Submissions

The MTA is committed to taking a proactive approach with the Australian and South Australian government to ensure the automotive industry and our members are best represented and protected.

The MTA is committed to taking a proactive approach with the Australian and South Australian government to ensure the automotive industry and our members are best represented and protected.

Through submissions the MTA is able to:

  • Highlight failures of government regulations and legislation affecting our members.
  • Advocate on behalf of our members and highlight member concerns.
  • Propose changes to regulations and legislations which best serve the public, our members and the automotive industry.
  • Provide options which assist our members to be more productive and achieve greater business efficiencies.
  • Initiate positive change for the automotive industry in South Australia.

Below is a selection of some of the submissions made by the Motor Trade Association:

  • Small Business Tax Concessions (2018)
  • NHVR Master Industry Code (2018)
  • Light and Heavy Vehicle Standards Review (2018)
  • Road Vehicle Standards Bill Submission 2017 (2018)
  • State Budget Submission (2017)
  • State Nominated Skills Occupation List (2017
  • Accident Towing Charges (2017)
  • Interim Guidelines on Misuse of Market Power Concerted Practices (2017)
  • Quad Bike Safety (2017)
  • Review of CBS Compliance and Enforcement Policy (2017)
  • Vehicle Inspections Position Statement (2017)
  • The Work Health and Safety (Notification of Next of Kin) Amendment Bill 2017 (2017)
  • Road Traffic Act Regulations for NA Category (Two Wheel Drive) Vehicles (2017)
  • Bus and Coach Accreditation and Regional Contract Matters (2017)
  • Competition Policy Review Legislation 2016 (2016)
  • ASIC Actions Relating to Dealer Finance (2016)
  • ACCC Market Study into New Car Retailing (2016)
  • ACL Interim Report Feedback Submission (2016)
  • Review of the Return to Work Act 2014 Submission (2014)

For more information on submissions and the MTA’s commitment to Industry Policy and Advocacy please contact 8291 2000 or email mta@mtaofsa.com.au


Small business tax concessions

The submission focussed on automotive businesses views on keeping the instant asset write off, abolishing payroll tax and reducing the burden of collecting and reporting taxation on behalf of the government. The MTA also highlighted the need for extra tax breaks for businesses starting up or going through growth phases.

MTA members can view the full submission here


NHVR Master Industry Code of Conduct

Members have reiterated that more clarity is needed around the NHVR Master Industry Code of Conduct in relation to changes in Chain of Responsibility obligations. In particular, our submission highlights the need to fight to make sure that drivers and mechanics are properly protected from the misconduct of others, as well as the need to ensure that roadside inspectors have the appropriate qualifications and experience to do their job.

MTA members can view the full submission here


Light and Heavy Vehicle Standards Review

We continue to pursue the introduction of a federally administered light vehicle inspection scheme that ensures safety on our roads and consistency with Australian Design Rules. We are also fighting to ensure that tyre ages are included in an inspection scheme.

MTA members can view the full submission here


Clarification , simplification and modernisation of the consumer guarantee framework (2018)

The MTA has surveyed its entire membership to assist in developing an appropriate response to the Regulatory Impact Statement.

MTA members can view the full submission here.


Road Vehicle Standards Bill Submission 2017 (2018)

The MTA’s submission makes eight recommendations and requests clarification on a further eight issues following consultation with our members.

MTA members can view the full submission here.


State Budget Submission (2017)

Our submission seeks to achieve progress towards the Premier’s vision by prioritising:

  1. Enhancing business cash flows to increase sustainability and enable enterprise expansion.
  2. Increasing workforce productivity and employment outcomes through improved training structures and greater assistance for training providers.
  3. Reducing business costs such as electricity and overheads.
  4. Increasing access to government funding pools to assist in innovation and transformation.

MTA members can view the full submission here.


State Nominated Skills Occupation List (2017)

The South Australian economy is facing a current and growing skills shortage.

The automotive sector, notwithstanding the end of automotive manufacturing, continues to be a significant employer in South Australia, with over 28,000 people employed in the automotive trades we support.

MTA members can view the full submission here.


Accident Towing Charges (2017)

Every year the Accident Towing Rate is reviewed for concerns raised by operators including the impact of insurance costs and the stagnation of storage charges.

MTA members can view the full submission here.


Interim Guidelines on Misuse of Market Power Concerted Practices (2017)

The MTA supports the introduction of the misuse of market power provisions to the Australian Competition and Consumer Act 2010.

The intent of the ‘effects test’ is to give the ACCC greater scope to successfully investigate and prosecute businesses engaging in the misuse of market power by allowing for the effect of any conduct to be considered as grounds for a breach, rather than only considering the purpose of that conduct.

MTA members can view the full submission here.


