For many businesses, particularly mechanical workshops, parts are purchased new and body panels are not used in the business. Parts used in the general repair and servicing of motor vehicle do not generally fall into the “Traceable Parts” requirements In most cases- the records that a business is required to keep as a traceable record is what is kept for taxation purposes.

Recently there have been some different statements made to businesses as to what is actually required as a traceable parts record.

• As previously highlighted the records DO NOT have to be in the form of a “Police Book”
• Every single part used does not have to be recorded, only those prescribed.
• Air Bags are not currently traceable parts pursuant to the Motor Vehicle Repairs Act 1980. Parts do not have to have individual reference numbers recorded on them as required by auto dismantlers for the Motor Dealers Act 1974.

The essential element of this requirement is that if an authorised officer queries from where or how a specific traceable part was obtained, or where or how it was disposed of; the licensee has the records to show where that part came from/ where it went as the case may be.

For most businesses what is currently being done is acceptable for this requirement. General record-keeping and invoicing is usually sufficient. Most business employ good recordkeeping for other reasons such as taxation

If a business has many front and rear bumper bars and several bonnets on site – these parts may require individual notations such as invoice or rego numbers to show how that part was acquired. In other words, the writing on the parts is the businesses way of complying; it is not a mandatory requirement though.

Business such as mechanical workshops and body repair shops need to be familiar with what are traceable parts and the required records. If a business has lots of used body panels as stock than it is advised to have a manner with which to record where each of those parts came from.

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What are traceable parts?

traceable part means any of the following:
(a)  major body components, that is:
(i)  chassis and major body sections, and
(ii)  bonnets, and
(iii)  right and left front doors, and
(iv)  right and left front mudguards, and
(v)  front and rear bumper bars, and
(vi)  front apron panels,
(b)  major mechanical components, that is:
(i)  engines and engine blocks, and
(ii)  gearboxes and transmissions,
(c)  major car accessories, that is, car radio, tape or compact disk equipment.

parts acquired by purchase means traceable parts that a licensee acquires by purchase in the course of carrying on the business of a repairer.
parts acquired otherwise than by purchase means traceable parts that a licensee acquires otherwise than by purchase in the course of carrying on the business of a repairer.

The record must contain the invoice or document issued to the licensee when acquiring the parts. The licensee must be able to show to whom the part was sold to or the vehicle to which the part was fitted. This can be in the form of the invoice that was issued to the customer- if a second hand door was purchased from an auto dismantler the invoice from the dismantler should be cross referenced in the system to show where it went. For taxation purposes the business should also be retaining invoices of all parts purchased.

The actual Regulation for this requirement is:

 (1)  A record of traceable parts must distinguish between parts acquired by purchase and parts acquired otherwise than by purchase.
(2)  The record of a part acquired by purchase must include the following:
(a)  the invoice, receipt or other document (or a copy of it) issued to the licensee in connection with the licensee’s acquisition of the part,
(b)  details sufficient to identify:
(i)  the vehicle to which the part was fitted by the licensee, or
(ii)  the person to whom the part was sold or otherwise disposed of by the licensee,
      together with the date on which the part was so fitted, sold or otherwise disposed of.
(3)  The record of a part acquired otherwise than by purchase must include the following:
(a)  details sufficient to identify:
(i)  the vehicle from which the part was removed by the licensee, or
(ii)  the person from whom the part was acquired by the licensee,
      together with the date on which the part was so removed or acquired,
(b)  details sufficient to identify:
(i)  the vehicle to which the part was fitted by the licensee, or
(ii)  the person to whom the part was sold or otherwise disposed of by the licensee, together with the date on which the part was so fitted, sold or otherwise disposed of.

The regulations allow the records to be kept in writing or electronically. If kept electronically the data must be able to be printed and must not be able to be altered without leaving a record of the original entry. The records must be kept for a period of 6 years.

Authorised officers (including NSW Police and Fair Trading Officers) are able to inspect records and take copies. Authorised Officers can make enquires as to where parts came from and where they went. Whilst it is not specific in the Legislation Authorised Officers should always act with respect and courtesy.

The Office of Fair Trading inspectors are conducting regular operations in various areas and ensuring that sufficient traceable parts records are being kept is one area that is checked for compliance. If a licensee disagrees with the Inspectors interpretation of a particular matter please contact the MTA for assistance.

This information is a general note on the traceable parts requirement of the Motor Vehicle Repairs Act and Regulations (NSW)- it is not intended to be nor should it be interpreted as legal advice. For specific advice regarding individual circumstances please contact the MTA NSW.