Mitsubishi Motors Australia Limited (Mitsubishi) says the Australian government should consider reforming the Australian Type Approval and Australian Design Rule (ADR) processes to maximise benefit to new car buyers as well as the environment, through a wider choice of available vehicles, at the earliest possible time and the lowest possible cost
With the New Vehicle Efficiency Standard becoming effective on 1 July 2025 this is an opportune time for the Australian Government to reconsider its approach to Australian type approval.
Time is short to implement supporting processes, including any potential need for vehicle manufacturers to undertake additional type approval activity that might become necessary.
Mitsubishi's recent eK X EV Australian market study highlights the difficulty in navigating current type approval and ADR requirements.
The vehicle conforms to Japanese Type Approval and safety requirements, however the cost and time investment to update the vehicle to achieve Australian Type Approval and to conform with ADRs makes it uneconomic to import into Australia in its current form as an entry city car.
These factors currently make Australian importation of this small electric vehicle highly challenging.
Australian Type Approval
The largest barrier to Automotive vehicle manufacturers introducing these vehicles is the lengthy Australian Type Approval process. Depending on the vehicle, this process can take anywhere from 18-24 months.
This factors in the time taken to obtain international type approvals in the first instance, undertaking development and obtaining compliance information for additional unique Australian ADRs, as well as production and shipping time.
The timeline also includes up to three business months for the government to assess an Australian Type Approval application. There are no service level agreements that confirm if it could be completed earlier.
Manufacturers follow strict quality assurance practices, which generally require that production not commence until the Australian Type Approval is achieved.
Vehicle importation regulations also prohibit vehicle shipping until the type approval has been issued (Note: The type approval is also the importation approval.)
Mitsubishi would support an Australian Government reform program, and suggests consideration of a process where vehicles type approved in established global markets, such as Japan, the European Union and the UK, be accepted into Australia without needing additional unique modifications and approvals.
This would reduce processing time and development costs. It would also support OEMs to introduce more fuel-efficient vehicles in time for the NVES legislation commencement date.
Ongoing, it would remove barriers to entry and allow increased consumer vehicle choice and speed to market.
Additionally, Mitsubishi calls for all ADRs to be fully harmonised with vehicle regulations established under the United Nations Economic Commission for Europe (UNECE), 1958 Agreement concerning the Adoption of Uniform Conditions of Approval and Reciprocal Recognition of Approval for Motor Vehicle Equipment and Parts.
The Australian Government is already a contracting party and participates in the UNECE World Forum for Harmonization of Vehicle Regulations (WP.29).
Equivalent standards in other advanced markets such as Japan, the EU, UK and other jurisdictions should also be accepted. This would further accelerate new vehicle adoption in this country, with no impact on safety.
Australian Design Rules
Mitsubishi says unique Australian requirements should also be removed from the ADRs.
For example, Australia uniquely requires a second-row centre seat top tether (ADR 34/03). This could be amended to unconditionally accept EU-approved ISOFix restraint systems.
ADR 61/03 uniquely requires an Australia-unique VIN label in addition to permanent VIN markings already on a vehicle, as dictated by international regulations. Mitsubishi suggests that this should be removed.
ADR 69/00 covering full frontal impact occupant protection could be replaced with harmonised European frontal collision requirements.
Of particular importance to NVES implementation, ADR 81/02 Fuel Consumption Labelling for Light Vehicles requires amendment to define the test procedures required to create NVES data.
Presently ADR 81/02 is primarily a unique Australian labelling regulation that requires a unique windscreen-mounted fuel consumption label.
Mitsubishi would favour making it mandatory for Type Approval holders to input fuel consumption and CO2 data into the existing Federal Government’s Green Vehicle Guide (participation in which is currently voluntary).
This provides an easy and convenient platform from which consumers can compare vehicle fuel consumption, CO2 and energy consumption. This approach is consistent with the recent removal of unique compliance labelling requirements in favour of the on-line Register of Approved Vehicles implemented under the Road Vehicle Standards Act.
Mitsubishi's preference is that ADR 81/02 be replaced with a new ADR that nominates the test procedures required for NVES, and that those procedures be fully harmonised with UN ECE regulations and their internationally accepted equivalents.
Are These Good Ideas?
At first glance being offered a future with a wider choice of EVs, available earlier and at a lower cost sounds great.
The Australian government should consider whether to implement Mitsubishi's suggestions, even if only some changes could be made it could reduce the time to market for EVs.
Making all the suggested changes could mean Australia catches up with NZ which often gets new car models months (sometimes years!) ahead of Australia.
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