NEW CHANGES TO IN-SERVICE (WOF & COF) MODIFICATION THRESHOLDS
The NZTA Warrant of Fitness and Certificate of Fitness manual, called the Vehicle Inspection Requirements Manual (VIRM), is being amended, with effect from April 2020.
The main changes for modified vehicle are detailed below. Click on the following link for the NZTA announcement and full details: https://vehicleinspection.nzta.govt.nz/
Location of changes:
There are two sections of the VIRM that have amendments – the ‘Reasons for Rejection’ tables and the ‘Modification Threshold’ tables
All modifications to light vehicles must meet WoF/CoF requirements, however not every modification requires low volume vehicle (LVV) certification - there are a number of modifications that are deemed ‘under threshold’. These are listed in ‘modification threshold' tables, which provide vehicle inspectors a list of modifications which don’t require LVV Certification, and the point at which a modified light vehicle must be LVV certified.
The amendments that affect modified vehicles are mainly in the ‘modification threshold' tables. There are also some changes to individual Reasons for Rejection sections, which are located throughout the various sections in the VIRM under the ‘Reasons for Rejection’ tab.
Some of the changes make the intent of a requirement clearer, with the consequence that some vehicles that passed a WoF previously will now be failed. The most important changes are listed below.
There are also many wording improvements in the new threshold which are not covered in this document as they are considered minor, for example the addition of new items to the tables, such as roof mounted solar panels. Changes that are self-explanatory are also not included. Regardless of this, all changes are highlighted within the amended Modification Threshold document.
Note that the LVVTA Threshold document does not include motorcycle thresholds or requirements, such as requirements around handlebar modifications, which can be found in the NZTA’s motorcycle VIRM.
Main Threshold changes
The main changes to the threshold are related to the following topics which are explained in detail below.
Click on each item below to expand.
>> Tyre and wheel fitment including protrusion of tyres beyond mudguards
The previous threshold wording allowed for increasing the offset of wheels provided that the tread remained within the guards, or the track increased by no more than 25mm.
This relied on knowledge of the original vehicle track so was not widely enforced.
The new wording allows more scope to modify before reaching the modification threshold.
LVV certification is not required provided that: The tyre tread does not protrude beyond:
· in the case of a vehicle that is not a class NA or class MC vehicle, the unmodified original body panels or factory fitted mudguard extension/flare, or
· in the case of a class NA or class MC vehicle, 25mm outside of the unmodified original body panels, provided that a flare or wheel arch extension covers the full width of the tyre tread
We have explained this requirement in more detail here: Click to download PDF
>> Springs and shock absorbers
An additional requirement is added to the threshold – certification is not required provided that the suspension retains at least 40mm of rebound (droop) wheel travel.
Rebound wheel travel is measured as the difference between the distance from the top of the tyre and the wheel arch with the vehicle resting on the ground and the top of the tyre to the wheel arch with the vehicle lifted so that its tyres are clear of the ground (Suspension hanging in full rebound).
This difference must be greater than 40mm. Note that suspension that does not meet this requirement is unlikely to meet LVV requirements and so cannot be certified.
>> Items moved from the ‘certification never required’ to ‘certification not required provided that’ box
Some items have been moved from the ‘certification never required’ table to the ‘certification not required provided that’ table, to enable requirements around structure and external projections to be covered.
Items that are in the ‘certification never required’ table do not need to be inspected by an LVV certifier as part of a certification, but those items in the ‘certification not required provided that’ table do need to be assessed.
This move means that a vehicle that is certified for other modifications will now have additional items inspected and covered in the certification. Examples include ute trays, glass racks and sunroofs.
>> Fuel system threshold more detailed
The threshold previously stated that LVV certification is not required provided that:
· No structural modifications have occurred to the vehicle during the installation or modification, and
· The filling location remains the same as at original manufacture, and
· The fuel type (petrol, diesel) has not changed (other than a change to LPG/CNG).
The threshold is more specific now, such that all fuel system modifications except the following always require certification:
· Fuel lines that are of similar construction to the OE fuel lines (i.e. Hard lines are not replaced with flexible lines), and in the OE location and mounted to all the OE fixing clips
· In-line fuel filter that is of an appropriate pressure rating, adequately supported, at least 50mm from the exhaust and at least 100mm from a catalytic converter
· Electric fuel pump that is a replacement for a mechanical pump on a carburettor engine, is adequately supported, and does not increase the fuel pressure above OE specification.
>> Future treatment of utes with wide trays
Ute trays have previously been a modification that never required certification.
After 1 Jan 2021 however, newly registered utes with trays that protrude more than 100mm from the widest part of the vehicle cab/body structure (excluding mirrors) will require LVV certification, unless they have suitable pedestrian protection measures.
>> ‘Grandfather rights’ for vehicles re-entering the fleet
The NZTA VIRM for vehicles going through Entry into the fleet, or being re-entered after lapse of registration/write-off, has a clarification note stating that the vehicle must be LVV certified unless the vehicle modifications fall below the threshold as detailed in the LVV Threshold document, excluding any ‘grandfather clauses’. There are several items in the threshold which refer to a date that provides a ‘grandfather clause’. These can no longer be accepted for a vehicle going through Entry or re-Entry:
· Addition of side windows into a panel van or goods van before 1 March 1999
· Campervan conversions completed before 1 March 1999
· Seats modified or replaced before 1 March 1999
· Right-hand drive steering conversions before 1 March 1999
· Aftermarket ‘Retro’ brand child seats installed by Auckland Auto Trimmers or their agents before 1 June 2012
· Rear seatbelts fitted to class MD1, MD2 and NA vehicles before 1 March 1999
The requirements contained within the appropriate LVV standards and New Zealand Car Construction Manual will apply to old conversions and depending on the age of modification, some relaxations to technical requirements may be applicable. For instance, modifications completed before 1992 will usually only be subject to general safety requirements.
>> Clarification around modifications to structure, and modifications that present a danger to pedestrians
Two new notes are added to provide more guidance to inspectors around which modifications affect structure and what constitutes a potential trap for a pedestrian:
Weakening the vehicle structure:
· Heating, drilling, welding or cutting the vehicle structure, modifying a roof bow, or modifying any part of the structure anchorage would be considered to weaken the structure.
· Cutting a single layer of unstressed panel of sheet metal (i.e. roof) is not considered to weaken the vehicle structure.
· Drilling a hole suitable for a child restraint top tether does not require LVV certification.
Forward-facing pedestrian traps:
· A pedestrian trap is any part of a vehicle that may hook, catch or pull/push a pedestrian into or under a vehicle.
· Vehicle components should be shaped to reduce injury to a pedestrian and to move the pedestrian away from the vehicle in the event of an incident.
>> Steering wheels and attachment
Three additional requirements have been added to the threshold:
LVV Certification is not required for a replacement steering wheel provided that it is:
· Mounted with a one-piece boss
· Has a diameter greater than 245mm
· Does not significantly inhibit the drivers view of the speedometer or mandatory warning lights.
A vehicle fitted with a quick release steering wheel must always be referred for LVV certification, and even then, is only permitted within strict criteria.
If you have any questions relating to these changes, you can contact the Tech Team at LVVTA via our Contact Us page.