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4 Technical bulletins

39 Identifying class MB, MD1 or MD2 based on seats on Japanese deregistration certificates


Some vans are entering New Zealand with a number of seats stated on the Japanese deregistration certificate that would place them in vehicle class MD1 or MD2. There is a requirement that vehicles must be compliant in the class they sit in as imported. Therefore a van with a deregistration certificate that states 10-12 seats (and has a GVM not exceeding 3.5t) is an MD1 and one whose deregistration certificate states 13 or more seats (and has a GVM not exceeding 3.5t) is an MD2. Each must be entry certified as the class determined by the number of seats on the deregistration certificate.

However, some of these seating positions, as defined by Japan, are either wheelchair positions or occasional seats (often referred to as dickie seats or jump seats). In New Zealand, the occasional seats are not suitable as seating positions nor do they have the appropriate seatbelts. Also, many importers would prefer to remove the occasional seats and discard them. The issue is the vehicle would then become a 9-seater (or 12-seater) and therefore change class to an MB (or MD1). In both these situations these vehicles would be deemed non-compliant MD1s (or MD2s) and would either have to be brought in line to meet MD1 (or MD2) requirements or have an exemption issued at a cost.


The standards requirements for MD2, MD1 and MB class are identical providing the gross vehicle mass (GVM) is over 2500kg. However, technology requirements differ in that MB class vehicles require ESC. The following resolution is for vans with a GVM over 2500kg entering the country with a deregistration certificate stating more than nine seats:

  • If these vehicles meet the requirements for MB (or MD1) class apart from the number of seats stated on the deregistration certificate, they can be considered MB (or MD1) class providing that they have nine or fewer seats (or 12 or fewer in the case of a change from MD2 to MD1) that meet New Zealand requirements, and the seating is original equipment. Wheelchair positions or occasional seats that have been removed are to be excluded from the seat count.

Vehicle class at import

Number of seats (incl. dickie seats and wheelchair positions)

Number of dickie seats/wheelchair positions removed

Updated number of seats

New vehicle class











Page amended 1 April 2021 (see amendment details)