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Gary Bailiff’s well-written article in the October
2005 edition of The Wanderer caused me to hasten research into an article
on this subject. Seemingly I was not alone, as virtually before I started,
the CMCA forwarded a letter to me from Colin Young, Executive Officer
of the Recreational Vehicle Manufacturers Association of Australia regarding
this very matter.
Rather than continue to produce what frankly would have been a less
authoritative article myself, the RVMAA has graciously allowed me to
edit and present Colin’s letter as a Tech Notes article. I am
presenting it in this manner as it raises very serious issues that
deserve wider exposure than in letter form. I have made a number of
changes. All have been seen and approved by the RVMAA. Some are simply
to bring the letter into article style. A few changes were deemed prudent
for legal reasons and in one matter (identified in the text) the RVMAA
provided anecdotal evidence of one seemingly very dubious business
practice. A few technical matters have been expanded.
Whilst the RVMAA clearly represents the interests of the Australian RV
manufacturing industry, it stresses that it is not opposed to RV imports.
My own experience is limited to inspecting various imported vehicles,
and correspondence with a substantial number of buyers.
It seems clear that many importers make every effort to ensure products
meet Australian Design Rules. But others equally clearly do not. Upon
measuring the overall width of one fifth wheeler, and finding it several
centimetres over the legally permitted maximum, the salesman told me
my steel tape measure was faulty. And, as the RVMAA points out, photographs
of some imported RVs provide visual evidence of noncompliance.
The Recreational Vehicle Manufacturers Association of Australia receives
a substantial number of communications from owners and potential owners
of imported vehicles stating that they cannot get ex-US motorhomes or
fifth-wheelers registered, or get the registration transferred. The main
concerns relate to serious non-compliance with ADRs (Australian Design
Rules) and/or other regulatory requirements such as the gas and electrical
appliances, or their installation.
The RVMAA strongly advises CMCA Members to think very seriously before
importing or buying an ex-US RV. Gary Bailiff’s quantified listing
of freight, duty, insurance, quarantine, air conditioning, refurbishing,
etc, etc, along with stressing the possible deterioration of the vehicles,
highlights important considerations when importing or buying.
The ‘15-year-old imports scheme’ has indeed been amended.
The age of permitted imports increases each year, hence the financial
viability of bringing in a probably high-mileage vehicle must be thoroughly
considered.
‘Commercial imports’ must be modified to comply with all
ADRs (Australian Design Rules) that were in force when the vehicle was
manufactured. While some ADRs are the same as the US FMVSS (Federal Motor
Vehicle Safety Standard) requirements, some are different and generally
more stringent. It can be very costly to modify these vehicles to comply
fully… if in fact they can be modified at all. On top of this
is the cost of obtaining an engineering certificate from an accredited
professional automotive engineer.
Vehicles newer than 15 years old can legally be imported under the ‘personal
imports’ scheme, if the vehicle owner is qualified to do so. This
requires proof that they have legitimately owned and used the vehicle
overseas for a continuous 12-month period. In such a case, the vehicle
does not have to demonstrate compliance with all ADRs, but it still must
be modified to comply with some ADRs and other regulatory requirements.
Here, despite the less-stringent requirements, it may not even be possible
to modify the vehicle, and in any event, the cost and time involved can
be considerable.
In all cases, it is imperative to obtain written quotes from professional
vehicle conversion companies in Australia before you consider buying
any vehicle overseas and importing it into Australia.
The RVMAA has certain knowledge of scams relating to ‘personal
imports’ schemes that purport to facilitate arrangements for Australians
travelling overseas and then ‘buying’ an RV that is subsequently
imported.
Before entering into any such ‘personal import’ arrangement
check with the Federal Department of Transport (Vehicle Imports) to confirm
that the compliance plate and vehicle import approval are legitimate.
Take this very seriously. The RVMAA states that a substantial number
of FORGED personal import compliance plates and vehicle import approvals
have been used to enable vehicles to be registered. The RVMAA provided
me with the actual details of one such scheme – but the specifics
cannot be revealed here - CR.
It is common knowledge in the industry that many people have been caught
unaware of what they were buying or importing, and have experienced major
financial problems with imported vehicles that do not comply with the
relevant ADRs and other Australian Standards. Photos of imported vehicles
that are for sale (and advertised in various magazines) clearly show
many that do not comply for various reasons, including that of dimensional
requirements.
