Timing key for safety mandates

The Imported Motor Vehicle Industry Association (VIA) says introducing new safety requirements for vehicles entering New Zealand’s fleet risks increasing the cost for importers trying to secure compliant models from Japan.

“A new regulation narrows the set of vehicles that qualify as compliant,” it says in a submission to the government on proposals to mandate certain advanced driver-assistance systems (ADAS).

“That narrowing creates scarcity at Japanese auctions, which increases hammer prices for the remaining compliant vehicles.

“The used-import market is not a random slice of Japan’s fleet. It is a tightly filtered subset shaped by price, mileage, grade and household affordability. That matters because each additional regulatory requirement narrows the compliant supply set.”

Its comments come as the government is considering mandating automatic emergency braking (AEB), lane-keep support systems, and acoustic vehicle-alert systems for “quiet” electric and hybrid vehicles for new and used light and heavy vehicles entering the country.

Officials are considering feedback on the proposals before the Associate Minister of Transport makes any final decisions. The NZTA says any Land Transport Rule amendments would likely be signed by mid-2026.

VIA says it supports the intent to lift road safety through modern vehicle technologies, but it has concerns over the timing, affordability and operational feasibility of such changes for the used-import sector.

It opposes a 2027 start date for features such as AEB to be compulsory for used light vehicles because it says this would precede the practical supply window for affordable, eight to 12-year-old Japanese vehicles relied upon by many Kiwi households and small to medium enterprises.

“If mandates are set ahead of real-world availability in Japan’s used fleet, and ahead of what New Zealand households can afford, New Zealanders will be priced out of upgrades and will hold on to older vehicles longer, undermining safety outcomes,” its submission states. 

“New Zealand’s used import channel relies overwhelmingly on Japanese stock. Regulatory timelines should therefore align with the real arrival curve of safety technology into Japan’s used fleet and into New Zealand’s affordability band, not simply with Japan’s new-vehicle rule dates. 

“That is how safety improvements reach those most at risk at scale and pace – rather than concentrating benefits among higher-income buyers who can access newer vehicles sooner.”

VIA notes New Zealand does not manufacture vehicles and sources the vast majority of its used imports from Japan. 

“AEB will be fully mandated in Japan from the end of this year, which means New Zealand will inevitably receive AEB-equipped vehicles as they age into the used market. 

“In practical terms, New Zealand cannot ‘fall behind’ Japan in used-import safety standards; it can only mis-time access by setting requirements ahead of when those vehicles are actually available and affordable in the source market’s used fleet. 

“The real policy risk is not falling behind, but introducing mandates before supply exists in the used-fleet pipeline.”

Suggested starting dates

VIA highlights the mean age of used imports is 11 years but says using that figure as a compliance threshold risks eliminating about 50 per cent of current used-import supply.

It suggests 12 years would be a better point on which to base ADAS policies, although this would still result in about a 20 per cent supply reduction. 

“Mandate timing should be based on at least a 12-year shift – and, in our view, no less than that – if the aim is to reach the mainstream used-import market rather than a thin, early tranche of higher-priced supply,” VIA tells officials.

“Meaningful AEB volumes for NZ begin around 2029; large volumes arrive around 2033; broad availability occurs in the early 2030s once the 12-year offset is applied.”

In 2027, New Zealand will primarily import 2015-2016 Japanese vehicles. In that model-year range, AEB fitment was incomplete and concentrated in higher-spec trims, which means early mandates may lead to a scarcity of suitable models and higher prices.

VIA adds lane departure warning (LDW) and lane-keep assist (LKA) technology is not mandated in Japan and remains trim-dependent. Therefore, it suggests these should not be assumed to become universal in New Zealand’s sourcing window.

“LDW reaches only around 80 per cent in Japan, and LKA remains highly variable and trim-dependent,” it explains. 

“No party can know today exactly how quickly either feature will diffuse through Japan’s used fleet, or how consistently it will appear in the trims that land in New Zealand’s affordability band. 

“That uncertainty is precisely why fixed-date mandates are risky. On our current view, NZ availability for LDW/LKA does not reach ‘mandate-ready’ volumes until the mid-to-late 2030s – if at all.”

To align mandates with Japan’s existing-model coverage and the arrival of ADAS-equipped vehicles in a price range Kiwi consumers are prepared to pay, VIA recommends certain start dates for safety features in used light vehicles. 

It says making AEB and LDW compulsory should start from 2035, while rules for LKA should kick in from 2037.

It also supports a minimum 16-month lead time from such features being mandatory in new vehicles before they become compulsory as part of entry compliance for used units.

“New-vehicle mandates raise the future standard of vehicles globally. Used-import policy should focus on maximising the rate at which New Zealand’s existing fleet is upgraded within real affordability constraints. 

“Used-import mandates must therefore be timed to when better-than-current vehicles are actually available in sufficient numbers, rather than mirroring new-vehicle timelines.”

Dual compliance pathway

A further practical constraint flagged by VIA is that ADAS feature visibility at the sourcing stage is limited and inconsistent, especially for older Japanese vehicles and lower-spec trims. 

Auction or document fields are not standardised feature-by-feature, so mandates dependent on pre-purchase confirmation “risk compliance friction, supply loss and price distortion rather than improved safety”.

VIA suggests creating a dual compliance pathway to reduce supply choke points, with one for where documentation exists to show safety feature compliance and another focused on performance-based compliance using recognised safety ratings.

“ADAS policy should maximise the rate of safety improvement per dollar of household transport spend, by accelerating affordable fleet turnover, not by maximising nominal compliance at the border.”

VIA also urges any mandates be underpinned by a clear problem statement, quantified death and serious injury (DSI) reductions by crash type, and a cost-benefit case that tests affordability and supply impacts. 

“Mandating specific technologies only makes sense if it targets material contributors to DSI outcomes, and if the benefits justify the costs. 

“VIA requests that NZTA publishes, or references, the specific crash problem statement for the ADAS mandate, including which crash types it is designed to prevent, the estimated DSI reductions, and the cost-benefit case.”

Creating safer fleet

The submission identifies keeping vehicle turnover moving as the fastest route to a safer fleet “because safety technology only helps once households can actually replace vehicles”.

“New Zealand should avoid fragmented policy sequencing,” adds VIA. “The government has recently acknowledged in the clean car standard settings that affordability constraints materially limit access to newer vehicles and can slow fleet turnover. 

“ADAS mandates that further narrow supply risk working in the opposite direction.”

VIA says it supports exemptions from safety mandates for disability and mobility vehicles and recommends transitional relief for segments that are disproportionately affected yet essential for households, community services and small to medium enterprises.

It also wants the government to confirm a scheduled review in 2030 to reassess ADAS uptake in Japan’s used fleet, with particular focus on LDW and LKA availability, pricing effects and verification practicality. “This allows policy to adjust to real-world outcomes rather than relying on long-range assumptions.” 

VIA adds officials should engage with importers, compliance centres and inspection providers to develop practical, consistent guidance for identifying and verifying ADAS features on used imports, including treatment of Japanese documentation and model or trim-level variation.