Recommended Changes to the Consumer Information Standards (Used Motor Vehicles) Regulations 2003: Discussion Paper

March 2007

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2. Supplier Information Notice Information Requirements

A. Supplier (Seller) Details

Supplier's Name and Address and Contact Information and Registered Motor Vehicle Trader and Registration Number

Currently, the supplier must state on the SIN their name, address and any other contact information unless the vehicle is displayed for sale by auction. In the case of sale by auction, the auctioneer must state their name, address, and any other contact information in place of the seller's information.

This information gives the buyer the details needed to contact the supplier after the sale to seek redress if things go wrong. In the May 2006 discussion paper, the Ministry of Consumer Affairs did not identify any need to change these information requirements. Feedback from submissions also supported the current SIN requirements.

The regulations also require the supplier to indicate whether they are a registered motor vehicle trader by ticking the appropriate box - "yes" or "no". If registered, they are required to provide their registration number. The seller must leave this space blank if they are not a registered trader.

Providing a registration number enables a buyer to search the Motor Vehicle Traders Register to check the registration status of the trader before they buy the motor vehicle. It is also useful for trader identification purposes if a buyer needs to seek redress or make a complaint against the trader, particularly if they are not selling from a conventional car yard.

Feedback was sought on whether the requirement to leave the space blank when the seller is either a private seller or an unregistered (and illegal) trader, creates confusion. The need for private sellers to provide a SIN arises from section 14(2) of the MVSA that requires car market operators take reasonable steps to ensure all sellers using a car market display a SIN - that is both private sellers and traders.

A suggested alternative (to the yes/no tick box) which was put forward by the Ministry of Consumer Affairs for discussion purposes was that the seller be required to provide either their registered motor vehicle trader number or state unequivocally that the sale is a private sale. The latter statement would be in breach of, and prosecutable under section 13 of the Fair Trading Act 1986, if made by any person treated as a motor vehicle trader under the MVSA, whether registered or not.

The Ministry of Consumer Affairs currently is seeking feedback on proposed changes to the MVSA (see discussion paper Recommended Amendments to the Motor Vehicle Sales Act 2003[1]). One proposed change is to amend the section 14 (2) MVSA requirement that car market operators take reasonable steps to ensure all sellers using a car market display a SIN and instead to require only traders selling through car markets to display the SIN.

If this proposed amendment to the MVSA is made, the SIN would no longer require the registered as a motor vehicle "yes" or "no" acknowledgment. The requirement to note the motor vehicle trader details and registration number, however, would remain.

This issue is discussed more thoroughly in Appendix Two.

B. Sale and Standard Vehicle Details

Cash Price

The regulations require the supplier to state the cash price of the motor vehicle (including goods and services tax) except in the case of sales by auction or competitive tender. For auction sales and competitive tenders, the SIN must state either "for sale by auction" or "for sale by competitive tender" in place of the cash price. No indication of price is allowed.

The Ministry of Consumer Affairs suggested in the May 2006 discussion paper that most buyers' expectation of the cash price is that this is the price they will have to pay to buy the vehicle and drive it away and it is potentially misleading for consumers if they are unaware the cash price may exclude what are referred to as additional "on road costs" (for instance, licensing the vehicle, or registering it in the case of a new import).

Submissions from consumer representatives such as the Automobile Association and the Commerce Commission have expressed strong support that the cash price should be inclusive of all relevant costs - that is all reasonably foreseen road costs such as registration and licence costs. This supports the Ministry of Consumer Affairs view noted above that it is misleading to consumers if the cash price excludes additional "on road costs". The full price to be paid to allow immediate use of the vehicle allows consumers to make uniform price comparisons between motor vehicles. Motor vehicle industry representatives agreed in principle that full costs should be disclosed to potential purchasers but suggested there should be provision for the cash price and separately provision to record additional costs that must be paid.

Considering these two approaches, the Ministry of Consumer Affairs has concluded that for consumers it is easier to have one price clearly presented. We cannot see why it is necessary to separate out the component parts of the price to drive away the vehicle.