An as yet unknown number of imported vehicles - both motorhomes and fifth-wheelers
- have been (incorrectly) registered in the first place. Some clearly
non-complying vehicles have been issued with engineering certificates.
Some clearly breach dimensional limits. Whilst these breaches were seemingly
not detected when the vehicles were presented for initial registration
there have been many cases within recent months when non-complying vehicles
were detected when registration was attempted to be transferred; this
is especially an issue if the registration transfer is to another State
or Territory. Such matters may well end up with ongoing legal battles
over who is legally liable in the event of a vehicle being deemed non-compliant
and subsequently unable to be used on the road.
The main non-compliance with some ex-US imports include:
• Too wide (over the permitted 2.5 metres)
• Too much rear over-hang (the maximum allowed is the lesser of
3.7 metres or 60% of the wheelbase)
• Not enough ground clearance (between the axles) and/or not enough
rear angle of departure (ground clearance).
• An entry door being on the right-hand side of the vehicle, and
not on the left- hand side - and also doors that (illegally) open inward.
• The right-hand-drive conversion not being in accordance with
VSB-6 (Vehicle Standards Bulletin No. 6) for vehicles over 4.5 tonne
GVM.
• Windscreens not having sufficient light transmittance (tinted
too heavily).
Some of the state vehicle registration (such as VicRoads & RTA VSI
{Vehicle Standard Information} legislation) is at:
• NSW: http://www.rta.nsw.gov.au/registration/downloads/vsi/vsi_dl1.html
VSI 05
• VIC: http://www.vicroads.vic.gov.au/vrne/vrne5nav.nsf/FirstChild/-EEC8092FE0E5
478FCA256FD300241C39 VSI 3, 5 & 23
All caravans and camper-trailers (manufactured since 1989) must comply
with VSB –1. This can be obtained from:
• http://www.dotars.gov.au/transreg/vsb/index.aspx (or simply by
entering VSB-1 in Google and ticking the ‘I feel lucky box’ -
CR).
VSB-1 dictates all of the ADRs and Australian Standards that these vehicles
must comply with. It covers carrying capacity, couplings, safety chains,
axles, suspensions, brakes, wheels, tyres, dimensional limits, mudguards,
and the extensive requirements for all of the lamps and reflectors.
All recreational vehicles must be safe. Just because imported vehicles
may comply with overseas regulations, there is no guarantee that they
will comply with Australian safety regulations. It is a highly contentious
topic as to why we do not have mutual-recognition with all overseas standards,
but it has to be remembered that there are some very valid reasons why
we have different and usually more stringent, requirements… particularly
in matters relating to gas and electricity.
Two vital safety areas that must be completely understood when considering
buying or importing an RV are whether all of the electrical and gas appliances – and
more importantly, their installations – comply with the Australian
Standards.
(That the vehicle is registered is seemingly no guarantee. One registered
fifth wheeler on the trade display at a CMCA Rally had a 240-volt system
that contravened Australian requirements in several major respects. Upon
querying this, the salesman stated he did not care and that - ‘it
passed rego mate’ - CR).
It is a requirement that a licensed electrician and a licensed gas fitter
must inspect and approve every RV. There has been a lot of concern regarding
the appliances and installation in imported recreational vehicles and
the local manufacturing industry has been worried that a disaster with
one of these units would be devastating for the industry. Most pleasingly,
State and Territory regulatory authorities are well aware of the concern
and are being most professional in ensuring that everything is being
done to ensure that the highest levels of safety are achieved.
The RVMAA does not oppose the importation of RVs, but it strongly recommends
that prospective buyers demand (preferably via a legally-binding document
- CR) that imports meet the same standards of safety as that required
of locally-made vehicles. As has been said many times before… when
it comes to buying or importing an RV: Buyer Beware!
The CMCA thanks Colin Young and the RVMAA for allowing their letter to
be edited and presented in this manner. Colin Young is a chartered professional
automotive engineer and quality auditor. He has extensive experience
in vehicle safety and ADR compliancing. His brother (Ian) is a Western
Australian Member of the CMCA.
For further information about the RVMAA – see www.rvmaa.com.au
Collyn Rivers W 8054
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