Pursuant to clause 11.7(1)(d) of Land Transport Rule: Vehicle Standards Compliance 2002, as amended in 2005 and 2007 (“the Rule”), and pursuant to an authority delegated to me by the Director of Land Transport (“the director”), I, Donald Norman Hutchinson, Manager Vehicles, Land Transport New Zealand, give the following notice.
N o t i c e
1. This notice may be cited as the Whole of Vehicle Marking Notice 2008, dated 28 February 2008. Whole of Vehicle Marking (WOVM) involves attaching thousands of microdots containing the vehicle’s identification number (VIN) to various locations on the vehicle for identification purposes. From the dates specified below, WOVM will be required on vehicles inspected for certification, under section 6 of the Rule, for entry and use on roads in New Zealand.
2. This notice applies to imported light passenger vehicles of Classes MA, MB and MC (see Table A of the Rule) that are less than 15 years old from the date of manufacture, or if this is not known, from the date of first registration anywhere (for the avoidance of doubt, scratch-built vehicles are excluded from WOVM). Inspection for the presence of WOVM is to commence on 1 July 2008 and be progressively extended to all entry points nationally to capture all applicable vehicles that enter the fleet from 1 September 2008. From 1 September 2008, applicable vehicles must not be entry certified unless they have WOVM in accordance with this notice.
3. Inspecting organisations appointed under 2.2(1)(d) or (e) of the Rule are now invited to apply to the director to be “appointed applicators” for the purpose of WOVM in accordance with this notice. Applications for appointment must provide details of the proposed operation, microdot supplier to be used, and security arrangements as specified in this notice.
4. If multiple copies of the VIN that comply with the technical requirements for microdots in this notice are not already attached to the vehicle, then the microdots must be attached to it in the places and manner specified in the Schedule of this notice.
5. The system and process followed to supply and attach the microdots must comply with the security requirements in
the Schedule of this notice.
Schedule
Specification for Microdot Vehicle Security System
1. Administrative Requirements
1.1 Acceptance of system
Microdot suppliers must be able to satisfy the director that the administrative, supply and application arrangements meet the requirements in the following clauses 1.2, 1.3 and 1.4.
1.2 Security of Supply Chain
Security of the supply chain must be strictly controlled to prevent unauthorised access to microdot stock. Detailed processes must be developed by the entry certifiers, the microdot suppliers and the persons or organisations who attach the microdots to vehicles (applicators).
1.3 General Security
Microdot suppliers must have effective security arrangements in place and ensure the supply of microdots (VIN identifiers) is only to orders from applicators either appointed by the director or contracted to the entry certifiers (appointed applicators).
The appointed applicators must have systems in place to ensure:
(a) supplies of microdots are secure and cannot be tampered with or partially removed before use; and
(b) surplus/residual microdots are disposed of in a manner that ensures they are not available for use on other vehicles; and
(c) any missing stock of unused microdots is recorded and follow-up action taken.
1.4 Administration and Control Processes
The appointed applicators must have systems in place to ensure:
(a) the microdots are attached to the correct vehicle; and
(b) the identity of treated vehicles is recorded; and
(c) cross contamination of microdots between vehicle applications is avoided.
2. Physical Characteristics
2.1 Acceptance of System
Documented evidence must be provided from an independent testing authority acceptable to the director of Land Transport, certifying that the product meets all the requirements in the following clauses 2.2, 2.3 and 2.4(a) and (b).
2.2 Components Used
(a) Microdots:
(i) Microdots must be made of an inert, durable material, scientifically certified to have no adverse reaction with any part or function of the vehicle to which they may be applied.
(ii) Microdots must not be more than 1mm in width and able to be easily located once they have been applied to a vehicle and covered with adhesive/coating.
(iii) Microdot material and the data stored on it must meet the requirements of the Accelerated Ageing and Removal Tests in the appendix to this notice.
(iv) Identification data stored on the microdot must link it directly to the VIN of the vehicle without the need to obtain additional data. The data on the microdot must include the whole VIN. The microdot must also incorporate means to identify the microdot supplier.
(b) Adhesive/Coating Material:
The adhesive/coating material must readily coat the microdots and adhere them to the various surfaces of the vehicle on which the system is to be applied in such a manner that ensures the Accelerated Ageing and Removal Tests specified in the appendix to this notice are met.
The adhesive/coating material must allow the easy detection and selective removal of individual microdots (but not the en-mass removal of microdots) and the cleaning of the microdot if needed to retrieve the microdot data.
The adhesive/coating material must incorporate a UV trace element that enables its presence to be detected using a UV light source (black light).