The May 2006 discussion paper also sought views on whether the SIN for vehicles for sale by auction or competitive tender should be able to provide an indicative price range.

With respect to an indicative price, auction houses and some consumer representatives indicated a preference to allow for a range of price that the vehicle is expected to sell for. On the other hand, there was quite strong opposition to this approach in other submissions. Weighing up the views, the Ministry of Consumer Affairs notes that indicative prices are akin to market speculation on behalf of the auctioneer. If absolutely required by the auctioneer, indicative prices could be separately indicated to the consumer (in other words by other notice than the SIN).

Disclosure of Security Interests

Section 15 of the MVSA and the SIN require disclosure of any security interest that is recorded on the Personal Property Securities Register (PPSR) or a statement as to the effect of non-disclosure. The disclosure must be consistent with the information recorded about the motor vehicle on the PPSR. On the SIN, the supplier must either state "there is a security interest registered over this motor vehicle" or leave the entry blank.

Views were sought on whether the SIN should require an unequivocal statement that there is not a security interest on the vehicle and whether the requirement to leave the security interest field blank when there is no recorded interest creates confusion for the consumer. It was suggested that a buyer unfamiliar with the regulations may be unsure whether a registered security interest exists when the entry is left blank.

Submissions from consumer groups and the motor vehicle industry supported (or did not disagree), in the main, that an unequivocal statement as to the nature of the security interest should be stated on the SIN. The Law Society, however, was concerned that this would place too onerous a duty on motor vehicle traders.

The importance of the disclosure statement on the SIN is to alert consumers to a security interest if one exists. If a security interest exists but is not declared, the consumer is entitled to free possession of the vehicle and the liability for the security interest is vested back on the trader. As such, either a trader declaring there is "no" security interest or leaving the declaration box blank has the same effect in law. For the consumer, however, a "yes" or "no" statement provides clarity. Accordingly, an unequivocal statement regarding security is recommended.

Note: Some motor vehicle dealers have a "floor plan" finance facility which means a security may be registered over individual cars on the lot of the dealer - these are extinguished when the car changes ownership. These cars are, however, often presented on the SIN as having no security interest. Allowing this practise to continue would have no effect on the consumer because if a SIN is presented as not having a security interest the buyer obtains the vehicle free of any interest that may actually exist. This is because under the MVSA, if a motor vehicle trader fails to declare an existing security interest, then liability is vested back on the trader, and the buyer has free title to the vehicle. On the other hand, if the security interest is declared then the buyer takes on the liability and the vehicle could potentially be repossessed.

Make and Model, Engine Capacity, Operating Fuel Type and Vehicle Identification Number or Chassis Number

The SIN must state the make and model, engine capacity and operating fuel type of the motor vehicle as recorded on the Motor Vehicle Register established under the Transport (Vehicle and Driver Registration and Licensing) Act 1986. It also must state the vehicle identification number or chassis number.

No need to change these information requirements was identified by Ministry of Consumer Affairs and the feedback from the consultation process supported this view. The vehicle make and model, engine capacity and operating fuel type help in assessing performance capability and relative value for the purchaser. For example, a buyer may be looking for specific design or safety features or performance attributes. This information is also used to source parts for vehicle repair and maintenance and may be significant in setting insurance premiums and the vehicle's resale value. The vehicle identification number or chassis number can help identify the vehicle if it is stolen or a dispute arises. These identifiers can also be important in verifying the various date attributes (for example, model year or year of manufacture) of a particular vehicle.

Date Attributes -Vehicle Year, Year of Manufacture and Year of First Registration

The SIN regulations currently require the supplier to state the "vehicle year" of the motor vehicle as recorded on the Motor Vehicle Register. "Vehicle year" is defined in the SIN as either the calendar year in which the vehicle was manufactured or the model year as designated by the manufacturer.

