Reference
What has to exist, and when
Twenty two obligations across nine markets, sorted by the moment they bind rather than by the country they come from, because what goes wrong is almost never which document. It is discovering that the document had to already exist.
Five of these cannot be satisfied after the unit is built. Not with a later certificate, not with a rework, and in Canada not at all: the border agency states there is no provision to modify a non-compliant vehicle into compliance after import, and that it cannot be brought in for parts either. Those five are the reason the matrix is sorted by when each obligation binds.
Every row is a verified external fact read from the regulator or the instrument on 2026-09-04. Where something is open it is recorded as open. The per country routes, with each source and the date it was read, are on registration by country.
True at manufacture, or never · In place before the unit ships · In place before the unit is supplied · In place before the unit is registered · Obligations that continue after the unit is delivered
True at manufacture, or never
Cannot be fixed laterThese cannot be added, corrected or certified after the unit is built. A unit that leaves the floor without them does not become compliant later, it becomes unsaleable, and the loss falls on whoever is holding it.
| Market | What | Why it binds |
|---|---|---|
| Australia | Gas appliance certification An authorised Conformity Assessment Body | Certification must exist at the time of manufacture and cannot be added later. CE and CSA certification are explicitly not sufficient. It is an offence in every state and territory to sell or offer an uncertified Type A appliance. |
| New Zealand | Gas appliance and fitting certification A recognised certification body | Gas appliances and specified fittings must be certified before being offered for sale, and the importer must make a Supplier Declaration of Compliance. |
| United States | Part 567 certification label The original manufacturer | A conforming trailer is admitted on a declaration with no government approval only if the certification label was permanently affixed by the original manufacturer. Without it the fallback route needs a Registered Importer and a bond of 150 percent of dutiable value. |
| Canada | Bilingual Canadian compliance label The original manufacturer | The trailer must be built to CMVSS and carry the label affixed at manufacture. CBSA D19-12-1 states there is no provision to modify a non-compliant vehicle into compliance after import, and it cannot be brought in for parts either. |
| Australia and generally | 17 character VIN under a World Manufacturer Identifier The WMI is allocated to the manufacturer | The identifier is struck into the unit and recorded on the statutory plate. Restriking a VIN is not a correction, it is a defect in the identity of the vehicle. |
In place before the unit ships
Cannot be fixed laterThese bind the movement rather than the build. A unit that sails without them is a unit sitting under customs control at the far end, accruing storage, with no route forward that does not involve sending it back.
| Market | What | Why it binds |
|---|---|---|
| Australia | Import approval under section 22, Road Vehicle Standards Act 2018 The Commonwealth department | It is an offence to import a road vehicle without approval and the Australian Border Force will not release an unapproved vehicle from customs control. Assessment takes up to 60 business days, so it is planned against the build rather than against the sailing. |
| Australia | Concessional entry headroom The Commonwealth department | Concessional entry to the Register of Approved Vehicles is capped at four low ATM trailers of 4.5 tonnes or less per twelve months, and a single vehicle import application is itself capped at four trailers. Above that a vehicle type approval is required, which is a different route with a different lead time. |
| United States | Designated US agent for service of process Designated with NHTSA by the manufacturer, assembler or importer | 49 CFR 551.46 requires the designation before a vehicle is offered for import. It is a filing rather than an approval, and it is the step most often discovered too late. |
| United States | EPA Form 3520-21 for an onboard engine Filed with CBP, against a valid EPA certificate of conformity | A generator on the unit is a separate federal requirement from the trailer. Admission needs the form and a valid certificate for that engine. |
| Canada | VIN specific case by case authorisation The Canadian authority, to the importer | An importer buying directly from a foreign manufacturer not listed on Appendix G obtains authorisation per VIN, and the unit must be purchased directly at the manufacturing level. |
In place before the unit is supplied
Cannot be fixed laterThe unit can be in the country and still not lawfully change hands. In two of these markets supplying without the certificate is a criminal offence rather than a paperwork problem.
| Market | What | Why it binds |
|---|---|---|
| Great Britain | An EU Certificate of Conformity, a national small series certificate, or an IVA certificate The manufacturer, the approval authority, or DVSA | Under the Road Vehicles (Approval) Regulations 2020, Schedule 4 paragraph 1(1), supplying a recordable trailer for use on a road without one in effect is an offence. Penalty is an unlimited fine in England and Wales, or up to three months imprisonment for an individual, or both. |
| Great Britain | DVSA consent for a large trailer DVSA, before supply | Regulation 23 requires the supplier to notify DVSA, provide the pertinent information and obtain consent before supply. DVSA may inspect and test, and consent is withheld until import VAT and customs duty are paid. Large trailer is defined in regulation 26 by unladen weight over 1,020 kg or any semi-trailer, for trailers built to carry goods, and not by the 3,500 kg line. |
| Australia | Entry on the Register of Approved Vehicles The Commonwealth department | Every trailer must be on the register before it is first provided to an Australian consumer. |
| Netherlands | Approval before it is driven or sold RDW | The RDW states the vehicle must be approved before it may be driven or sold, and Article 48(1) of Regulation (EU) 2018/858 conditions making available on the market on approval. The requirement binds selling, not only registering. |
In place before the unit is registered
Route stepThe unit is lawfully in the country and lawfully sold, and it still cannot be driven. These steps happen at the destination, they are the buyer's or the importer's to arrange, and they take time that has to be in the plan rather than discovered in it.