2.3 Authenticity
(a) Either the microdot or the adhesive/coating material must incorporate a proprietary exclusive feature that enables the microdot supplier to scientifically or otherwise conclusively authenticate the supplier’s microdot and/or adhesive from any other product or any attempt to counterfeit the supplier’s product.
(b) The authenticity feature must be demonstrated to have a high degree of counterfeit resistance.
2.4 Application of Components
(a) Application System:
The application system must enable the microdots to be distributed over the surface being treated and allow the application of the microdots to locations that cannot be physically reached without dismantling of components.
The application system must incorporate features that prevent cross contamination of microdots between applications to different vehicles.
The number of microdots applied to a vehicle must be of the order of 7000 (seven thousand) or more, and these must be evenly distributed over the vehicle components treated.
(b) In-field Readability:
The identification data stored on the microdot must be able to be read in the field using a low powered microscope device.
(c) Cleanliness of Surfaces:
The surfaces to be treated must be clean, dry and in sound condition, and free of loose material, oil and grease.
(d) Vehicle Application Points:
The following areas of a vehicle must have microdots applied, where applicable and accessible without dismantling (except removal of rubber caps, covers and similar, without the use of tools)
(i) Compliance plate/label.
(ii) Inside reinforcing ribs of the bonnet.
(iii) Inside reinforcing ribs of the boot lid or tailgate.
(iv) Inside of the front and rear bumper assemblies.
(v) Front and rear suspension components.
(vi) Wheel bearing housings.
(vii) Engine block, bell housing, transmission, transfer case.
(viii) Rear axle and differential housing.
(ix) Parts of the floor pan and structural/reinforcing members.
(x) Inside openings in body structural members.
(xi) Part of the underside of the body.
(xii) Exhaust system brackets.
(xiii) Rear of brake callipers/brake drums.
(xiv) Inside wheels.
(xv) Rear of headlights.
(xvi) Rear of tail lights.
(xvii) Door cavities.
Other areas of a vehicle may have microdots applied.
Appendix – Accelerated Ageing and Removal Tests
A1 Preparation of Test Specimens
Test Specimens shall consist of steel plates approximately 1mm thick and 300mm square.
Test Specimen (Type 1): Shall be clean dry bare metal with at least one side free of loose material, oil or grease.
Test Specimen (Type 2): Shall be coated on at least one side with an automotive sound deadening material and prepared, finished and allowed to cure to approximately replicate a typical automotive underbody surface.
Test Specimen (Type 3): Shall be painted on at least one side and prepared, finished and allowed to cure to approximately replicate a typical automotive cosmetic surface such as the underside of a bonnet or boot lid.
Note: The side of the Test Specimen that meets the criteria above is referred to as the “prepared side” in the remainder of this appendix.
Sufficient Test Specimens of each type shall be prepared to enable a new Test Specimen to be used for each Accelerated Ageing Treatment and subsequent Removal Test. A minimum of six Test Specimens of each type will be required.
A2 Testing Environment
Unless otherwise specified, after the preparation of the Test Specimens, all further processing and testing shall be carried out in a controlled atmosphere of 23 ± 2°C, and at 50% ± 5% relative humidity.
A3 Application of Microdot System
Each Test Specimen shall have the microdot identification system applied to the whole area of the prepared side in a manner such that it replicates the application of the system to a vehicle. This application need not be carried out in the Testing Environment but after application and drying of the adhesive/coating material each treated Test Specimen shall
be conditioned by placing it in a controlled atmosphere of 23 ± 2°C, and at 50% ± 5% relative humidity for not less than
24 hours. During this time the treated prepared side shall be fully exposed.
Prior to the Accelerated Ageing Treatments below each Test Specimen shall be examined under ultraviolet light to ensure that the whole surface of the treated prepared side has been covered with the microdot identification system as indicated by the response of the UV tracer in the adhesive/coating material. Any Test Specimen with less than 90% coverage shall be discarded and a replacement Test Specimen prepared.
A4 Accelerated Ageing Treatments
(a) High Air Temperature—
Two of each Test Specimen Type 1, 2 and 3 shall be placed into an air circulating oven preheated to 110 ± 1°C and maintained at this oven temperature for a period of 168 hours. The treated prepared side shall be fully exposed during this period. The Test Specimens shall then be removed and allowed to return to the Test Environment conditions.
(b) High Humidity—
Two of each Test Specimen Type 1, 2 and 3 shall be placed in a humidity cabinet at 38 ± 1°C with a relative humidity of 97 to 100% and a condensation rate of 1 to 2 millilitres/hour and maintained in this environment for 168 hours. The treated prepared side shall be fully exposed during this period. The Test Specimens shall then be removed and allowed to return to the Test Environment conditions.