The May 2006 discussion paper noted this definition is problematic because the Motor Vehicle Register protocols are not compatible with the SIN requirements in relation to what can be entered as the vehicle year on the register. The register, run by Land Transport New Zealand, under delegation from the Ministry of Transport, allowed for the vehicle year, prior to 15 December 2003, to be "year of first registration" (YOFR) where the "year of manufacture" (YOM) or "model year" (MY) could not be determined.[2] Thus motor vehicles entered onto the register before December 2003 may have any one of the three attributes (YOM, MY or YOFR) entered into the vehicle year field.

As well, since 2003, the register vehicle year entry for some vehicles has continued to allow YOFR, in part because YOM or MY data is more difficult to obtain and in part because the register requires a four numeral entry, cannot be left blank and does not allow "unknown" to be entered in this field.

This situation presents several options including for the SIN definition of vehicle year to be amended to mean any of YOFR, YOM or MY (in other words to match the Motor Vehicle Register data) or for the SIN to delete reference to vehicle year and to require one or each of YOFR, YOM or MY to be provided. The May 2006 discussion paper sought views on the need for the SIN to have each of YOFR, YOM and MY recorded.

Consumer groups were mixed in their preferences regarding the disclosure of the YOM, MY and YOFR information on the SIN. There was agreement amongst most submitters that the present use of YOM or MY is not appropriate to indicate vehicle year and could potentially mislead or confuse consumers. The AA considered separate fields would be useful whereas the Consumers Institute took the view that the YOFR is the traditional way of defining the age of a vehicle and that if it is considered essential to have other information such as the YOM it should be displayed less prominently.

The motor vehicle trade industry associations indicated their support for the SIN requiring the disclosure of the YOM, MY and YOFR dates. They noted that where the information is unavailable this should be able to be noted on the SIN.

Comment

Discussions between the Ministry of Consumer Affairs, the Ministry of Transport and Land Transport New Zealand (LTNZ) have identified that year of first registration is the most reliable source of information for consumers about the age of a vehicle. For new vehicles, the Motor Vehicle Register accurately records the date of first registration in New Zealand. At the time of registering a used vehicle new to New Zealand, documentation must be provided to LTNZ from the equivalent to New Zealand's Motor Vehicle Register stating when the vehicle was first registered. This information is then recorded on the Motor Vehicle Register and is a reliable source of information for consumers.

On the other hand, model year is not a reliable consumer indicator of the age of a vehicle. This is because model year may be a later date than year of manufacture. For example, production runs for 2007 model cars occur in 2006 and sometimes may be several years earlier. Model year is never an earlier date than the year of manufacture but it can be a later date.

Year of manufacture is also not always able to be obtained from authorised sources such as the Motor Vehicle Register or its international equivalents. Whilst for some vehicles, the year of manufacture can be determined from the vehicle identification number, this source of information cannot be used for Japanese vehicles and some European and American manufactured vehicles. JAMA tables[3] are one potential source of information for Japanese manufactured vehicles. These tables need to be converted, however, to determine year of manufacture. Whilst the Ministry of Transport has successfully trialled a conversion of the JAMA tables into a format that can be sorted electronically into alphabetical order and which could provide a platform for web-based interrogation of the year of manufacture, this is not an authoritative data source. It is also relevant only to Japanese vehicles.

The conclusion reached is that traders need to be able to source year of manufacture data from a reliable source and easily (in order to avoid compliance costs). Consumers need to know the data source is reliable. Although year of manufacture data would be very useful for consumers, given the data cannot be obtained readily from authoritative sources it is inappropriate to require this data to be placed on the SIN.

Providing for year of first registration to be the source of information on vehicle year means that vehicle age attributes are described in a consistent fashion.

Changing the requirement on the SIN to year of first registration removes the current incompatibility between the SIN and the Motor Vehicle Register protocols. The current vehicle year definition in the SIN does not provide reliable information as to the age of the vehicle. In particular, as model year information is not a primary indicator of age its inclusion in this field compromises the usefulness of the data.

