Secure identification $0.266 $0.000 $0.000 $0.266 RAWS, personal imports scheme and letter of compliance Plate removal -$1.190 $0.000 -$0.185 -$1.375 Online database $0.000 $0.000 $0.000 $0.000 Cost offset Not Applicable Not Applicable Not Applicable $0.00 Total by Sector -$14.317 $0 -$0.185 -$14.502 Are all new costs offset? Yes, costs are offset No, costs are not offset Deregulatory, no offsets required
Benefits Streamlined internal processes resulting in more efficient administration of the regulation. Consumers Billable vehicle verification directly passed on to consumers while regulatory savings are not. Benefits Increased clarity for import decisions as regulatory processes are simple, streamlined and clear. Increased range and availability of specialist vehicles. Community Costs Nil Benefits Increased encouragement for the uptake of lower emission vehicles The table below shows the itemised costs for consolidating all the concessional schemes. The regulatory costs identified in the below table reflect the average cost borne by businesses and individuals per year, averaged over a ten year period. Change in costs ($million) Business Community organisations Individuals change in cost Streamline number of schemes -$0.258 $0.000 -$0.565 -$0.824 Change SEVs criteria -$0.004 $0.000 $0.000 -$0.004 Modification (compliance with ADRs, left to conversions, tyres and catalytic converters) -$5.028 $0.000 $0.000 -$5.028 Approved Vehicle Verifier $1.405 $0.000 $0.000 $1.405 Model report -$0.315 $0.000 $0.000 -$0.315 Application to become a RAW -$0.014 $0.000 $0.000 -$0.014 RAWS renewal -$0.006 $0.000 $0.000 -$0.006
Appendix F – Summary of key stakeholder positions in response to the 2014 Options Discussion Paper Organisation Modernisation and strengthening Harmonisation Personally imported new vehicles Specialist and enthusiast vehicles, concessional schemes Australian Automotive Dealers Association Supports modernisation to improve its clarity, links with other related legislation and provide the best practice administration of the regulatory framework. Need for increased flexibility. Supports the retention of the current practice for harmonising the Australian Design Rules. Opposes personal importation of new vehicles. Cites concerns about parts, warranty, safety recalls, provenance, safety and environmental standard of aging fleet, suitability for Australian conditions, information asymmetry and scope for organised crime. Australian fuel quality is not suitable for overseas vehicles. Supports changes to strengthen the management, compliance and enforcement of Registered Automotive Workshop Scheme and the Register of Specialist and Enthusiast Vehicles.
Dealer Group Against Used Car Imports Supports initiatives to update the Act to remove administrative complications, improve definitional clarity, improve linkages with other relevant legislation and remove any duplication in information collection. Supports the gradual aligning of Australian Design Rules with UN automotive standards regulations where appropriate and acceptable to Australian standards of safety. Opposes any change to existing guidelines on imported vehicles. Cites concerns about the impact on the dealership network, safety and consumer protection. Supports consideration being given to the reduction in the number of individual schemes through which a second-hand vehicle can be imported provided the objects of the Act are maintained. Australian Holden Dealer Council Supports modernising and strengthening the legislation. N/A Opposes personal imports. Cites concerns about vehicle fit for purpose, and consumer protection. N/A
Australian Trucking Association Supports preventing individual state vehicle regulation. However, the foundations of the Act appear sound and thus do not appear to demand substantial revision. Neutral. Consider possible adoption of other appropriate vehicle standards in the world. Neutral. It seems reasonable to reduce barriers to importation of new and or second hand vehicles but there must continue to be ‘obligations’ on importers. N/A National Heavy Vehicle Regulator Supports improving the clarification of a number of areas and strengthening the operation of the Act. Supports adopting the UN regulations as standard and maintain the capacity to allow for variations for unique operating conditions either through continued use of Australian Design Rules or by increasing powers within Heavy Vehicle National Law. Opposes personal importation of vehicles as heavy vehicle differences between US, Japan and the EU (e.g. width) make this difficult without wider change to standards (Australian Design Rules and infrastructure limits). Supports improvements in relation to the importation of special vehicles.
/ Caravan Industry Association of Australia Supports increased powers of the Minister to implement a new regime of increased penalties for Neutral. Should be more inclusion of the recreational vehicle industry in this process and its impacts. N/A Supports increased certification requirements for trailers less than 4.5 tonnes for vehicles both manufactured locally and imported. Supports replacing the current provisions for trailers between and 4.5 tonnes with an inspection based verification scheme. Supports the introduction of a approach. Registered Automotive Workshop Association Supports mandatory use of national standards through all states and territories. Supports continuance of the current practice for harmonising Australian Design Rules. Supports personal importation of new and used vehicles to increase competition in vehicle prices will put younger drivers in safer cars. Supports deregulation and reduction of compliance and current legislation lags vehicle technology. compliance.
and Parts Australian Motor Industry Federation and Motor Trades Association of Australia Supports initiatives to reduce regulatory compliance provided these do not increase community risk. Supports harmonisation of Australian Design Rules with international standards. Opposes personal importation of new and used vehicles. Supports changes to enhance the Register of Specialist and Enthusiast Vehicles and Registered Automotive Workshops and streamline Australian Automotive Aftermarket Association Supports changes to reduce administrative complexities, improve definitional clarity, improve the linkages with relevant legislation and remove any duplication in information collection. Supports harmonisation with international standards. Supports personal importation of new and used vehicles. The market for repair, service and parts will respond. Supports the consolidation of concession scheme arrangements.
Australian Automobile Association N/A Supports the alignment of Australia’s national vehicle standards for light vehicles with those of the United Nations. Supports reducing the restrictions on the personal importation of new vehicles to increase competition and affordability provided vehicles comply with standards that have been deemed comparable to Australian standards. Supports restrictions on the number of vehicles imported per individual and vehicle mileage. Supports updating the evidence requirements for the Specialist and Enthusiast Vehicles. Supports the eligibility requirements proposed for the Register of Specialist and Enthusiast Vehicles relating to high performance, environmental performance, mobility and rarity. Choice N/A N/A Supports personal importation of new and quality used imports. N/A Insurance Council of Australia N/A N/A Neutral. Personal importation may have a considerable impact on the insurance industry. N/A Insurance Australia Group N/A N/A Supports new personal importation provided are appropriate safeguards in place for consumer protection. N/A
National Motor Vehicle Theft Reduction Council N/A N/A Opposes personal importation as insufficient network of information on overseas vehicles will give critical mass for organised crime. N/A Shannons N/A N/A Supports the proposed introduction of a personally imported new vehicle scheme in 2018 and facilitate the insurance of personally imported vehicles. Supports a review of the importation of enthusiast or collector vehicles. Supports changes to a rolling 25 year rule and strongly recommends introducing this change as soon as possible. N/A Supports aligning of Australian Design Rules but acknowledge different needs in different regions/nation states. Opposes personal importation due to the potential for less safe vehicles to the Australian market. N/A
Fleet, and Australian Fleet Lessors Association N/A N/A Opposes personal importation due to the potential devaluation of the existing vehicle fleet and concerns about consumer protection and vehicle fit for purpose. N/A National Automotive Leasing and Salary Packaging Association N/A N/A Opposes in removing existing barriers to personal imports (new and used) as the consumer risks outweigh the benefits. N/A Australian Fleet Management Association Supports modernising and strengthening the Act, Australian Consumer Law is not sufficient and the reforms should strengthen lemon laws. Support Unique additions imposed by the Australian Design Rules are problematic. Supports personal importation of new vehicles provided they are built to UN or equivalent specifications. N/A