Words and Images by: Collyn Rivers N8054

US power outlet. If you see one in an imported RV you know instantly it cannot be compliant

Posts on various forums and direct enquiries show there is still major confusion about the electrical compliance of privately-imported RVs. Virtually all owners believe in good faith that their units are made fully compliant. They rarely are.

The cause is misunderstanding a legislative loophole that allows visitors to Australia to use non-compliant devices such as razors, phone chargers, etc. and also enables locals to import RVs bought overseas.

If North American or Canadian they have 120 volt ac everything, but may legally be used here by that buyer if modified by adding a 230 volt to 120 volt transformer, plus safety devices. This does not, however, confer electrical compliance. It allows the original buyer ONLY to use that RV. With one exception, it cannot be sold (or given away), unless made 100 percent compliant: not just electrically but in every respect. Such compliance extends to the LP gas system, weight, overall width, and rear overhang. It must be made fully compliant – or scrapped. It can, however, be sold to a dealer who takes on that responsibility.

Import facilitators may arrange a private import and (allegedly) imply it will be 100 percent compliant, but as the facilitator is not the buyer, unless you have that compliance statement in writing there is no way to enforce it.

DEFINITION OF ‘SELL’ AND ITS APPLICATION

In the context of this article, ‘Sell’ includes auction or exchange; offer, agree or attempt to sell; advertise, expose, send, forward or deliver for sale; cause or permit to be sold or offered for sale; hire or cause to be hired; and display for sale or hire. It is also an offence for any person to dispose of or make available an article if it would be an offence to sell that article.

FIXING THE ELECTRICS

Bringing the electrics into full compliance is costly. It includes rewiring with 230- volt cabling, adding double-pole circuit breakers and switches, replacing all socket outlets and all appliances. The 120- 12 volt converter can be replaced by a locally-made 230 volt equivalent, but if free-camping is planned it is better to use  a conventional battery charger system. Rewiring can be costly as the original is usually stapled between the inner and outer RV lining. An alternative is to leave it in place (totally disconnected) and to run the new wiring within cupboards, bed bases, etc.

All electrical goods sold in Australian states and territories must meet the requirements of the Electricity (Consumer Safety) Act 2004 and its Regulations. This covers the distribution of safe electrical appliances and other electrical goods listed as Declared Articles. The listing includes everything used domestically including in RVs: e.g. appliance connectors, circuit breakers, wall and other switches, lamp holders, plugs and outlet sockets, RCDs, supply cords, lighting and all appliances etc. The list is virtually identical in all Australian jurisdictions.

FIXING THE GAS

Changes to the gas system are usually simpler. Local requirements for ventilating gas compartments are more rigid but this is not a costly thing to do. The gas regulator will need replacing.

OTHER COMPLIANCE ISSUES

A major and sometimes impossible situation can arise if the RV is over-width, over-weight – or has excess rear overhang. Over-width can sometimes be resolved by scrapping an overhanging awning and fitting one that does not, but where there is excess rear overhang, it close to impossible to shorten it.

PENALTIES FOR NON-COMPLIANCE

It is an offence under section 16 of the Electricity (Consumer Safety) Act 2004  to sell an unapproved electrical article. Penalties for selling unapproved products include up to $55,000 and/or two years imprisonment for an individual and $550,000 for a corporation.

It is also an offence under section 151 of the Australian Consumer Law (Competition and Consumer Act) 2010 to falsely represent that goods or services have approval, performance characteristics, etc. It is an offence under section 194 of the Australian Consumer Law (Competition and Consumer Act) 2010 to supply consumer goods that do not comply with safety standards. Fines for both include maximum penalties of $1,100,000 for a body corporate and $220,000 for an individual for a first offence. The law is clear and applicable in all Australian states and jurisdictions – excepting that in some, non-observation is a civil offence, in others it is a criminal offence.