(c) Low Air Temperature—
Two of each Test Specimen Type 1, 2 and 3 shall be placed in a freezer at minus 30 ± 2°C for 4 hours. The treated prepared side shall be fully exposed during this period. The Test Specimens shall then be removed and allowed to return to the Test Environment conditions.
A5 Removal Tests
(a) High Pressure Cold Water/Detergent Cleaner Test—
This test consists of cleaning one of each Test Specimen Type 1, 2 and 3 that has been subjected to each of the Accelerated Ageing Treatments, A4(a) High Air Temperature, A4(b) High Humidity and A4(c) Low Air Temperature (ie 9 test specimens in all) using a high pressure cold water cleaner with a detergent injection.
The Test Specimen shall be placed on a flat horizontal surface and the treated prepared side subjected to a high pressure cold water jet with a detergent injection. The minimum outlet pressure of the water jet shall be 110 bar (approximately 1600 psi). The outlet nozzle shall be placed approximately 100mm from the test specimen surface and moved slowly back and forth across the whole test specimen surface for a period of at least 5 minutes such that all areas get approximately the same exposure to the water/detergent jet. The detergent injection used shall be a commercially available degreasing detergent produced for use in high pressure cold water cleaners and injected at the rate recommended by the detergent or high pressure cold water cleaner manufacturer.
Each Test Specimen shall be allowed to dry and then examined under an ultraviolet light. The area still covered with the microdot identification system as indicated by the response of the UV tracer in the adhesive/coating material shall be assessed visually.
Ten microdots shall be removed from each Test Specimen and the information on each microdot read using the appropriate equipment for the system.
The High Pressure Cold Water/Detergent Cleaner Test will be deemed to have been passed if at least 75% of the total surface area of the treated prepared side of each Test Specimen is covered with the adhesive/coating (irrespective of the original area covered – see the second paragraph of section A3) and the data on 9 out of the 10 removed microdots from each Test Specimen can be read completely and correctly.
(b) High Pressure Hot Water Cleaner Test—
This test consists of cleaning one of each Test Specimen Type 1, 2 and 3 that has been subjected to each of the Accelerated Ageing Treatments, A4(a) High Air Temperature, A4(b) High Humidity and A4(c) Low Air Temperature (ie 9 test specimens in all) using a high pressure hot water cleaner (sometimes referred to as a steam cleaner).
The Test Specimen shall be placed on a flat horizontal surface and the treated prepared side subjected to a high pressure hot water jet with a minimum outlet water pressure of 110 bar (approximately 1600 psi) and a minimum outlet water temperature of 85°C. The outlet nozzle shall be placed approximately 100mm from the test specimen surface and moved slowly back and forth across the whole test specimen surface for a period of at least 5 minutes such that all areas get approximately the same exposure to the hot water jet.
Each Test Specimen shall be allowed to dry and then examined under an ultraviolet light. The area still covered with the microdot identification system as indicated by the response of the UV tracer in the adhesive/coating material shall be assessed visually.
Ten microdots shall be removed from each Test Specimen and the information on each microdot read using the appropriate equipment for the system.
The High Pressure Hot Water Cleaner Test will be deemed to have been passed if at least 75% of the total surface area of the treated prepared side of each Test Specimen is covered with the adhesive/coating (irrespective of the original area covered – see the second paragraph of section A3) and the data on 9 out of the 10 removed microdots from each Test Specimen can be read completely and correctly.
Signed at Wellington this 25th day of February 2008.
DONALD NORMAN HUTCHINSON, Manager Vehicles (acting under the authority delegated to me by way of instrument of delegation dated 8 February 2008).
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Explanatory Note
1. The 2005 Vehicle Standards Compliance Amendment Rule facilitates the Whole of Vehicle Marking (WOVM) aspect of the Government’s Vehicle Crime Reduction Programme launched in January 2005. The Rule enables the Director of Land Transport to require vehicles less than 15 years old, which are imported after the WOVM regime comes into effect, to have multiple copies of their vehicle identification number (VIN) attached to them at border inspection or when they are inspected prior to registration.
2. If it is proposed that the multiple copies of the VIN are to be in a form other than microdots, application must be made to the Director of Land Transport or his appointed delegate for recognition of the system to be used. Any such new technology must at least meet the same security requirements as are set out in clause 1.2, the same authenticity requirements as are set out in clause 2.3, and the same extensive application requirements as are set out in clause 2.4. Approval would require
a separate New Zealand Gazette notice.
3. Multiple copies of the VIN complying with the technical requirements in this notice and applied at vehicle manufacture in New Zealand or overseas, or post vehicle manufacture overseas are acceptable. However, if the multiple copies of the VIN from these sources do not comply with the technical requirements in this notice, an application must be submitted to the Director of Land Transport or his appointed delegate for recognition of the proposed system. Approval would require a separate New Zealand Gazette notice.