Who can fit Lovells GVM and BTC Upgrade Kits and Warranty/Replacement Parts?
Because the Kits are approved on the basis of Lovells Automotive Systems being a Second Stage Manufacturer, and the responsibility ultimately lying with Lovells, only Lovells Authorised Fitters (Production Facilities) are approved to fit our Kits. All GVM and BTC Upgrade Kit’s are supplied with detailed fitting instructions and appropriate documentation.
Is the GCM Upgraded and is the ANCAP Rating Affected?
Note that The GCM (Gross Combined Mass) is not noted on our Second Stage of Manufacture RVD (Road Vehicle Descriptor) nor is GCM noted on the Original Equipment Manufacturers RVD. A GCM figure is also not noted on any OE or SSM Federal Compliance plate, however the figure is usually gazetted or published in handbooks, owner’s manuals, sales brochures or specification sheets.
Lovells RVD (Road Vehicle Descriptor) for each SSM IPA (Identification Plate Approval) notes the New Lovells GVM Capacity and the Maximum Braked Towing Capacity. As a Second Stage Manufacturer, Lovells publish a new GCM Capacity for the vehicle, as we accept responsibility for compliance with the ADRs in relation to that vehicle and are issued a compliance plate approval certificate for that vehicle. As a Second Stage Manufacturer, it is Lovells responsibility to document all applicable ADR tests and compile evidence packages for critical vehicle components, handling, stability, thermal dynamics of powertrain and drivetrain, chassis and mechanical connections and thus take responsibility and liability for the GVM upgrade compliance, increased axle capacities, towing capacities and GCM revisions.
We note that Lovells increase and list new Axle Loading Capacities for each vehicle based on stringent test data and FEA evidence.
The Original Equipment maximum braked towing capacity for example on the Toyota Landcruiser LC200 is 3500kg. This doesn’t increase nor decrease when a Lovells GVM Upgrade is fitted, it remains at 3500kg.
The new vehicle GVM becomes 3800kg (LC200) as noted in Lovells SSM (Second Stage of Manufacture for GVM Upgrade)
The factor that comes into play is the ball weight of the towed apparatus. Whatever the ball weight is, must be subtracted from the vehicles GVM and GCM.
Therefore, the vehicle can still tow up to OE 3500kg. If the ball weight is 200kg, the vehicle’s maximum available GVM (with a Lovells GVM Upgrade kit fitted) will now be 3600kg for the LC200.
Whereas, when a Lovells 4,000kg BTC Upgrade is fitted, the vehicle can then tow up to 4000kg. Yet, if the ball weight remains at 200kg, the vehicle’s maximum available GVM (with a Lovells GVM Upgrade kit fitted) will still be 3600kg for the LC200).
Important Information regarding towing and operating at maximum GCM
Due to increased drivetrain operating temperatures at maximum GCM, Lovells suggest engine, transmission/gearbox, transfer case and differential (s) oil changes to be carried out at half the Original Equipment Intervals. Eg. half the interval of the OEM oil changes, say from 24months/200,000km to 12months/100,000km. Failure to accommodate this may result in premature failure of drive train components which may affect warranty. Constant operation of the vehicle at maximum GVM, Towing Capacity and GCM will reduce the Duty Cycle and life of components and this must be taken into consideration by the vehicle operator.
Pre-registration GCM upgrades
A vehicle’s GCM is first nominated by the original manufacturer (OEM).
There are various organisations, known in the industry as ‘second stage manufacturers’ (SSMs), that are frequently engaged to upgrade vehicle capacity, prior to first registration. Some SSMs, like Lovells, update the GCM to reflect the change in capacity as a result of the upgrade.
Lovells believes that when there has been an upgrade to vehicle capacity pre-registration, it is important for any change to the vehicle’s GCM that has resulted from the upgrade to be noted. Lovells believes this is important for numerous reasons, including for accuracy and safety.
Lovells understands that an updated GCM may be specified by a manufacturer and believes it is good practice for manufacturers to do so.
Who is a manufacturer?
The term manufacturer has a clear definition in the Australian Design Rules
(ADRs), in clause 3 of Vehicle Standard (Australian Design Rule - Definitions and Vehicle Categories) 2005.
The ADRs say that a manufacturer of a vehicle is the person who accepts responsibility for compliance with the ADRs in relation to that vehicle and is issued a compliance plate approval certificate for that vehicle.
The ADRs do not differentiate between OEMs and SSMs.
Based on the definition in the ADRs, Lovells will be considered to be a manufacturer of a vehicle if it accepts responsibility for compliance with the ADRs in relation to that vehicle and is issued a compliance plate approval certificate for that vehicle. Lovells accepts this responsibility as part of its GCM upgrade packages.
Has there been a recent change to the law regulating pre-registration GCM upgrades?
There has been no recent change to the law regulating pre-registration vehicle upgrades.
