Updated 28 May 2017
Caravan and motor home compliance can confuse – imports are often not 100% compliant. This article shows what is required.
Caravan and motor home compliance is rarely an issue with locally-made product. There often is however with imported caravans. This is particularly fifth wheelers from 2002-2008) There can also be problems with private imports. They may legally be used but only by the original buyer. That buyer often truly (but wrongly) believes them to be 100% compliant. They must not be sold, nor even given away, unless brought to 100% compliance.
‘ Caravan and Motor Home Compliance ‘ is written by the Caravan Council of Australia (CCA). It is published here with the CCA’s permission. It primarily relates to RVs of all types: similar requirements however apply to boat-trailers and horse-floats. See also Imported RVs.
‘Is your camper trailer, caravan or motor home fully compliant? Many are not, especially North American fifth-wheeler and motor homes 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). Severe penalties can apply in such cases.
‘Many manufacturers, importers and ‘facilitators’, have been able to get away with such practices. When legal actions are instigated against them, however, or one of their vehicles is involved in an accident, serious repercussions inevitably occur. This is especially if they lead to a coronial enquiry. In such cases, lawyers and their diligent engineers will dig deep, to best ensure truth is exposed.
Caravan and motor home compliance – motor vehicles & over 4.5 tonne trailers
‘When you buy a motor vehicle – or a trailer over 4.5 tonne ATM Rating – it will have a Compliance Plate fitted to it. This is issued by the Federal Vehicle Safety Standards (formerly referred to as DOTARS). This means that complete proof-of-compliance with all applicable ADRs (Australian Design Rules) has been submitted to VSS for their engineering inspection and subsequent approval. VSS will then have probably conducted a SUTI (Single Uniform Type Inspection) on one of the subject vehicles. This is to confirm that the evidence does, in fact, accurately match the vehicle description and specifications.
Caravan and motor home compliance – caravans & trailers under 4.5 tonne.
‘For caravans and trailers under 4.5 tonne ATM Rating, industry self-certification is permitted. 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. Sadly, in many instances, this has not been the case.
Caravan and motor home compliance – 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. Many owner/buyers have not been aware of the consumer-protection provided by the Trade Practices Act until January 2011, when the Australian Consumer Law became uniform legislation.
The term ‘Merchantable quality’ later became up-graded to ‘Acceptable quality’. ‘Fit for purpose’ is a 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 down-loaded from http://www.infrastructure.gov.au/roads/vehicle_regulation/bulletin/ index. aspx
Caravan and motor home compliance – 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.
‘The ‘Tare Mass’ is 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. One would certainly argue that, providing this figure (in writing), it is a critical duty-of-care responsibility of the vendor.
Caravan and motor home compliance – 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 Plate to be up-dated with the true Tare Mass.‘It is prudent for buyers to weigh a newly-purchased caravan or camper-trailer – both new and second-hand – to confirm the actual Tare Mass, at a certified weigh-bridge. The (empty trailer’s) ball-loading should also be accurately measured.
Caravan and motor home compliance – 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, even though some ADR (and unique State) requirements depend on the GTM Rating. This especially applies to braking requirements above and below 2000 kg 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 whatsoever on the ball-loading.
Caravan and motor home compliance – 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 stop lights; different lamps and reflectors have different fields-of-view (horizontally and vertically) and different maximum and minimum light intensities.
Caravan and motor home 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).
- E-marks (E for Europe) are used on many automotive components that are 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) that is issued by 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’.
The Caravan Council of Australia
The Caravan Council of Australia has free, no-obligation, compliance, quality and assessment documents down-loadable from its website (www.caravancouncil.com.au).
The CCA also provides free, no-obligation, consultations on compliance, technical and safety issues. It endeavours to use mediation to resolve these problems, thus trying to avoid messy and costly legal actions.
If professional assistance – vehicle inspections or technical reports – are required, CCA-accredited engineers or technicians may be engaged to assist moderate commercial rates however, there is no obligation to do so. Manufacturers and importers can freely use the Compliance Audit and Quality Assessment check-lists for in-house evaluations, and likewise, may engage any professional person to assist them.
Caravan and motor home compliance – further information
Caravan and motor home 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: