The LVV certification system for scratch-built or modified vehicles has been in place since 1992. Recent customer feedback and experiences have prompted us to review the system to ensure it’s still fit for purpose, and to look for ways it could be improved.
We want the LVV system to be responsive to innovation, efficient and transparent. The system must uphold the safety of road users, while also providing a positive user experience for customers of the certification process. Feedback from the commercial sector dealing with low volume vehicles has suggested we could make improvements to the system to make it more suitable for them, encouraging innovation and economic growth.
As part of our review of the LVV system, we’re seeking to develop and implement tailored certification processes that reflect the risks associated with different types of modifications and the contexts of different type of modifiers.
All vehicles imported into New Zealand are inspected by entry certifiers before being issued a Warrant of Fitness (WoF) and registration to operate on New Zealand roads. This includes a check to confirm if the vehicle has had any modifications made to it after being produced by the original manufacturer. At present, if any post-production modifications are identified by the entry certifier, the vehicle must be further inspected by a Low Volume Vehicle (LVV) certifier to confirm that it complies with New Zealand’s standards for modified vehicles. This requirement is applied to all imported modified vehicles, regardless of any testing or approvals that may have been issued in the country it was modified in.
There are several overseas authorities that issue approvals to modified vehicles to confirm those vehicles have been inspected and/or tested and found to meet the required standards in their country. Often these standards are comparable to (or in some cases higher than) New Zealand’s standards. In many cases, the vehicles are modified in significant numbers in factory settings similar to those of original manufacturers.
Where such approvals have been issued by an overseas authority with comparable standards to our own, we think it shouldn’t be necessary to require further proof of vehicle safety by requiring LVV certification in New Zealand. In these cases, LVV certification adds cost and complexity to the importing process. We’re therefore proposing a process where the LVV certification requirement is removed from the entry process for vehicles that have been approved by certain overseas authorities.
Under the proposed process, all imported vehicles will continue to go through the entry certification process. If a modification is found to have been made after original manufacture and the vehicle’s documentation includes appropriate confirmation from an approved overseas authority that the modifications meet overseas standards, the vehicle will no longer be required to undergo LVV certification. A WoF and registration will be issued and the vehicle will be able to be used on New Zealand roads. No LVV plate will need to be attached to the vehicle, and an LVV certifier will not be involved in the process.
If a vehicle with modifications is imported from an overseas authority that has not been approved, or the importer cannot provide documentation to show that it has been approved to an acceptable standard overseas, the vehicle will still be required to undergo LVV certification, and follow the existing process.
Overview of the proposed process for importing modified vehicles
Key changes being proposed:
Under the proposed approach, overseas approvals will be added incrementally as we are able to research and approve them. The first overseas approval we propose accepting is European Community Whole Vehicle Type Approval (ECWVTA).
The ECWVTA framework governs the safety of vehicles in the European Community and is designed to cover a range of vehicle types, including series production vehicles and those that have been commercially modified. ECWVTA is a type approval system that involves independent testing and certification carried out by ‘technical services’ and ‘approval authorities’ approved by each member state. Technical services (normally commercial organisations such as Germany’s Technical Inspection Association [Technischer Überwachungsverein or TUV]) carry out testing and manufacturing plant audits and prepare documents. Approval authorities are government departments (such as the German Federal Motor Transport Authority [Kraftfahrt-Bundesamt or KBA]) who have overall responsibility for the process and grant the formal approval.
Given the widespread acceptance of ECWVTA, and because it is based on technical standards already accepted under New Zealand law, there is good reason to believe it would produce vehicles that are safe and appropriate for use in this country.
We are also researching the Japanese approval system to identify opportunities to apply the proposed process to vehicles imported from Japan. Currently vehicles imported from Japan with a Type Designation Number (TDN) are not required to go through LVV certification when entering New Zealand, but there may be other types of Japanese approval that could also be accepted. We expect this to be the second jurisdiction to which the proposed process could be applied.
Over time we will also consider other jurisdictions such as Australia, the United States and individual countries from within Europe, and approve them if appropriate.
The benefits of allowing imported modified vehicles with recognised overseas approval to be excluded from LVV certification are:
It’s important that the safety standards of vehicles on New Zealand roads are not reduced by any changes. The proposed changes will ensure safety standards are maintained, because evidence will be required to show that the imported vehicle has already met comparable safety standards in another country. If this evidence is not supplied, the vehicle will be required to undergo LVV certification.
Given the widespread acceptance of ECWVTA, and because it is based on technical standards already accepted under New Zealand law, there is good reason to believe it would produce vehicles that are safe and appropriate for use in this country.
Under ECWVTA, modified vehicles are required to comply to the greatest extent possible with the same standards applicable to full volume production vehicles. For the key standards (which are also those required by New Zealand law), full compliance — that is, full independent testing and certification — is required. This means that for many systems and components, multi-stage or modified vehicles are effectively the same as compliant full production vehicles.
The overseas authorities whose approvals we expect to accept under the proposed system are ones that have robust systems for setting vehicle standards, a well-established motor vehicle industry, and robust processes for testing and inspecting vehicles to ensure they meet standards.
Where a vehicle has already met recognised standards that are comparable to New Zealand’s, there should be no increased risk to removing the requirement for LVV certification.
| Submissions for this consultation have now closed. |