Lovells understands that the longstanding position for many years has been that while the Federal Department does not assess, endorse or approve GCM upgrades, it equally does not restrict or prohibit GCM upgrades. Lovells understands this longstanding position has not changed.
Importantly, this means that:
Vehicles that Lovells has previously modified are legal in all States and Territories.
Lovells is permitted to plate vehicles with gross vehicle mass
(GVM) upgrades and towing capacity upgrades under the approved RVD (as stated in Lovells SSM approvals and as noted on current RVDs).
Lovells is permitted to modify GVM/GCM/towing capacity or variants of these modifications in all States and Territories prior to first registration.
What is the position regarding post-registration upgrades?
When a manufacturer modifies a vehicle that has already been registered, this modification is governed by the various State and Territory authorities and their individual Type Approvals or Modification Codes. Put simply, these upgrades are governed by State and Territory law.
Whether a particular type of modification is available post-registration, therefore depends on the position in the State or Territory in question. Some of the States and Territories have recently changed their position in relation to post-registration upgrades.
GCM upgrades post-registration
Lovells understands that the current position in relation to GCM upgrades in each State and Territory is as follows:
NSW, SA and VIC recognise a revised GCM specified by a SSM if endorsed by the inspecting engineering signatory. The signatory must be an endorsed engineer who has access to our Evidence Packages. Endorsed engineers’ contact details are available upon request.
Tasmania recognises a revised GCM specified by a SSM.
Queensland no longer recognises a revised GCM above the GCM nominated by the OEM. However, on 22 January 2020, Queensland TMR released a statement to the industry that “TMR is exploring options for the issue of a new code that deals with GCM increases. TMR is working closely with Industry on this task, and in particular the Australian Automotive Aftermarket Association (AAAA). Whilst TMR’s priority remains on road safety and national consistency, it is optimistic that a technically sound and separate code-based solution for GCM re-rating can be developed”.
WA, ACT and NT no longer recognises a revised GCM above the GCM nominated by the OEM if the vehicle is modified after first registration.
Towing upgrades post-registration
NSW, SA and VIC recognise a revised towing capacity upgrade if endorsed by the inspecting engineering signatory. The signatory must be an endorsed engineer who has access to our Evidence Packages. Endorsed Signatories contact details are available upon request.
Queensland recognises a revised Towing Capacity Upgrade based on LS11/LS15/LX1 Modification Codes under the VSA (Vehicle Standards Approval System).
Tasmania, WA and NT no longer allow Towing Capacity over OEM nominated capacity.
How does Lovells ensure that any GCM it nominates is accurate?
Not every SSM can or does nominate a revised GCM.
Lovells does nominate revised GCM capacity figures as a SSM.
Lovells is committed to going above and beyond and believes it is the only SSM that has a full complement of test data and evidence packages to satisfy the December 2019 released GCM and Towing Upgrade Technical Working Group test regime.
This comprehensive new test regime is endorsed by the AAAA, exceeds OEM requirements, and includes the following tests:
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ADR35/05 Testing- Dynamic Braking performance, handbrake performance and gradient starts.
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ADR88 ESC Performance Testing- Sine with Dwell.
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Uprated Axle Assembly Testing- FEA (Finite Element Analysis), lab testing, material testing and CAD modelling.
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SAE J2807 GCM Verification- Driveline and Power train thermal testing.
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SAE J2807 Dynamic Stability testing as a combination. Utilising Lovells test trailer built to SAE standards. This is the only SAE test trailer in the country at present and features include, adjustable draw bar/axle position, adjustable centre of gravity, adjustable moment of inertia, load cells on all components, yaw sensors and data acquisition systems, adjustable aerodynamics and frontal area, adjustable weight distribution with rail slides and interchangeable suspension types.
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SAE J266 Understeer testing as a combination.
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VSB6 GCM verification calculations- Startability and Gradability.
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Combination Vehicle and Trailer Braking test based on ADR35.
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Towing Upgrade Chassis testing and ADR-62/02 testing.
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Towing Upgrade Hitch receiver load testing and durability/cyclic frequency evidence by an independent DIRDC endorsed Test Facility.
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ADR62/02 Evidence- Mechanical Connections between vehicles.
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Laboratory Report ADR-62/02 - 1200lb Weight Distribution System.
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Dynamic Strength Test Report - Lovells 5T Haul Ace All Terrain Hitch.
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Laboratory Report ADR-62/02 - Static Test AS4177.1 -1200lb Weight Distribution System.
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Laboratory Report ADR-62/02 - Static Strength Test.
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Component Registration 47868 Lovells 5T Haul Ace All Terrain Hitch.
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Component Registration 48275 Lovells 1200lb Weight Distribution System.
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Component Registration 48274 Lovells Tow Bar/Drop Shank.
