If it isn’t broken…

In the MVSA Review Discussion Paper the government stated that the review was necessary to ensure that Australians had sufficient vehicle choice and competitive pricing, that there were appropriate levels of consumer protection and that community safety through the implementation of “international best practices” for vehicle safety standards was paramount.

Let’s look at these objectives in a little more detail, firstly vehicle choice. Australian consumers currently have the choice of 22 brands of heavy vehicles, supplied by 13 manufacturers or distributers directly representing the Original Equipment (vehicle) Manufacturer (OEM). We have the choice of trucks from Europe, America and a number of countries in Asia and when you consider that less than one third of all vehicles produced globally are right hand drive, our choice of models is greater than it possibly should be.

Next we have the issue of price. When you compare the very high specification levels that are demanded by Australian consumers and business operators, our safety requirements both through Federal regulation and State Occupational Health and Safety requirements, coupled with our unique operational (high GCM’s, multiple trailers, high average speeds) and our very hot climatic conditions, all of which require Australian unique design solutions and specifications, we actually have some of the most competitively priced new trucks found anywhere.

Considering the issue of consumer protection, current OEMs or their Australian agents are responsible for ensuring that the vehicles they sell are “fit-for-purpose”. That is, the truck will function reliably in our very hot climate, they have a suitable driveline and brake system for our high GCM and multi-trailer applications and they are backed by a national aftersales network of dealers, parts and service, etc. What level of protection will an independent importer of a used truck that was not designed for Australia offer to the consumer? What level of parts and service support will be offered by the importer? The independent importer simply cannot guarantee these required levels of functionality, reliability and support. It would be the consumer who will suffer.

Finally there is the issue of community safety to consider. Truck OEMs or their Australian agents are responsible for notification and implementation of vehicle safety recalls. How will the independent importer of a non-Australian specification truck be aware of, or conduct a safety recall if required? Equally the vehicle OEM, or their Australian agent, cannot be responsible for a safety recall on a vehicle that they did not import and sell. In fact, the OEM would not even know that such a vehicle had been imported and was operating in Australia. Another significant safety concern relates to what standards would apply to used and parallel new vehicle imports. If it is less than our current Australian Design Rules for new vehicles, then overall safety outcomes will be reduced. How could this be considered “international best practice”?

There is a simple question to ask here, “Is there a market failure with the existing system?” The Truck Industry Council (TIC) believes that the answer to this question is “no”, there is no current market failure. The existing MVSA regulatory framework gives the Australian consumer access to the combination of largest choice of truck brands (from Asia, Europe and the USA) at a level of safety, environmental and consumer protection not seen in ANY other country in the world.

TIC will continue to work with the Government as it reviews all areas of the MVSA. Further, TIC calls on the government to very carefully consider all aspects and ramifications of opening up Australia’s borders to large scale used or parallel new truck imports.

3As they say, if it isn’t broken…

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