Accordingly, the Ministry of Consumer Affairs recommends that the SIN be amended to delete all reference to vehicle year and instead require the inclusion of the year of first registration as recorded on the Motor Vehicle Register.

Actual Distance the Vehicle Has Travelled

The regulations require the correct distance the vehicle has travelled to be recorded on the SIN. If the correct data is not displayed, a statement noting the inability to determine the actual distance travelled must be made.

The May 2006 discussion paper noted industry concern that the requirement to record solely the "actual distance the vehicle has travelled" is too strict for certain situations. Industry argues that there can be legitimate reasons why a vehicle's odometer reading may differ from the vehicle's true mileage. For example, the odometer may have gone around the clock or numbers may have been transposed in manually recording the odometer reading. Industry contends that, in such situations, a responsible motor vehicle trader is obliged to note on the SIN that the "vehicle odometer reading may be inaccurate" and that this is likely to give the buyer the impression the odometer has been tampered with. This could discourage a person from buying what might have been a suitable vehicle.

Views were sought on whether there should be some relaxation in the current disclaimer requirements.

Submissions on this issue supported the SIN continuing to have actual distance travelled or a disclaimer. Several submitters suggested changes to the disclaimer wording. The motor vehicle trade associations commented that the current statements that are permitted are too restrictive and can cause confusion. There was a suggestion in other submissions that tick boxes be provided with options such as "Cannot Verify" or "Accurate". On the other hand the Consumers Institute supported the status quo.

As noted in the May 2006 discussion document, consumer and industry concerns regarding odometer tampering are widely documented. Consumer confidence that an odometer has not been tampered with is vital. Even though a vehicle's mechanical condition may provide a better indicator of its current and likely future capability, many buyers consider the odometer reading a significant indicator of a vehicle's condition and factor this information into their purchase decision.

The Ministry of Consumer Affairs is concerned that providing an option for traders to tick "cannot verify" would effectively become the default tick box. The decision to have odometer reading on the SIN reflects the strong views of New Zealand consumers that this information is considered relevant to their decision making concerning purchase of a car. The Ministry is concerned that any variation to the requirement to enter the actual distance travelled could create an avenue for traders to not make best endeavours to verify and present this information accurately. This risk is considered greater than any reason for relaxing the current requirement and, accordingly, changes to the current requirements are not proposed.

Vehicle Registration and Vehicle Licence

The regulations require the supplier to indicate on the SIN by ticking the appropriate box, whether or not the motor vehicle is currently registered as required by Part 1 of the Transport (Vehicle and Driver Registration and Licensing) Act 1986. The supplier must also state the vehicle licence expiry date as recorded on the most recent licence (whether current or expired). If the vehicle has never been issued with a licence, the supplier leaves the entry blank.

The May 2006 discussion paper noted confusion in this area because the public commonly refers to the annual motor vehicle licence as "registration".[4] The SIN currently tries to address this terminology confusion by saying "Vehicle licence (registration) expiry date."

Views were sought on the best method for notifying a buyer of the vehicle registration and licence status. This is important information as a motor vehicle must be both registered and licensed before it can be legally used on the road. Many buyers will expect to be able to use their new purchase immediately and that the cash price includes all those costs required to allow this immediate use.

Submissions on this issue varied. Some considered it was important for registration and licence information to be on the SIN. Others noted that the licence information was on the windscreen and did not see the need for it to be on the SIN also. In the main it was agreed that the status quo creates confusion.

The Commerce Commission supported licence details being mandatory regardless of when the licence is due to expire. It suggested there be two separate and clearly defined boxes for "Vehicle registration" and "Vehicle licence". It suggested continuing "Registered vehicle" tick boxes "No" or "Yes" and that the Yes box link to "Registration plate number details". It suggested a separate box for "Vehicle licence" and "expiry date of the licence".

The Law Society of New Zealand commented that the SIN would be clearer if the word registration was deleted from "Vehicle licence (registration) expiry date".

