C-Day for shonky caravan brands

According to the Caravan Industry Association of Australia (CIAA), the new Road Vehicle Standards Act (RVSA) which comes into effect on July 1 is the "biggest legislative change the Australian caravan industry has seen in over 30 years".

It's been years in the making, with the deadline repeatedly pushed back for the introduction of tougher compliance laws designed to improve both safety and quality of locally-made and imported caravans and camper trailers, not to mention reduce the number of 'lemon' vans built.

After July 1, the new laws will make it more difficult and costly for 'backyard' and shonky industry players to both operate and supply caravans that will be road registrable, with the current, much criticised 'self certification' process replaced by a more accountable, automotive-like process requiring more paperwork and attention to detail.

Basically, unless they're produced in extremely low numbers caravans and campers weighing up to 4500kg (ATM) will need to hold federal government approvals which will make them more easily traceable and searchable via a publicly accessible database, for product recalls and other safety reasons.

But despite numerous delays it's believed a significant number of the 200-odd RV builders and importers operating in Australia will not make the July 2023 cut-off for the new RVSA rules, resulting in a potential 'minefield' for buyers as the last of the 'self-certified' and potentially unregistrable caravans are sold off the showroom floors to unsuspecting buyers after July 1.

"It has been dragging on for a long time and our industry is not grateful for the delays," Gerard Waldron, the Melbourne boss of the Track Group which manufactures Pioneer, Track Trailer and Trakmaster campers and caravans, recently told caravancampingsales.

"It's given a free kick to the people who aren't doing the right thing, for another 12 months, and the (manufacturers and importers) who were doing the right thing were probably ready for it this time last year. It already had a 12 month transition period which then became two years..."

Waldron, who also sits on the CIAA board, said many major brands including the Track Group and New Age have been 'RVSA ready' for close to 12 months, with all 60-odd RVMAP-accredited brands required to be up-to-date by July 1.

He said some RV brands, most likely lesser known, low-volume manufacturers or smaller 'batch' importers of 'off-the-shelf' Chinese campers, will either flout the new rules or be forced to shut up shop after July 1.

"Some of them aren't going to do it at all; we know a few that have just said I've got the big order book from COVID and we're just going to deliver that and come June 30 we can just shut up shop. So I think there could be some grief around that," Waldron said.

He said the July 1 deadline also means "you won't be able to register a trailer that doesn't have a Type Approval (and) gone through the Government sign off... and that applies to anyone who's supplying more than four caravans or campers a year".

"Each Type approval is in the hundreds of dollars to put in the application but it's a much bigger thing than just about the vehicle," he explained.

"You've got to demonstrate that you've got control over the design and manufacture, and that means you submit details of your quality processes and (demonstrate) good traceability, of XYZ axles for example, so in the fullness of time it turns out there's a fault with them, it makes it easier to specify the vehicles which have those axles and locate them for the recall.

"The backyarders who are operating off the seat of their pants would be at quite a disadvantage in that environment. Do you really want someone who's not keeping (complete) records... building the van that you buy?

"Not everybody has the technical capability to do it and there are additional costs. Most of the majors if you like in this industry would have preferred that this was in a year ago, the people who were never going to comply have just been given another year to make hay..."

Waldron warned that getting a non-Type approved caravan that hasn't been registered by the dealer after July 1 could be problematic for buyers.

"The other really big issue that happens on July 1 is if it hasn't got a Type Approval the state road authorities won't register it because the process of registration requires you to submit the VIN number... which corresponds to a Type Approval number on the ROVER (database).

"It's possible that a number of dealers at the moment have a number of caravans in stock that don't have Type Approval, and so they either have to sell them now before July 1, or register them by June 30 and sell them as registered vehicles some time after that.

"Another option unlikely to be a popular one is to go back to the manufacturer and in the transition arrangements, the government would allow the manufacturer to nominate the VIN of an in-stock trailer for inclusion under the Type Approval... as long as the manufacturer is prepared to ensure it meets all the standards of the others."

"As it stands right now we have one dealer with one Tvan in stock who is in that situation.... (otherwise) we've been putting all our (Track) vehicle production under the RAV system for the best part of 12 months, and it's unusual for our dealers to have a van that's more than 12 months old in stock," Waldron said.

"After the date you certainly don't want to be buying a (non-Type approved) trailer that isn't registered. The concrete guarantee might be gone once you get it off the concrete! Because if you turn up to VicRoads or whatever to register it you'll be in big trouble, because most of the time the dealers are registering it for the customer.

"If you're buying it registered you're free and clear... (but you do have to ask) why isn't the RV a Type Approved vehicle when the industry has had at least two years to prepare?"

Worse-case scenario, according to Waldron, would be if a buyer puts a deposit down on a caravan only to discover when they pick it up from the dealer a few months later it's not on the RAV register and the dealer can't register it.

"No doubt the dealer would do what they can but they would have paid the supplier and been paid by the customer," he said. "Somebody would have to set about getting concessional approval. How long will it take? How much will it cost? Who will pay? What happens if it’s non compliant and can’t get approval?"

In most cases buyers should be able to identify a Type Approved caravan by a separate number on the build plate.

"There's also a publicly searchable register so you can put in the VIN number and see if it's included under the Type Approval," he said.

Industry consolidation inevitable

Waldron has been predicting for years that tougher regulations combined with high costs of local manufacturing will prove the downfall of many current RV brands operating in Australia.

"The extension of the RVSA deadline has probably given a lease on life to some manufacturers who should have already gone," he said.

"The ACCC is also starting to take a greater interest in recreational vehicles and there are a whole lot of consumer guarantees that are not in the Australian Design Rules area, so I put it to you if someone is not getting the engineering right the chance of them getting all the other areas right is not good."

"What's more all the electrical standards are just being updated at the moment to AS/NZS 3001, and some of them require a fair degree of sophistication to understand. If someone can't get get a compliant drawbar and test procedure sorted out, the chances of them wiring up your van safely are pretty slim as well.

"I think there has to be a consolidation of the industry; certainly the additional hoops that people are having to jump through are pushing up the overheads so to speak, and if you're too small how can you afford to cover those overheads?

"I think that will be good for the consumers as well. But I wouldn't see our industry ever consolidating down to the point there's only one manufacturer; there will always be a range of product even if it's from a much smaller number of manufacturers and importers."