AIMVIA: Australians should have access to the widest choice of used vehicles

In its submission to the National Electric Vehicle Strategy (NEVS) consultation paper, the Australian Imported Motor Vehicle Association (AIMVIA) says Australian consumers should have access to the widest choice of available used vehicles including Electric Vehicles (EV).

AIMVIA represents the entire supply chain associated with the independent importation, preparation, and sale of used vehicles and it rejects claims from the new vehicle industry that such vehicles are unsafe.

It says all used vehicles are subject to robust checks for provenance and safety before leaving the country of origin and are also often verified twice before state registration.

“Our position is that Australians should be able to access the widest possible choice of quality used vehicles including EV which comply with Australia’s safety and environmental standards,” AIMVIA says. 

It says such choice would ensure competition and the best possible pricing of vehicles.

“There are only six models of electric vehicles available new under $50,000, and with EV sales representing 3.9% of the market, and new vehicle depreciation at record lows, it is unrealistic to solely rely on new EV sales to filter down to the more-affordable used vehicle market any time soon,” AIMVIA says.

“Supplementing existing new EV sales with a range of near-new and used EVs independently imported from overseas markets would drive down the price of used EVs and more rapidly increase their uptake by consumers at all points of the socio-economic scale,” it says.

AIMVIA points out the independent vehicle importing industry has never held its hand out for government incentives, and a broadening of the used imported EV market would use market forces to drive down prices rather than taxpayer dollars.

It has submitted three solutions to the NEVS consultation to increase supply of affordable and accessible EVs to meet demand across all segments.

Solution 1: Minor amendment to the Road Vehicle Standards Rules

The Road Vehicle Standards Act (2018) and the accompanying Road Vehicle Standards Rules (2019) determine a number of pathways through which new and used vehicles can be imported to Australia. Of interest to this submission is the concessional pathway for Specialist and Enthusiast Vehicles (SEVS), which permits the importation of new and used EVs providing they satisfy section 132, which is the Environmental Criterion:

“A variant of a model, or a make and model, of a road vehicle, as originally manufactured, satisfies the environmental criterion if the Secretary is satisfied that it:

(a) either:

(i) meets or exceeds the national road vehicle standards relating to emissions

that would apply to a new vehicle of the variant, or the make and model, at the time the application is made; or

(ii) meets or exceeds emissions standards that are determined under subsection 136(1) to be comparable to the standards mentioned in subparagraph (i); and

(b) either:

(i) uses an alternative to an internal combustion engine (other than human or

animal power) as a means of propulsion, whether as the exclusive means of propulsion or in addition to an internal combustion engine; or

(ii) has a maximum engine capacity of 660cc, a maximum engine output of 47 kilowatts and is not more than 3.4 metres long and 1.48 metres wide.”

Put simply, new and used EVs and hybrid vehicles can be imported to Australia if they are at least as fuel efficient as brand new cars says AIMVIA.

“While this may seem like news for EV enthusiasts, the vehicles imported via SEVS must also meet Section 129A, which decrees that makes and models already sold through official channels in Australia are ineligible for independent import,” it says.

AIMVIA recommends a minor amendment to the RVS Rules to allow vehicles that meet the Environmental criterion to be exempt from meeting the requirements of Section 129A. This would allow ALL environmental vehicles to be considered eligible for independent importation, irrespective of whether have been previously sold by the manufacturer in Australia.

AIMVIA estimates that this change would result in approximately 6000 more environmental vehicles entering the Australian market per annum, at far more affordable prices than the new EVs currently available.

“These additional vehicles would be subject to the same robust compliance processes already in place for all SEVS vehicles, which are independently verified to ensure that imported vehicles are free from damage and rust, and safe for the first Australian owner to drive,” it says.

Solution 2: Greater recall protection for vehicle owners

One long-standing argument used by manufacturers to oppose the relaxation of vehicle importation rules is that owners of used imported vehicles are left unprotected in the event of a recall, such as the recent one involving Takata airbags. A prudent solution might be that AIMVIA, for example, provides a website where owners can see whether or not their vehicles are subject to recalls. 

Unfortunately, this process is not sufficiently robust when there are compulsory, safety- related recalls, for two reasons: 1) despite extensive vehicle and owner information being held in both federal and state databases, there is no established process for locating and contacting vehicle owners, and 2) if a vehicle is found to be subject to a recall, how does the owner then access the replacement parts needed for the repairs?

AIMVIA recommends the following:

1) The Department of Infrastructure builds and maintains a vehicle database that correlates and consolidates state-based registration data, the Register of Approved Vehicles (RAV), the National Exchange of Vehicle and Driver information System (NEVDIS), as well as external data for used imported vehicles, supplied by overseas sources such as Japan’s MLIT and JASPA websites. 

This database would be publicly accessible by all vehicle owners, regardless of whether the vehicle has been imported via the manufacturer’s distribution network or independently. New Zealand already provides such a service for used imported vehicle owners. Furthermore, this database would allow the Department of Infrastructure to identify and locate vehicles that are subject to compulsory, safety-related recalls, and contact owners via State and Territory Registration Authorities (STRAs) where necessary.

2) Adjustments be made to Australian Consumer Law so that, in the event of a compulsory, safety-related recall, overseas manufacturers are required to provide the necessary replacement parts for affected vehicles they have manufactured that are registered for use on Australian roads, irrespective of whether they have arrived to market via the Type Approval or Concessional Pathway.

AIMVIA notes that current RVS Rules state that used imported vehicles cannot be complied and registered if they’re subject to an active recall. As a result, such vehicles have their recall work completed in the country of origin, prior to importation.

Solution 3: Introduction of quadricycles

Quadricycles such as the Renault Twizy and the Citroen Ami provide an inexpensive (sub-$A10,000) mobility solution for city dwellers in Europe. Current Australian Design Rules do not make provision for a separate category for L-category quadricycles, as is the case in Europe, the United Kingdom and Japan. Therefore, quadricycles are currently considered normal M- category passenger vehicles and would not meet the required ADRs to be driven on public roads.

AIMVIA recommends that the quadricycle category be added to Australia’s vehicle category mix, allowing small, cheap electric vehicles to be used in, and restricted to, urban areas.