Context of the proposed changes

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 without compromising on safety.

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.

• Why we're proposing change
• Key changes being proposed
• Benefits of the proposed change
• Maintaining safety

Why we're proposing change

The LVV system applies to all modified or scratch-built vehicles produced in volumes of less than 500 per year, regardless of the process used or the quality controls in place for the modifications. The system applies equally to both hobbyist and commercial vehicle modifiers. 

Feedback from the modification industry has suggested that the current system, while appropriate for scratch-built and individually modified vehicles, is less suitable for the commercial modification environment.

Currently, to achieve certification, all stages of modification must be sighted by an LVV certifier who then certifies the vehicles at the end of production. Costs for commercial modifiers can therefore accumulate significantly and there can be delays in the process while an LVV certifier is commissioned to undertake inspections. 

Many vehicles commercially modified in New Zealand are modified in a factory-like setting, with strict processes and good quality controls in place, and are often built in a ‘series’ where multiple vehicles are built to the same design and process. As a result, they present a lower risk than individually-produced ‘one-off’ modifications. We are therefore proposing to provide an alternative method of obtaining certification for vehicles modified in these settings.

Overview of the proposed process for commercial, production-based vehicle modifications

Key changes being proposed

• A qualifying commercial modifier is appointed by the Transport Agency as an entity that can certify their own vehicles, provided that they have been built exactly to a type-approved design.
• An LVV certifier will certify the first vehicle produced.
• LVVTA will approve the design for use on subsequent vehicles and issue a type-approval number. 
• An LVV certifier will no longer be required to certify subsequent vehicles built to the type-approved design.

 Benefits of the proposed change

The benefits of providing an alternative certification system for commercial, production-based modifications include the following:

• Efficiency is increased as production can carry on continuously – there is no down-time in production while waiting for an LVV certifier to inspect each vehicle in stages. Stage inspections will be completed by the modifier.
• The cost of producing modified vehicles will be reduced as less LVV certifier involvement will be required.
• LVV plates will be able to be pre-issued to the modifier and fitted onsite, allowing vehicles to get on the road more quickly.

Maintaining safety

It’s important that a high standard of safety is maintained when commercial modifiers certify their vehicles. The proposed process includes a number of criteria and checks to ensure that high safety standards continue to be met.

• Commercial modifiers must meet a strict set of criteria in order to be eligible to certify, including the Transport Agency’s standard ‘fit and proper person’ requirements.
• Commercial modifiers must be appointed by the Transport Agency and will therefore be subject to requirements that ensure they perform to a high standard.
• Modifications will be made in a factory-like setting, allowing structured processes and quality controls to be in place.
• An externally-audited QMS system will ensure the production process has rigour and that good processes are being used.
• The requirement to sign off the build of each vehicle at key points ensures that rigorous production records will be kept, and that potential inconsistencies can be picked up early and corrected.
• The requirement to keep production records allows the Transport Agency to check previously built vehicles adhered to the approved design.
• Auditing by the Transport Agency will ensure that the described build processes and approved type design are being followed.

What are we seeking your feedback on?