Comment

There is no disagreement that vehicle registration and vehicle licence status is important consumer information. If a vehicle is not licensed or registered this means it cannot be used on the road. Requiring a total cost price to be stated (see recommendation 2) means that a consumer will not be misled about any additional costs to obtain registration and licensing before being able to use the vehicle on the road.

If a vehicle is licensed, it is still important to the consumer to know the licence expiry date and therefore when future licensing costs will be incurred. It is also useful to know if a vehicle is unregistered so that enquiries can be made as to why. This could be particularly important if a vehicle has been deregistered.

As noted in the May 2006 discussion paper, it is common for low value vehicles to be auctioned without a current licence. A buyer seeing a SIN has been ticked "Yes" indicating the vehicle is registered may assume the vehicle has a current licence (because of common terminology misunderstanding). Similarly, as noted in the May 2006 discussion paper, it is common for a newly imported used vehicle to be displayed for sale before it has been registered.

Given registration and licensing information is useful consumer information, it is important that it is clear when presented on the SIN. The Ministry of Consumer Affairs concurs with the Commerce Commission suggestion about presenting the registration and licensing information in two separate boxes so that the information is more clearly distinguishable.

Registration Plate Number

The supplier must state the number or distinguishing mark on the registration plate of the vehicle as recorded on the Motor Vehicle Register. As discussed above, it is logical to provide this information on the SIN alongside the tick box "Vehicle registration" "Yes".

The motor vehicle trader associations have suggested "Not yet registered" as an option. This would reduce the confusion that can exist if the field were to remain blank.

The Ministry of Consumer Affairs concurs with this suggestion in that it will help to reduce confusion related to vehicle registration and vehicle licensing. Accordingly, if the vehicle is not registered then "Not yet registered" should be noted to avoid confusion (even if the Vehicle Registration field has been ticked "No").

Warrant or Certificate of Fitness

The supplier is required to note on the SIN (by ticking "Yes" or "No") whether the vehicle has a warrant or certificate of fitness (WoF). The actual expiry date must also be noted.

Views were sought on whether it is necessary for the SIN to provide warrant of fitness dates given they are already provided on the windscreen sticker, should this information have to be provided only if the warrant of fitness is due to expire within 28 days of sale and how should the warrant of fitness dates be given when the vehicle is sold through the internet.

A number of submissions, including those from the motor vehicle trader associations, the Consumers Institute, the AA and the Commerce Commission, considered that given the WoF information can be found on WoF sticker on the window of a car the need to have this information noted on the SIN may not be necessary. The Consumers' Institute suggested this information not be required for vehicles on dealer yards. Other submissions, including from On Tap, who produce electronic SIN for motor vehicle traders, expressed the point that it would be irrational for the buyer to rely upon the licence, registration and WoF information on the window screen of the vehicle because of the increasing use of the internet as the means of sale (buyers are unable to physically inspect the window screen) and the historical record nature of the SIN. It was suggested that with internet sales fraudulent WoF information was possible.

The Commerce Commission commented that the expiry date of the WoF should be included because of the need to have a current WoF at the time of sale.

Comment

The Ministry of Consumer Affairs notes that as with registration and licensing, a warrant of fitness is required for a vehicle to be used on the road. There are various pieces of information on the SIN that can be found without too much difficulty on the actual vehicle. The advantage of the SIN is that useful consumer information is altogether in one document. It is a good consumer checklist. For internet sales, the importance of having core information in one document is particularly important.

Given that not all consumers are aware that a vehicle must have a WoF no older than 28 days at point of sale and that the SIN is a record of core information relating to the car, the Ministry of Consumer Affairs has concluded that Warrant of Fitness information should be displayed on SIN.

Road User Charges Apply and Outstanding Road User Charges

The supplier must indicate (by ticking "Yes" or "No") whether or not the vehicle is subject to road user charges under the Road User Charges Act 1977 and also whether or not there are any outstanding road user charges in relation to the vehicle. All diesel powered vehicles and vehicles over 3500 kg are subject to road user charges. To pay the charges, you must buy a Road User Charge licence.