Quad Bike Safety (2017)

There have been a number of injuries and deaths associated with the use of Quadbikes.

The MTA has considered the data presented in the issues paper and has undertaken extensive consultation with its dealership members in order to provide the ACCC with an appropriate response to the issues raised in their paper.

The evidence supplied in the paper does not support a definitive conclusion that Australian specific regulations mandating the fitment of Roll Over Protection Systems and Crush Protection Devices would result in a material change in the number of injuries and fatalities associated with the use of all-terrain vehicles.

MTA members can view the full submission here.


Review of CBS Compliance and Enforcement Policy (2017)

The Australian Consumer Law and Second Hand Vehicle Dealers Act seminars, developed jointly by MTA and CBS, have been positively received by industry and have greatly assisted in informing dealers of their rights and obligations in relation to consumers. The MTA recommends that this program of engagement and education continue into the future.

The MTA considers that there is considerable scope to expand enforcement actions to include those businesses, including auto recyclers and mechanics, who do not meet environmental standards as prescribed by law.

The MTA considers enforcement action would be enhanced by increased awareness of the reporting mechanism on the CBS website, with subsequent enforcement action acting as a deterrent to others in the industry.

Non-compliant businesses pose a consumer detriment and substantially harm their respective industries.

MTA members can view the full submission here.


Vehicle Inspections Position Statement

The MTA supports mandatory vehicle inspections to reduce the incidence of vehicle related fatalities on our roads.

The absence of a robust system to identify ‘at risk’ vehicles, encourage regular maintenance and servicing and to reduce the number of aged vehicles on South Australian roads has hidden the risk of un-roadworthy vehicles.

MTA members can view the full submission here.


The Work Health and Safety (Notification of Next of Kin) Amendment Bill 2017 (2017)

While the MTA supports the objective of the Bill to ensure next of kin are notified in the event of an incident, we cannot support the proposed amendments of the Bill. Further, it should be reiterated that the proper responsibility for notifying next of kin should remain with trained emergency personnel.

MTA members can view the full submission here.


Road Traffic Act Regulations for NA Category (Two Wheel Drive) Vehicles (2017)

The MTA recommends amending the regulations to include this provision from the National Code of Practice:

"Off-Road and Goods Vehicle Wheel Track.

The wheel track of off-road four wheel drive vehicles and goods vehicles (MC, NA, NB ADR category) must not be increased by more than 50mm beyond the maximum specified by the vehicle manufacturer for the particular model. If a solid axle from another manufacturer is used, the wheel track may be increased by 50mm beyond the maximum specified by the vehicle manufacturer for that particular axle, provided all other requirements such as clearances and the tyres do not protrude outside of the vehicle bodywork."

MTA members can view the full submission here.


Bus and Coach Accreditation and Regional Contract Matters (2017)

The MTA wishes to reiterate the concerns our members have expressed about being excluded from government procurement processes and the lack of transparent communication to the whole industry.

MTA members can view the full submission here.


Competition Policy Review Legislation 2016 (2016)

The MTA considers the introduction of an ‘effects test’ into s46 of the Australian Competition and Consumer Act 2010 (ACC) a step forward in regulating competition practices in Australia.

The drafting of the proposed amendments accords with the MTA’s recommendation to the consultation panel which considered the ‘Options for Strengthening the Misuse of Market Power Provisions’ in the ACC.

MTA members can view the full submission here.


ASIC Actions Relating to Dealer Finance (2016)

The MTA does not support ASIC's contention that the current dealer finance model is inherently unfair, presents a systematic conflict of interest or poses systematic risk to the dealer finance market resulting in consumer harm.

MTA members can view the full submission here.


ACCC Market Study in New Car Retailing (2016)

An ultra-competitive market already exists in new car retailing, as it does across the retail, service and repair sectors, and any moves to further slice margins will affect employment and business viability in the sector, undermining the competition remit afforded to the ACCC and lead to greater consumer detriment.

MTA members can view the full submission here.


ACL Interim Report Feedback Submission (2016)

The MTA’s submission focuses on five key areas discussed in the report that most impact on our membership and the ACCC has sought further advice on.

These are:

  • The Consumer Guarantee Threshold;
  • Small Business Considerations;
  • Lemon Laws;
  • Product Safety; and
  • Manufacturer’s Warranties

MTA members can view the full submission here.


Review of the Return to Work Act 2014 Submission (2014)

The MTA believes that this review does provide an opportunity to refine those elements of the scheme that:

  • Are likely to pose significant funding threats to the scheme due to issues of interpretation by the courts.
  • Do not operate in a manner that best supports the scheme’s primary objective of returning injured workers to meaningful and sustainable work as efficiently and safely as possible.
  • May impact the scheme’s ability to return injured workers to meaningful and sustainable work as efficiently and safely as possible.

MTA members can view the full submission here.