STATEMENT RELATING TO REVISIONS OF GROSS COMBINATION MASS 23/10/2018

***STATEMENT RELATING TO REVISIONS OF GROSS COMBINATION MASS 23/10/2018***

On the 21st August 2018, the Queensland Government overturned Queensland Department of Transport and Main Road’s decision to release new Vehicle Modification Codes (LS11 and LS15), which were due for release to the industry on the 4th September 2018.

Changes in these Modification codes included the banning of:

• Towing Capacity Upgrades on in-service vehicles
• Axle capacity increases on in-service vehicles
• GVM Upgrades on in-service vehicles which had previously been upgraded by another jurisdiction/State and/or brand,
• GVM Upgrades on in-service vehicles which had previously had active SSM Approvals, which are no longer manufactured (eg. Nissan Patrol Y61 and Toyota Hilux KUN125/126).

At a Federal level, we can confirm the following which was uploaded to the RVCS website (Federal Dept of Transport and Infrastructure) on 3rd August 2018.

Of note in this, which is listed at the following https://infrastructure.gov.au/vehicles/compliance_and_enforcement/compliance_update/2018/rvcu-2018-August-issue-3.aspx

Administrator's Circular 0-4-6 (Issue 4 June 2018)

Administrator's Circular 0-4-6 (Certification of vehicles which have undergone a second stage of manufacture) was amended in June 2018 following industry consultation. The circular was amended to include arrangements for Second Stage Manufacture (SSM) Light Vehicles that have been subject to a Gross Vehicle Mass (GVM) upgrade under Clause 10—and formalise current business practice for GVM upgrades to light vehicles.

Of note:

• The guidance provided by the Circular 0-4-6 applies to NA (GVM up to 3.5 tonnes) and NB1 (GVM over 3.5 tonnes and up to 4.5 tonnes) category vehicles.
• The revised circular only applies to new applications and new amendments to existing Identification Plate Approvals (IPAs).
• The Circular will not affect the existing IPAs held by the second stage manufacturers. Existing IPA holders can continue to supply (to the market) vehicles covered by the approved Road Vehicle Descriptors (RVDs). This includes vehicles where the approved RVD has variants that exceed the first stage manufacturer's Gross Combination Mass (GCM) rating or Rated Towing Capacity or Maximum Braked Towing Mass rating. The second stage manufacturers need to ensure that the current approved RVDs refer to the current approved RVDs for the first stage manufacturer.
• The option of GCM or towing capacity upgrade may be available to consumers in some state and territory jurisdictions, after the vehicle is supplied to the market.

 

The Federal Legislation, or superior legislation, is known as Vehicle Standard (Australian Design Rule – Definitions and Vehicle Categories) 2005.  The relevant definitions under the ADR:

"MANUFACTURER - the name of the person or company who accepts responsibility for compliance with the Australian Design Rules and to whom the ‘Compliance Plate’ approval certificate is issued."
"GROSS COMBINATION MASS - value specified for the vehicle by the ‘Manufacturer’ as being the maximum of the sum of the ‘Gross Vehicle Mass’ of the drawing vehicle plus the sum of the ‘Axle Loads’ of any vehicle capable of being drawn as a trailer."

 

From these definitions the Manufacturer is Lovells Springs Pty Ltd because that is the company that accepts responsibility for compliance with the ADR and to whom the compliance plate approval certificate is issued.  Considering the definition of GCM, the Manufacturer Lovells can specify the GCM as being the maximum of the GVM plus the axel loads of the trailer.

TMR QLD publicise the below policy in relation to GCM revisions.  This policy is called the Queensland Code of Practice, Vehicle Modifications Version 3, February 2018.  Page 58, paragraph 5.2 and the relevant excerpt from this policy is below

"5.2 Gross Combination Mass Rating & Towing Capacity

This code does not permit an increase in rated towing capacity or GCM rating (unless in accordance with an SSM approval). For some light vehicles rated towing capacity or GCM rating may not be specified. In such cases please note that the maximum towing mass at GVM must be proportionately reduced to ensure that the sum of GVM and maximum towing mass at GVM before and after GVM upgrade remains unchanged."

The Federal body The Department of Infrastructure, Regional Development and Cities (DIRDC) is the national governing body.  DIRDC published an amendment to Circular 0-4-6 dated June 2018.  Paragraph 10.6 says:

"The towing capacity of a light vehicle expressed as Gross Combination Mass (GCM) rating or Rated Towing Capacity or Maximum Braked Towing Mass rating must not exceed the value set by the first stage manufacturer. Second stage manufacturers are not permitted to increase the towing capacity as part of an SSM IPA that results in GVM upgrade."

 

DIRDC soon after published a Clarification to Amendment to Circular 0-4-6 which was updated on 2 July 2018:

"The Circular will not affect the existing IPAs held by the second stage manufacturers. Existing IPA holders can continue to supply to the market vehicles covered by the approved Road Vehicle Descriptors (RVDs). This includes vehicles where the approved RVD has variants that exceed the first stage manufacturer’s Gross Combination Mass (GCM) rating or Rated Towing Capacity or Maximum Braked Towing Mass rating."

 

This clarification clearly shows that we can continue to supply vehicles covered by the approved RVDs.  This is for GVM and BTC upgrades as described on the RVD1 passenger category vehicles.