BUYING FROM A DEALER

A non-compliant RV can legally be sold to a dealer who automatically accepts responsibility for compliance. This can also be an issue of buying a non-compliant RV from the original owner. That owner is legally liable but may need to be advised of the penalties if refusing to fix the issues or refund the price.

HOW TO KNOW IF AN RV NON-COMPLIANT

Much that is non-compliant is out of easy inspection. There is however a 100 percent giveaway. No 120 volt, 60 Hz anything in an RV can legally be sold in Australia. This is often obvious: US and Canadian power outlets are different from ours. In most cases the owner will seek to sell the 120 volt appliances in the vehicle (particularly the fridge). If there is anything in that RV that is 120 volt then, by definition, that RV is not compliant. Establishing that an RV with 230-volt appliances is 100 percent compliant is not feasible for non-electricians. The only way to be certain is to have a licenced electrician check it out and issue a Certificate of Electrical Compliance.

(As explained below, do not accept as valid any existing Electrical Compliance Certificate if dated prior to 2010 – and particularly if issued in Queensland. This applies also to weight and dimensions).

ILLEGAL IMPORTS

Prior to 2009 many RVs were imported, mainly into Qld by rogue dealers. Many have weight and electrical compliance  certificates known to be based on false declarations of compliance – or forged certificates.

That this was happening was suspected by many journalists (including me) as many fifth wheelers registered as under 4500 kg proved to weigh in excess of 6000 kg unladen but defamation law precluded it being stated publicly. It was eventually brought to the attention of the Australian Government (by myself in conjunction with the CMCA and Colin Young of the-then RVMA). On November 20 2009 then Minister Anthony Albanese confirmed it as true in Parliament. As it was published in Hansard I can reproduce here with zero risk of legal action. It is an exact extract from the Minister’s statement entitled Unsafe Trailers Put On Notice with New Code of Practice.

‘This move will still allow Australians returning home from long periods overseas to bring with them their personal vehicles, whilst reducing the potential for abuse by organised syndicates seeking to bypass our rigorous motor vehicle certification arrangements by using third parties to import non-compliant vehicles.’

It later became clear (via the Qld Government) that Certificates of  Compliance – including those for electrical and on-road compliance – had been obtained by some ‘importers’ falsely declaring RVs were compliant – when they demonstrably were not. Similar issues occurred with declarations of weight and width.

Intending buyers of vehicles of this era should be aware that, even though certification exists for that import, it may be invalid. This is totally known by insurers and regulatory authorities. Any imported RV being re-registered in another state is likely to have to obtain new Certificates of Compliance – if indeed possible.

TECHNICAL ISSUES OF NON-COMPLIANCE

Safety issues  exist in a non-fully compliant important cannot be fully resolved by adding a 230 volt circuit breaker/RCD and adding a 230-120 volt transformer. The 'isolation transformers' used (where the input is fully electrically isolated from the output are intended to power only one Class 1 device at a time. ( A class 1 device has a metal chassis or enclosure connected to earth). There are known safety issues if two or more such are connected. (AS/NZS 3000:2008 7.4.3 re 'Arrangement of Circuits' all live parts of a separated circuit shall be reliably and effectively separated from all other circuits, including other separate circuits and earth').

There is thus no way that an isolation transformer in an RV can comply with the standards. RV insurers are now aware of it and may reject claims resulting from an electrical incident that involves a 120- volt item. 

Disclaimer: I am not a licenced electrician, but have extensive experience in electrical design and engineering.

This article is protected by the Commonwealth Copyright 2016 Caravan and Motorhome books. It may not be reproduced without express written permission in any shape or form.

This and similar articles are on caravanmotorhomebooks.com and constantly updated. The above issue is also covered in depth in Collyn's books - including the 2nd edition Caravan and Motorhome Electrics. Almost all of Collyn's books are available directly through CMCA. They are also obtained directly from the publisher - postage is applicable.  

Category: Technology
Written: Sat 01 Oct 2016
Printed: October, 2016
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