Caravan and motorhome compliance

Caravan and Motorhome Compliance

Caravan and Motorhome Compliance is written by the Caravan Council of Australia (CCA). It is published here with the CCA’s permission. It relates to RVs of all types. Similar requirements apply to boat-trailers and horse-floats. See also Imported RVs.

Note: This information is still (late 2020) mostly current but will change once the new Road Rules come into effect – probably in 2024.

Caravan and Motorhome Compliance

‘Is your camper trailer, caravan or motorhome fully compliant? Many are not, especially American fifth-wheeler and motorhomes imports.

‘It has been proven many times that declarations of compliance on many imports have been false. The Australian Federal Government even warned against this. In such cases, severe penalties can apply.

‘Many manufacturers, importers and ‘facilitators’ have been able to get away with this. When legal actions are instigated against them, or one of their vehicles is involved in an accident, serious repercussions inevitably occur. This is especially if they lead to a coroner’s enquiry. In such cases, lawyers and engineers dig deep to expose the truth.’

Motor vehicles & over 4.5 tonne trailers

‘A motor vehicle or a trailer over 4.5 tonnes will have a Compliance Plate. It is issued by the Federal Vehicle Safety Standards (VSS). The plate confirms the vehicle conforms with all applicable Design Rules. Also, that is been inspected and approved by VSS. That organisation will then probably inspect one of the subject vehicles. This is to confirm that the evidence accurately matches the vehicle’s description and specifications.

Caravans & trailers under 4.5 tonne.

‘Self-certification is currently (2020) permitted for caravans and trailers under 4.5 tonne ATM Rating. The manufacturer or importer provides a declaration on the VIN/ Trailer/Compliance Plate, that the vehicle complies with the Motor Vehicle Standards Act 1989.

‘Since that 1989 Act became legislated, all caravans and camper-trailers have been required to have a valid Trailer Plate securely affixed. As with motor vehicles, buyers and owners expect that all information on the Plate is true and correct. In many instances, this has not been the case.

Plate requirements

‘The Plate is legally required to show the following information:

• Manufacturer’s or Importer’s Name:
• Trailer Model:
• Vehicle Identification Number (17-digit):
• Date of Manufacture:
• Aggregate Trailer Mass Rating:
• The Certification Statement: ‘This trailer was manufactured to comply with the Motor Vehicle Standards Act 1989’
• Often the legally-required Tyre Placard is also included and possibly other information. Three of the items required on the Tyre Placard are:  the manufacturer’s recommended tyre size: (without mentioning brand names)
• Tyre load rating
• Speed rating
• All information on the Plate, or otherwise supplied to the public, must be true and correct for that specific vehicle.
• In Australian Consumer Law became uniform legislation. The term ‘Merchantable quality’ later became up-graded to ‘Acceptable quality’. ‘Fit for purpose’ is the main consideration when issues arise. Honesty and ‘duty of care’ are also prime considerations.

VSB-1 (Vehicle Standards Bulletin No: 1) is the legal instrument that prescribes the legal requirements for caravans and trailers (under 4.5 tonne ATM Rating). This can be downloaded from https://www.infrastructure.gov.au/infrastructure-transport-vehicles/vehicles/vehicle-design-regulation/rvs/bulletins/vsb1

Ratings and masses

‘The biggest issue that leads to complaints and litigation is Ratings and Masses. This especially relates to the load-carrying capacity’ (maximum legal pay-load) of the vehicle.

Caravan Ratings – reproduced by express permission of the Caravan Council of Australia.

The ‘Tare Mass’ is legally the measured (not estimated) mass of the vehicle as it leaves the factory. The water tanks and gas cylinders are empty. All equipment and accessories that were stated on the Purchase Contract must be included. Tare Mass is not legally required to be stated on the Plate. There is, however, a strong case for being a critical duty-of-care responsibility of the vendor.

ATM

‘The Aggregate Trailer Mass defines the maximum that the trailer may legally weigh on-road. The load-carrying capacity is thus the ATM Rating minus the Tare Mass. Many complaints relate to the actual Tare Mass being significantly more than is the stated Tare Mass. Problems have arisen because dealers or owners have added equipment and accessories later, without requiring the Tare Mass being up-dated.

It is al-but vital for buyers to weigh a newly-purchased caravan or camper-trailer (new or second-hand) – to confirm the actual Tare Mass, at a certified weigh-bridge. The (empty trailer’s) ball-loading should also be accurately measured.

GTM rating

‘The GTM Rating is the maximum weight of the fully-loaded trailer that may be imposed on the trailer’s axle when it is coupled to the tow vehicle. It is thus the ATM minus the mass carried by the tow ball. The GTM is not legally required to be stated on the Plate. Despite that, some ADRs (and unique state requirements) depend on the GTM Rating. This especially applies to braking requirements above and below 2000 kg (4400 lb) of the GTM Rating. The ratings of the wheels, tyres, axle(s) and suspension must all be equal to, or greater than, the GTM Rating. It is important to note that the GTM Rating has no bearing on the ball-loading.

Other important compliance items

• Ratings and method of attachment of the coupling and the safety chains
• Braking system
• Lamps and reflectors
• Electrical wiring between the vehicle and the tow-vehicle
• Vehicle dimensions… length, width, height, rear-overhang.

‘The most critical – and potentially lethal (if not correct) – internal safety items are the electrical and gas appliances and installations.

‘These must be in strict accordance with the appropriate Australian Standards. There have been a number of cases where appliances and installations – both electrical and gas – have not been approved to Australian requirements. Some states/territories may have different interpretations and requirements. The way to best ensure full compliance is to obtain certificates from licensed electricians and gas fitters.

‘Lights and reflectors have a number of legal requirements. Each has to be designed for its particular function: e.g. a generic red light cannot be used for the rear position, end-outline, and stoplights; different lamps and reflectors have different fields-of-view (horizontally and vertically) and different maximum and minimum light intensities.

Caravan and motorhome compliance – E-mark & CRN

‘There have been numerous cases of cheap non-compliant lights being used on caravans and camper-trailers offered for sale in Australia. Those approved have either an E-mark or a CRN (see below).

• An E-mark (E for Europe) is used on many vehicle components used internationally. The mark consists of a capital ‘E’, with a small sub-script number (inside a circle) and with the approval number embossed in the plastic. Lights and reflectors that are sold only in Australia, may have an E-mark. They are however required to have a CRN (Component Registration Number). This is issued by the VSS after proof-of-compliance is provided. Such lights and reflectors must have unique identification markings so that they can be cross-referenced to the specific CRN.
• Lights and reflectors must be oriented correctly, especially front and rear reflectors (in a side view). The prescribed number of lights and reflectors must be fitted, and they must be in the specified positions. While lights and reflectors may not be as critical as brakes, couplings and tyres, they are still an important road-safety item’.

Further information

Caravan and motorhome compliance is also covered in my articles: Imported RVs, Imported RV Electrics. It is also covered in my books Caravan & Motorhome Book, Caravan & Motorhome Electrics, and the Camper Trailer Book

The full list of requirements is at:

http://media.wix.com/ugd/74afe1_3005c62231b8dbb46ad5ce8efe57bce5