Warranty – OE Components
Once the Lovells SSM compliance plate is fitted to the vehicle, then Lovells Springs bare full responsibility and will warrant any failure directly associated with the GVM and GCM increase. Please see excerpts from Lovells undertaking in all Overview Documents;
‘IS THE ORIGINAL EQUIPMENT WARRANTY AFFECTED WHEN FITTING A LOVELLS GVM UPGRADE?
As a SSM approval holder, Lovells takes full responsibility for the changes the revised GVM, GCM and the Rated Towing Capacity may have on the duty cycle of the vehicle systems and sub-systems (for example, Brakes, Automatic Transmission, Tow Coupling etc) and any follow on effect on warranty claims by vehicle owners.
‘Vehicle warranty is not affected when a GVM or BTC Upgrade (Rated Towing Capacity Upgrade) is fitted. Our testing and analysis procedures are stringent and undertaken by an accredited Automotive Engineering Consultants to ensure original equipment components are not compromised. Modifications and load limits are within theoretical service/safety factors to ensure the integrity and longevity of OE (Original Equipment) parts associated with increasing the vehicles load carrying capabilities. As Lovells are a Second Stage Manufacturer, it is our responsibility to document these tests and thus take responsibility for the GVM, GCM and Rated Towing Capacity Upgrades (BTC Upgrades) and their compliance.
Therefore, should an OE (Original Equipment) component fail and be directly attributed/caused by the vehicle carrying loads to a maximum GVM, GCM and Rated Towing Capacity or part failure associated with the GVM, GCM and Rated Towing Capacity Upgrade modification, Lovells will take full responsibility to cover warranty of any failed component after written proof and testing by an independent body has been lodged and confirmed the failure is due to the vehicles increased GVM, GCM and Rated Towing Capacity.
Warranty excludes any component or system which has been identified by the OEM as having a potential failure or problem.
For example:
Toyota Landcruiser LC70 variants:
Toyota has identified an ongoing issue with potential front differential oil leaks on Toyota Landcruiser LC70 variants, (Toyota Technical News Flash TNF-79/19), Lovells SSM warranty excludes any gazetted failure of OEM components. This exclusion includes parts and labour.
Based on Lovells differential testing, CAD modelling and FEA analysis, there is no satisfactory correlation to the potential premature failure of the differential centre securing bolts loosening/breaking as a direct result of Lovells suspension upgrades.
Ford Ranger PX3 2.0 litre bi-turbo:
Based on Ford Customer Service Bulletin released on 4/3/20, Lovells will not assume any warranty or responsibility for transmission failure on the Ford Ranger 2.0 litre engine variant.
Can a Lovells BTC Upgrade be complied if a competitors GVM Upgrade is fitted to the vehicle?
No. The Lovells BTC Upgrade can only be complied if a Lovells GVM Upgrade is fitted to the vehicle. This is due to all test data, dynamic testing and ADR compliance has been gained with Lovells parts and design parameters.
Can a Lovells BTC Upgrade Kit be fitted to aftermarket tow bars/wheel carrier extension bars?
No. The Lovells BTC Upgrade tongue/hitch receiver/drop shank can only be attached to the Toyota OE Towbar on the LC200 and is not compliant for aftermarket tow bars. For the Prado, the Lovells BTC Upgrade Heavy Duty Tow Bar Assembly, tongue/hitch receiver/drop shank can only be utilized and is not compliant for aftermarket tow bars or non-Lovells brand Hitches.
Can you use another brand hitch receiver/drop shank/Hitch system or Weight Distribution System other than the Lovells kit parts?
No. The Lovells BTC Upgrade can only be complied if Lovells approved/sanctioned BTC Upgrade parts are utilized. This is due to all test data, load testing, dynamic testing and ADR compliance has been gained with Lovells parts and design parameters.
Can you fit a Lovells GVM Upgrade and Lovells BTC Upgrade and Replacement Parts yourself or can your local mechanic fit the kits?
No. Both kits and replacement parts must be fitted and plated by a Lovells Authorised Fitter. A list of Lovells Authorised Fitters can be found at
www.lovells.com.au
GVM Upgrade Fitters are registered as a Production Facility with the Federal Dept of Transport and Infrastructure and linked to our Approvals. They have supplied quality systems documents and are audited every 12 months. They all undergo intensive training for fitting and testing procedures and hold stock of parts to qualify for fitting status. They are signed into legally binding Fitters Agreements.
Can the Lovells GVM Upgrade and BTC Upgrade Kits be fitted to vehicles with KDSS?
Yes. Our Fitting Instructions come with full detail for our Fitters on how to adjust and reset KDSS. Some vehicles trim perfectly, whereas, some require trimming with D/S strut spacers. Height from D/S to P/S within 10-15mm is acceptable on KDSS equipped vehicles.
Is the GVM and BTC Upgrade legal in all States and Territories?
Yes. Rest assured, The Federal Dept of Transport have the final say on all Second Stage Manufacturers Approvals and we cover everything and more as required by the ADRs.