| Market | What | Why it binds |
|---|---|---|
| Germany | Gutachten from an amtlich anerkannter Sachverstaendiger or a designated Technical Service At the applicant's expense | National individual approval under Article 45 of Regulation (EU) 2018/858 is granted by the competent Land authority rather than by the KBA. There is no EU wide individual approval fallback for this product. |
| Germany | Compliance with Regulation (EU) 2019/2144, General Safety Regulation II Evidenced within the Article 45 procedure | Since 7 July 2026 the German Article 45 procedure requires it for categories O1 and O2. The applicable requirement set for a given category is the open question on this market and it is recorded as open rather than assumed. |
| Netherlands | Physical inspection after arrival RDW | Without original vehicle documents or a CoC the RDW asks for documentation on coupling and drawbar, brakes, steering and underrun protection, and states that approval is less certain. |
| France | Individual or isolated reception The regional authority | Required before registration. |
| New Zealand | Warrant of Electrical Fitness to AS/NZS 3001.2 An inspecting electrician | Electricity (Safety) Regulations 2010 regulation 76 bars connecting a connectable installation in a vehicle to a supply without a current warrant. Trailers under 3,500 kg are otherwise VIN exempt and need no entry certification. |
Obligations that continue after the unit is delivered
Route stepTwo of these bind a legal entity rather than a vehicle, which means they cannot be discharged by the factory and cannot be discharged by an offshore seller either.
| Market | What | Why it binds |
|---|---|---|
| Great Britain | Ten year supply record Kept by the final supplier | Regulation 25(3) obliges the final supplier to keep a record of each small trailer supplied for not less than ten years. Breach is its own offence, separate from the supply offence. |
| Australia | EESS Responsible Supplier registration The first importer | Under the Electrical Equipment Safety System the first importer is the Responsible Supplier and must be an Australian or New Zealand legal entity with an ABN or NZ IRD number. An overseas company cannot register. |
| Netherlands | Business stock recognitions RDW erkenning Bedrijfsvoorraad and TVBI | Holding trailers in Dutch business stock and registering them in the company's own name requires both, which require establishment in the Netherlands. Registration by the end customer or a recognised Dutch dealer avoids the requirement. |
What every row above was read from
The documents, and the date each was opened
Each route below was read from the document named beside it, on the date beside it. 8 countries, and where a source is a regulator's guidance page rather than the instrument itself, that is what the row says.
How to read this
Three things it is not
It is not legal advice, and it is not a substitute for the instrument. Every row names where it comes from so it can be checked rather than believed, and a row that turns out to be wrong is corrected on the corrections page with the date and what it was changed to.
It is not complete. Nine markets are published because nine have been read to the source. A market that has not been read does not appear, rather than appearing with a plausible sentence in it.
It is not ours to enforce on you. If you build trailers and none of this is news, that is a good sign for both of us. If some of it is news, it is better learned here than at a wharf.
Set this as an exercise
Procurement, supply chain, international trade- Five of the obligations cannot be satisfied after the unit is built. Identify them and explain, for one, what a buyer's remedy actually is when it is discovered at a port.
- The page is cut by timing rather than by country. Argue for or against that as the correct organising principle for a procurement team sourcing across three markets.
- Canada's border agency states there is no provision to modify a non compliant vehicle into compliance after import. Explain what that does to the risk allocation in a supply contract, and which party should carry it.
Free to set as coursework, print, adapt or put on a slide, on one condition: name the source and link to it. What else is free to teach from.
Written against the build standard, which is the specification these obligations sit inside. What changed and when it took effect is tracked on the change log, and the route for a given unit is on the approval route finder.
Citing this
MODUWRIGHT. "What has to exist, and when." Read 2026-09-04. http://127.0.0.1:8812/standards/evidence
Free to quote, reproduce or set as reading, in whole or in part, on one condition: name the source and link to it. If a row is wrong, tell us and it is corrected.
Take the data
Every row as a file. Free to reproduce in whole or in part, commercially or otherwise, on one condition: name the source and link back to it.
Evidence and timing, CSV · Changes, CSV · Both, JSON · Licence