The clarification also states “this includes where the approved RVD has variants that exceed the first stage manufacturer’s GCM or BTM”.  In considering the information on the RVD it is important to note that there are no ADR rules requiring a GCM value to be provided (for this category vehicle), is not a requirement on the RVD1 form and is not on the OEM vehicle’s compliance plate.

See below Lovells approvals extracted from the official Lovells Owners Manual which is issued to SSM upgrade end users (pre-registration/Federal Compliance) and post-registration (State Compliance);

LOVELLS GROSS VEHICLE MASS (GVM) UPGRADE CAPACITY and GROSS COMBINED MASS (GCM) CAPACITY GUIDE

• CPA 25742, Toyota Landcruiser LC70 Cab Chassis (Single & Dual Cab)/Troop Carrier to 3900kg. (Original GVM is 3300kg)- GCM=7400kg (minus ball weight of towed apparatus)- RVD LSLCCC15
• CPA 25742, Toyota Landcruiser LC79 Cab Chassis 2dr Single Cab 5 Star ANCAP to 4200kg. (Original GVM is 3400kg)- GCM=7700kg(minus ball weight of towed apparatus)- RVD LCCC42_5
• CPA 25742, Toyota Landcruiser LC79 Cab Chassis 4dr Dual Cab MY18 to 4200kg. (Original GVM is 3400kg)- GCM=6900kg as per O.E. (minus ball weight of towed apparatus)- RVD LSLC4D3
• CPA 25742-8 Toyota Landcruiser LC76 Series 4 door Wagon to 3660kg. (Original GVM is 3000kg)- GCM=7160kg (minus ball weight of towed apparatus)- RVD LSLC76H
• CPA 28971 Nissan Patrol Cab Chassis Y61 to 3900kg. (Original GVM is 3400kg)- STATE COMPLIANCE ONLY- RVD LCNPD
• CPA 40257 Toyota Landcruiser 200 Series Wagon to 3800kg (Original GVM is 3300kg)- GCM=7300kg (minus ball weight of towed apparatus)- RVD LS200_1a (PETROL)  RVD LS200_2a (DIESEL)
• CPA 40257 Toyota Landcruiser 200 Series Wagon to 4000kg (Original GVM is 3300kg)- GCM=7500kg (minus ball weight of towed apparatus)- RVD LS200_6 (DIESEL)   RVD LS200_5 (PETROL)
• CPA 40257 Toyota Landcruiser 200 Series Wagon to 3800kg (Original GVM is 3300kg) with 4000kg BTC Upgrade- GCM=7800kg (minus ball weight of towed apparatus)- RVD LS200_4a (DIESEL)   RVD LS200_3a (PETROL)
• CPA 46734 Toyota Landcruiser 200 Series Commercial Wagon to 3800kg (Original GVM is 3300kg) with 4000kg BTC Upgrade- GCM=7800kg (minus ball weight of towed apparatus)- RVD LS20LCO5
• CPA 46734 Toyota Landcruiser 200 Series Commercial Wagon to 4000kg (Original GVM is 3300kg)- GCM=7500kg (minus ball weight of towed apparatus)- RVD LS20LCO6
• CPA 42029 Toyota Hilux 150 Series 4x4 3/05-2015 to 3300kg (up from standard GVM of 2710kg- Extra Cab, 2780kg- Dual Cab and 2835kg- Single Cab)- STATE COMPLIANCE ONLY- RVD LSHLX_E2
• CPA 46728 Ford Ranger 4x4 to 3500kg. (Original GVM is 3200kg).- GCM=7000kg (minus ball weight of towed apparatus)- RVD LSFR15a (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 46728 Ford Ranger PXII 4x2 Hi-Rider to 3500kg. (Original GVM is 3200kg). GCM=7000kg (minus ball weight of towed apparatus)- RVD LSFR21a (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 47037 Mazda BT50 4x4 to 3500kg. (Original GVM is 3200kg). - GCM=7000kg (minus ball weight of towed apparatus)- RVD LSMBT15b (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 47037 Mazda BT50 4x2 Hi-Rider to 3500kg. (Original GVM is 3200kg). - GCM=7000kg (minus ball weight of towed apparatus)- RVD LSMBT21a (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 47909 Toyota Hilux GUN126 Series 4x4 2015 on to 3500kg (Original GVM of 3000kg)- GCM=7000kg (minus ball weight of towed apparatus)- RVD LSTH8_1b (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 47909 Toyota Hilux GUN126 Series 4x2 Hi-Rider 2015 on to 3500kg (Original GVM of 3000kg)- GCM=7000kg (minus ball weight of towed apparatus)- RVD LSTH21 (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 48580 Isuzu D Max 4x4 06/12 on to 3600kg (Original GVM of 2950kg)- GCM=7000kg (minus ball weight of towed apparatus)- RVD LSIDM1 (MULTIPLE RVD’s FOR DIFFERENT BODY CONFIGURATIONS)
• CPA 48580 Isuzu D Max 4x2 06/12 on to 3600kg (Original GVM of 2950kg)- GCM=7000kg (minus ball weight of towed apparatus)- RVD LSIDM6b
• CPA 48305 Toyota Prado 150 Series 10/09 on to 3500kg (Original GVM of 3000kg)- GCM=6000kg (minus ball weight of towed apparatus)- RVD LSLP1
• CPA 48305 Toyota Prado 150 Series 10/09 on to 3500kg (Original GVM of 3000kg)- with 3100kg BTC Upgrade- GCM=6550kg (minus ball weight of towed apparatus)- RVD LSLP2