Views were sought on whether any changes were needed to this requirement. All those who commented, including the motor vehicle trader organisations and the consumer groups, supported the present information disclosure requirements. Accordingly, the Ministry of Consumer Affairs recommend that road user charge information continues to be provided on the SIN.

These are additional costs the buyer needs to be aware of when making their purchasing decision. It is proposed that this information is placed either in close proximity to the cash price or to the entry disclosing operating fuel type.

Re-Registered Vehicle

The SIN requires the supplier to indicate (by ticking "Yes" or "No") whether or not the motor vehicle has been previously registered and then re-registered as recorded on the Motor Vehicle Register. The May 2006 discussion paper asked whether there was any need to change this requirement.

Re-registration is necessary if the vehicle's registration has been cancelled. Common reasons for cancelling registration are that the vehicle has been "written off" by an insurance company, rendered useless or destroyed, or having been unlicensed (and likely not used) for more than one year.

Submissions in the main considered the status quo should remain. A point was raised that a car may have been required to re-register if the registration has simply been allowed to lapse and that this could be confused with a car that has been repaired to a road worthy status after an accident.

The Ministry of Consumer Affairs considers the former occurs infrequently enough not to be concerned with making a distinction on the SIN. Accordingly, no change to the re-registration information required on the SIN is recommended.

C. Information about Imported Used Vehicles

Year First Registered Overseas, Country Where Last Registered and Imported (or Otherwise) as a Damaged Vehicle

The current SIN requires the supplier to state the year the vehicle was first registered overseas as well as the country where it was last registered prior to import as recorded on the Motor Vehicle Register. The supplier must also complete "Yes" or "No" tick boxes to indicate whether imported as damaged vehicle as recorded on the Motor Vehicle Register.

Land Transport New Zealand records on the Register whether or not the vehicle had obvious structural damage or deterioration at the time of import and this is flagged to the vehicle. The extent of damage is not recorded. The key word here is "structural", as this determines whether the flag remains on the vehicle or not. Vehicles with damage that is not necessarily structural - such as a minor dent to a door panel - may be flagged initially, but the flag will be removed following subsequent inspection by a Land Transport New Zealand approved entry certifier. No information on the damage will be retained on the record and, therefore, will not be disclosed on the SIN.

The May 2006 discussion paper noted the motor trade industry viewpoint that as the flag does not identify whether the damage is (was) major or minor, it should not be used as a "definitive categorisation of the vehicle as structurally damaged or incorrectly repaired". The implication from industry is that consumers will not give proper consideration to cars with such a flag, believing the car to have sustained major damage when in fact the damage may have only required a simple repair.

On the other hand, the Ministry of Consumer Affairs noted the flag is useful in that it alerts the consumer to additional history of the car and could aid the purchase decision.

Accordingly, views were sought on whether any changes should be made to the requirement to disclose that a vehicle has been imported as a damaged vehicle.

The motor trade associations, in line with the industry position noted above, submitted that the field should be removed from the SIN. The Commerce Commission, Consumers Institute and the Law Society, however, submitted that consumers being alerted to a vehicle imported as damaged, is core information.

Comment

As noted in the May 2006 discussion paper, the Ministry of Consumer Affairs considers it is important for a buyer to know if a vehicle has a recorded history of structural damage. This information is available to some extent in the re-registration history of a vehicle which may have been damaged in New Zealand.[5] However, it is recognised that this is a very limited source of such information and New Zealand incurred structural damage or repair information is not recorded or required for the Motor Vehicle Register. It is this disparity on which the trade industry voices its concern - also noting that there is not a level playing field between the private seller and the motor vehicle trader in terms of required information disclosure.

Land Transport New Zealand also acknowledges that the information supplied to this field on the Motor Vehicle Register is partial and that it relates only to those vehicles that might have been flagged as possibly damaged overseas and those that have been repair certified at entry or re-entry after structural damage has been repaired.

