The approval process for towable recreational vehicles of 4.5 tonnes ATM or less
Low ATM trailers under the Road Vehicle Standards Act
Under the RVSA, all low ATM trailers, towable recreational vehicles with an aggregate trailer mass of 4.5 tonnes or less, provided to the Australian market for the first time must be entered into the Register of Approved Vehicles. For a low ATM trailer to be recorded in the RAV, manufacturers and importers providing more than four trailers to the Australian market must obtain a vehicle type approval for their trailer type.
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:
No. Vehicle type approvals are based on the Vehicle Category Codes as defined in the Australian Design Rules. Multiple models of the same code are covered by one approval. Low ATM trailers are based on the gross trailer mass of the vehicle.
Vehicle category codes for trailers
All applications for approvals are managed through ROVER, the Road Vehicle Regulator, which is the Department’s administration system for the Road Vehicle Standards Act 2018. ROVER provides a single integrated system for all approvals and activities under the Road Vehicle Standards legislation, allowing you to:
The 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.
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 in ROVER section.
A video providing guidance on how to complete a vehicle type approval for a low ATM trailer and how to add design and manufacturing facilities within ROVER can be found under Videos.
Further information about ROVER, including how to create an account, can be found on the Department’s ROVER resources page.
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 vehicle type approval applicant must retain all relevant information to support their application.
More information on fees and charges can be found in the Department’s fees and charges document. 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.
Two of the key elements to obtaining a vehicle type approval are to demonstrate compliance to the relevant ADRs and conformity of production. Both of these elements will need to be completed before you can finalise 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.
Vehicle type approvals will cover all ADR-related aspects of the towable recreational vehicle. The Department has an ADR Applicability Summary for Trailers available on its website. 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.
The vehicle type approval applicant must have evidence in place demonstrating compliance to the relevant ADRs. All relevant documentation and 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, for example strength requirements and light intensity, will need to come from an approved testing facility. More information can be found on our Approved Testing Facilities page.
For guidance on the ADRs and expected detail of evidence to support compliance relevant to towable recreational vehicles, see ADRs Relevant to Towables.
The RVSA introduces a requirement for new vehicles to carry a Secure Vehicle Identification marking. This replaces the previous identification plate requirements of the Motor Vehicle Standards Act.
To implement these changes, Australian Design Rule 61, Vehicle Marking, has been updated to include the requirements for Secure Vehicle Identification as formal identification for new trailers supplied to market under the RVSA. For more information, see the the Department’s guidance on ADR 61/03, Vehicle Marking.
Based on the Vehicle Category Code that the applicant has selected, ROVER will filter and identify the relevant ADRs applicable for that code. The applicant will then identify which ADRs are applicable and the extent of compliance that their low ATM trailers have with these ADRs.
There are instances where a trailer product does not 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, for example not applicable or 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.
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 the low ATM trailers you are producing or supplying. In other words, you will need to have some form of Quality Management System in place to demonstrate that you have effective control on conformity of production.
Departmental guidance material on Quality Management System requirements can be found on the Department’s QMS page.
Applicants may choose to withdraw an application for any reason, and do not need to give a reason for the withdrawal. Sometimes, rather than refusing, or refusing to consider, an application, the assessor will suggest the applicant withdraw, amend and strengthen their application by including additional information or supporting documentation.
It is up to the applicant whether they wish to:
To know how to withdraw, amend, resubmit and delete an application in ROVER, see the Department’s the Department’s guidance material.
You may request to withdraw an application with a status of Paid, awaiting assessment, or Assessment in progress, in your ROVER portal.
The critical points after which your application cannot be withdrawn are:
When the Department receives notice to withdraw an application that has not already been decided, it will:
When the status of the application is updated to withdrawn, the applicant or authorised user may either:
If an amended application is submitted, the timeframe to decide the application will start again, as it is considered a new application.
Under section 72 of the Road Vehicle Standards Act 2018, the delegated decision-maker may refund the whole or part of an application fee if they are satisfied there are circumstances justifying the refund.
However, section 230(A)(3) of the Rules provides that any fees paid for a withdrawn application are not refundable if the Department had begun considering the application before it was withdrawn. It is therefore not expected that the relevant application fee will be refunded in many cases.
To request a refund, contact the Department using the online enquiry form and explain in detail the circumstances that would justify refund action.
