first time must be entered into the Register of Approved Vehicles (RAV). For a low ATM trailer to be recorded in the RAV, Manufacturers and Importers providing more than 4 trailers to the Australian market must obtain a vehicle type approval for their trailer type within a 12-month transition period beginning July 1, 2021.
To be able to hold a vehicle type approval by July 1, 2022, the Department cannot provide a vehicle type approval after May 31, 2022. Manufacturers and Importers must ensure that all the required information is provided in the vehicle type approval application to assist with the assessment process. Incomplete applications or applications submitted within 30 business days of May 30, 2022– that is, after April 11, 2022 (allowing for 4 public holidays in that 30 business day period) may not be approved.
An importer can continue to apply to import low ATM trailers that comply with, or could be modified to comply with, the requirements set out in Vehicle Standards Bulletin 1 (Revision 5). Applications can be made up until 11:59pm on April 30, 2022 through the Vehicle Import System (VIS). More information about importing low ATM trailers can be found HERE.
IS A VEHICLE TYPE APPROVAL REQUIRED FOR EACH MODEL OF A LOW ATM TRAILER?
No. Vehicle Type Approvals are based on the Vehicle Category Codes (VCC) as defined in the Australian Design Rules (ADRs). Multiple models of the same VCC are covered by one approval. Low ATM Trailers are based on the Gross Trailer Mass (GTM) of the vehicle.
HOW CAN I APPLY A VEHICLE TYPE APPROVAL?
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 Road Vehicle Standards Act 2018 (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
- Be notified of the decision outcome of your application.
The Road Vehicle Standards (RVS) legislation allows the Department to refuse to consider applications in certain circumstances. Refusing to consider an application means the application is closed without either granting or refusing to grant the requested approval. A guide released by the Department sets out why the Department may refuse to consider an application, how to avoid that happening and what you can do if the department refuses to consider your application. To access the guide click HERE.
The Authority To Act within ROVER allows an organisation to have multiple tiers of authority to represent the organisation. Multiple tiers are able to represent the organisation for any application or approval request, or for recalls, and are able to see any information pertaining to that organisation contained within ROVER. More information and requirements can be found in the Authority to Act section of this website.
A video providing guidance on how to add design and manufacturing facilities within ROVER can be found under the Videos tab.
Further information about ROVER, including how to create an account, can be found in the Department’s ROVER Resources page.
WHAT INFORMATION ARE NEEDED BEFORE I CAN APPLY?
To be eligible to apply for a Vehicle Type approval, the applicant must be able to demonstrate they fulfil all of the relevant eligibility criteria. The eligibility criteria are quite strict to ensure approval holders have the necessary skills, capabilities and business arrangements in place to consistently build compliant trailers. The eligibility criteria include (but are not necessarily limited to):
- The Manufacturer/ Importer is able to supply (provide) Low ATM Trailers which comply with all the applicable National Road Vehicle Standards – e.g. Australian Design Rules (ADRs);
- The Manufacturer/ Importer has control over all stages of the design, componentry and manufacturing process for the type of trailer or is able to access information, including information about any changes, relating to the design, componentry and manufacturing process for the type of trailer that may affect the compliance of the trailer with the applicable ADRs;
- The Manufacturer/ Importer is able to ensure that the design, componentry and manufacturing process will consistently produce compliant trailers;
- The Manufacturer/ Importer has the ability to access the original and any subsequent versions of the supporting information for the approval, provide the information to the Federal Regulators (VSS) if requested and ensure the supporting information is kept up to date; and
- The Manufacturer/ Importer is able to arrange for the Federal Regulators (VSS) to inspect premises used, or to be used, in the manufacturing process for the purposes of assessing compliance with the applicable ADRs and any other requirements of the Act, the Rules, or an instrument made under the Act.
The Vehicle Type Approval applicant must retain all relevant information to support their application.
The application fee associated with obtaining a Vehicle Type Approval for a Low ATM Trailer and entry of trailers into the RAV are as follows:
- Application Fee = $50
- RAV Charge (per Trailer) = $0.60
- Variation of an RVSA Approval = $50
More information on fees and charges can be found HERE.
The Department’s “Guide to Vehicle Type Approvals for Low ATM Trailers 4.5t ATM or Less” provides detailed information on the Type Approval process. Click here to access the guidance material.
WHAT CAN I DO NOW?
Two of the key elements to obtain your Business a Vehicle Type Approval are to demonstrate compliance to the relevant ADRs and Conformity of Production (CoP). Both of these elements will need to be completed before you can finalize your type approval application. These elements must remain a part of your business systems once you have transitioned to the RVSA and will need to continue to be updated and treated as living documents within your business.
Australian Design Rules
Vehicle Type Approvals will cover all ADR-related aspects of the towable recreational vehicle. VSS have an ADR Applicability Summary for Trailers available on their webpage which can be accessed by clicking HERE. This is a useful reference document for manufacturers and importers in determining which ADRs apply to the type of trailer they are providing to market.
Businesses will also need to consider which ADRs relate specifically to the type of Towable Recreational Vehicle being provided to market.
Evidence of Compliance with ADRs
The vehicle type approval applicant must have evidence in place demonstrating compliance to the relevant ADRs. All relevant documentation & evidence to support full ADR compliance will need to be obtained and kept up to date. Evidence of ADR compliance of some components that require testing (eg. strength requirements, light intensity) will need to come from an Approved Test Facility. More information on Approved Test Facilities can be found HERE.
For guidance on the ADRs and expected detail of evidence to support compliance relevant to towable recreational vehicles – CLICK HERE.
Trailer Markings (Plating Requirements)
The RVSA introduces a requirement for new vehicles to carry a Secure Vehicle Identification (SVI) marking. The SVI will replace the previous Identification Plate requirements of the Motor Vehicle Standards Act (MVSA).
To implement these changes, Australian Design Rule 61 – Vehicle Marking has been updated to include the requirements for SVI as formal identification for new trailers supplied to market under the RVSA.
For more information on the requirements, CLICK HERE.
Extent of ADR Compliance in ROVER
Based on the VCC that the applicant has selected, ROVER will filter and identify the relevant ADRs applicable for that VCC. The applicant will then identify which ADRs are applicable and the extent of compliance that their low ATM trailers comply with these ADRs.
There are instances where a trailer product doesn’t have a feature or system that would be relevant to an ADR so in these cases it would be not applicable. In this circumstance, the applicant must correctly identify the extent of compliance (e.g. Not Applicable/Exempt) and provide a satisfactory reason to justify it.
For more information, refer to the ‘Applicability of ADRs’ section of the Guide To Vehicle Type Approvals.
Conformity of Production (CoP)
Another key element of being eligible to obtain a vehicle type approval will be your ability to prove you have adequate control over all stages of design, componentry, and manufacture of low ATM trailers you are producing/ supplying. In other words, you will need to have some form of Quality Management System (QMS) in place to demonstrate that you have effective control on Conformity of Production.
Understanding the importance of Conformity of Production to the RVSA and industry, Caravan Industry Association of Australia has partnered with an Automotive Engineering Consultancy firm – Cadman Concepts P/L. This partnership will provide a cost-effective option to Recreational Vehicle Manufacturers/ Importers who are yet to implement a system or need to review/ upgrade their processes in preparation for the RVSA. This is an option available to Recreational Vehicle Manufacturers and Importers of all sizes to assist in complying with the Conformity of Production requirements. For more information on Conformity of Production (COP) click HERE.
VSS guidance material on Quality Management System requirements can be found by clicking HERE.