Whilst recognising all of these issues, the Ministry view point is that it is important that at least the capture-able part of the used vehicle market has this information disclosed. Accordingly, no change is recommended to the SIN imported as damaged vehicle disclosure requirements.

D. Other Information

Japanese Specification Radios

Used vehicles imported from Japan generally have radios which are specifically suited to the FM radio broadcasting spectrum used by Japan rather than that used by New Zealand. This means the radio will not receive many FM radio stations when used in New Zealand.

The use of a "band expander" attached to the radio receiver is a popular remedy but it has inherent limitations on some frequencies and may give degraded reception on other frequencies unless it receives a particularly strong radio signal.

This issue is further compounded by the possibility of new radio stations being licensed that interact with other existing frequencies due to the nature of the band expander's operation.

The use of Japanese specification radio receivers and band expanders has implications for the radio industry.

Radio advertisers and community based stations may potentially miss out on reaching their target audience. The broadcast of information during civil defence emergencies is also a possible issue. Popular radio stations are used as the means to convey information to the public during such times. A motor vehicle with a Japanese specification radio may be unable to receive the emergency information and could possibly compromise the health and well being of the public (although AM frequencies will still be able to be received by these radios).

The Radio Broadcasters Association has submitted that the SIN display whether the radio receiver is suited to New Zealand or Japanese specifications.

Comment

Parliament's Commerce Committee, when recently considering the power of broadcasting licences, accepted the view that the question of use of band expanders is best approached as a consumer issue and has commented in their report on the Communications Legislation Bill that the SIN could be a suitable mechanism for bringing the issue to greater visibility for consumers.

An unequivocal statement as to whether a motor vehicle is fitted with a radio receiver capable of receiving from 88 to 108 MHz should provide sufficient notice for consumers as to the suitability of the radio receiver for their needs (the term base receiver refers to the receiver fitted irrespective of whether a band expander device has been fitted).

A box that could be ticked "Yes" or "No" as to whether the vehicle carried a New Zealand standard radio receiver should be sufficient to alert the consumer to the ability of the radio to receive the normal range of FM stations without degradation.

Not all cars sold on the New Zealand used vehicle market are of Japanese origin so reference to Japanese radios for a European vehicle is unnecessary.

Features and Additional Information Facility

The May 2006 discussion paper asked for feedback on whether additional optional information should be allowed on the SIN alongside prescribed information, for example, additional information, such as features and accessories and information about the number of owners. Currently, such information may not be included on the SIN, but may be supplied on a supplementary form.

When the SIN form was originally developed, the required vehicle details were limited to those that could be independently verified and were meaningful in regard to the basic performance attributes of the vehicle. There were concerns that sale features would be given greater prominence on the SIN and that this would detract from details that were more meaningful, even if less attractive, to the buyer.

Trade associations represented to the review that, historically, their industry did request the ability to provide additional information on the SIN. Significantly, they now consider the status quo should remain. They have noted that the industry has adjusted and is now able to provide additional information through other means such as alternative window cards, websites or through personal interaction with the sales person.

The Consumers Institute submitted the number of previous owners of the vehicle could be included on the SIN as additional information.

The Commerce Commission supported additional information on the SIN provided it did not distract consumers from the statutory requirements of the SIN.

In the light of the trade associations' submission and no other strong views about the need for additional information on the SIN, the Ministry of Consumer Affairs does not recommend any changes to the SIN to allow for additional information to be provided.

Fuel Efficiency Labelling

The May 2006 discussion paper sought views on requiring fuel efficiency information on the SIN. It was noted that fuel efficiency is increasingly becoming a point of interest for consumers.

Since the release of the May discussion paper on the SIN, the Energy Efficiency and Conservation Authority (EECA) released a discussion paper Vehicle Fuel Economy Labelling. Following the consideration of submissions on both discussion papers the decision has been taken not to include fuel economy information on the SIN.

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