Motorhomes

Second Stage of Manufacture (SSM) involves modifying or adding to a new vehicle (the base vehicle) to create an alternate vehicle (eg. motorhome).  Under the RVSA, type approval holders can modify base vehicles that are on the Register of Approved Vehicles (RAV) and base vehicles fitted with a Motor Vehicle Standards Act 1989 (MVSA) identification plate. 

SSM performed according to an approval granted under the MVSA can continue in accordance with the MVSA Identification Plate Approval (IPA) until 30 June 2022.

NOTE: MVSA approval holders cannot fit an identification plate to a base vehicle that has been added to the RAV.

Under RVSA, all motorhomes, either as an originally built motorhome or as a Second Stage of Manufacture (SSM) to a completed or base vehicle, provided to the Australian market for the first time must be entered into the Register of Approved Vehicles (RAV).  For a motorhome to be recorded in the RAV, Manufacturers and Importers must obtain a vehicle type approval for their vehicle type.  More information about importing motorhomes can be found HERE.

In the Guidance Note released by the Department, a road vehicle is considered to have been provided to a consumer for the first time when the following conditions have been met:

  • the vehicle has been correctly entered on the RAV, and
  • a contract of sale has been entered into by the consumer and an OEM or dealership.

IS A VEHICLE TYPE APPROVAL REQUIRED FOR EACH MODEL OF A VEHICLE?

No.  A vehicle type approval may be issued for a motorhome, either as an originally built motorhome or as a Second Stage of Manufacture (SSM) to a completed vehicle.  An application for a type approval for SSM can only be made using one (1) base vehicle.  Therefore, separate applications for SSM are required for each different base vehicle approval.

When completing an SSM application, you will be required to use a unique make and model combination different from the base and other approved vehicle types.

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.

APPLYING A NEW VEHICLE TYPE APPROVAL

To be eligible to apply for a new 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):

  1. The Manufacturer/ Importer is able to supply (provide) motorhomes which comply with all the applicable National Road Vehicle Standards – e.g. Australian Design Rules (ADRs);
  2. The Manufacturer/ Importer has control over all stages of the design, componentry and manufacturing process for the type of vehicle or is able to access information, including information about any changes, relating to the design, componentry and manufacturing process for the type of vehicle that may affect the compliance of the motorhome with the applicable ADRs;
  3. The Manufacturer/ Importer is able to ensure that the design, componentry and manufacturing process will consistently produce compliant motorhomes;
  4. 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
  5. 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 fees associated with obtaining a Vehicle Type Approval for a Motorhome and entry of motorhomes into the RAV are as follows:

  • Application Fee = $330
  • RAV Charge (per Vehicle) = $5.25
  • Variation of an RVSA Approval = $140

More information on fees and charges can be found HERE.

A video providing guidance on how to use a UN Approval in ROVER to demonstrate compliance with the ADR can be accessed in the Videos tab.

More information about SSM and vehicle type approvals can be found in the Department’s Vehicle Type Approvals webpage.

VEHICLE 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 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 vehicles supplied to market under the RVSA.

The SVI will appear in 2 different forms within Recreational Vehicle Industry manufacturing, depending on the type of vehicle.  For more information on these changes – CLICK HERE

WHAT CAN I DO NOW?

Two of the key elements to obtain 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 (ADRs)

Vehicle Type Approvals will cover all ADR-related aspects of the motorhome.  The Federal Department  have an ADR Applicability Summary for Good Vehicles (N Category) available on their webpage.  This ADR Applicability Summary is a useful reference document for manufacturers and importers in determining which ADRs apply to the motorhome they are providing to market.  To access the ADRs, click HERE.

Businesses will also need to consider which ADRs relate specifically to the type of motorhome being provided to market.

Evidence of Compliance with ADRs

The Vehicle Type Approval applicant must hold 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 Testing Facility. More information on Approved Testing Facilities can be found HERE.

For guidance on the ADRs and expected detail of evidence to support compliance relevant to motorhomes – CLICK HERE.

Vehicle 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 MVSA.

To implement these changes, Australian Design Rule 61/03 – Vehicle Marking has been updated to include the requirements for SVI as formal identification for new vehicles supplied to market under the RVSA.

The SVI will appear in 2 different forms within Recreational Vehicle Industry manufacturing, depending on the type of vehicle.  For more information on these changes – CLICK HERE

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 motorhomes 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.