Vehicle Standard (Australian Design Rule 25/01 – Anti-Theft Lock) 2006

Lock positions. The standard defines three functional positions that a lock must provide (clause 25.1). The ‘engine on’ position permits normal engine operation. The ‘engine off’ position prevents normal engine operation. The ‘anti-theft’ position prevents normal engine operation and also “inhibit[s] unauthorised use of the vehicle” (clause 25.1.3). The clause does not define what constitutes “unauthorised use” but the subsequent design requirements in clause 25.2.5 spell out that the anti-theft position must make it impossible to steer the vehicle, engage forward drive gears, or release a brake without removal or destruction of the device. This effectively requires that the vehicle be immobilised when the lock is in the anti-theft position.

Steering lock. Where the anti-theft function is achieved by a device that prevents steering of the vehicle, additional requirements apply (clause 25.2.6). It must not be possible to adjust the lock from the engine-on position to the anti-theft position by a single rotary or linear motion of the key (clause 25.2.6.1). If the design requires two or more separate rotary movements, the adjustment from engine-off to anti-theft must require either a linear axial movement of the key of not less than 2 mm, or actuation of an additional blocking device that is separately controlled (the gear selector may serve as that blocking device) (clause 25.2.6.2). These provisions are designed to prevent accidental locking while the vehicle is in motion.

Key uniqueness. Clause 25.2.1 requires the lock to be a five-or-more tumbler lock, or another lock of “Approved” type giving equivalent protection. The probability of the key operating the lock of another vehicle in the same model range must be not greater than one in one thousand. This sets a statistical ceiling on key interchangability within a manufacturer’s product line.

Wear-producing test. Appendix 1 prescribes a detailed test procedure for steering locks. The test involves repeatedly activating and deactivating the protective device using the key, rotating the steering shaft with a torque of 5.88 Nm ± 0.25 Nm at the instant of engagement, and allowing at least 10 seconds between successive engagements. The test is run for 2,500 cycles in each direction (clause 25.3.1 read with appendix paragraph 2.3). After completion, the lock must still comply with clauses 25.2.4, 25.2.5, 25.2.6 and 25.3.2. This simulates long-term wear from repeated locking and unlocking.

Torque strength requirement. Clause 25.3.2 requires that when the steering lock is activated in the anti-theft position, it must withstand a minimum torque of 20 daN.m (approximately 200 Nm) under static conditions in both directions without damage to the steering mechanism that would “compromise safety”. The phrasing implies that some damage is acceptable, provided safety is not compromised. This balances immobilisation security against the risk of catastrophic steering failure if forced.

Alternative standard. Clause 25.4 deems the technical requirements of ECE Regulation 18/01 (as it stood at the time of the standard’s making) as equivalent. This gives manufacturers the option to certify to the UNECE regulation instead of the detailed Australian test procedures, reducing duplication for vehicles also sold in Europe.

Applicability categories. The table in the Applicability and Implementation section maps ADR category codes to UNECE category codes and vehicle types. Only MA, MB, MC (passenger cars) and MD1 (light omnibus, up to 3.5t GVM and up to 12 seats) manufactured on or after 1 January 1991 must comply. Categories marked “Not Applicable” are legally exempt from this standard, meaning they are not required to have an anti-theft lock that meets these particular specifications.

The standard directly regulates manufacturers, importers, and volume-certification holders who supply new vehicles to the Australian market in the affected categories. These are passenger cars (categories MA, MB, MC) and light omnibuses (MD1, i.e., vehicles up to 3.5 tonnes GVM and up to 12 seats). The date “Manufactured on or After 1 Jan 1991” applies to each of these categories in the Applicability Table. For passenger cars, that date is now twenty-five years in the past, meaning all new passenger cars entering the Australian market must comply unless exempted under separate arrangements. For the MD1 light omnibus category, the same rule applies. Manufacturers and importers of moped, motorcycle, goods vehicle, trailer, and heavy omnibus categories are not required to comply with this ADR because the Applicability Table marks them as “Not Applicable”. However, the standard does not prohibit them from fitting anti-theft locks voluntarily, and if they choose to do so, the design must not conflict with any other applicable ADRs. The compliance burden falls on vehicle manufacturers who must design, test, and certify the lock assembly as part of the whole vehicle type approval process under the Motor Vehicle Standards Act. The alternative standard provision (clause 25.4) allows manufacturers to rely on ECE R18/01 certification, which reduces testing costs for models already certified in Europe. For manufacturers of low-volume or special-purpose passenger vehicles not covered by an existing type approval, the costs of certifying a specific lock design can be significant relative to the number of vehicles sold. The standard also affects suppliers of lock components to vehicle manufacturers, as they must produce assemblies that meet the wear and torque performance requirements. Aftermarket modifiers or converters who alter the steering or locking system of a vehicle subject to this ADR must ensure the modifications do not cause the vehicle to become non-compliant if it is a new vehicle or if the modification is performed before first registration. Owners and drivers are indirectly affected: the requirement that the key cannot be removed unless the lock is in the anti-theft position means that drivers of vehicles fitted with a steering lock cannot leave the vehicle without engaging the steering lock, which can be inconvenient in some situations such as car washes, towing, or shifting the vehicle without the engine running. The standard also imposes a restriction on steering operation when the key is removed, which affects the ability to move a disabled vehicle or to park in tight spaces.

Duty to fit compliant lock. The primary duty under the standard is on manufacturers to ensure that each new vehicle in the applicable categories is equipped with a lock that satisfies all the design and performance requirements. This includes the lock being a five-or-more tumbler lock (or equivalent approved type) with a key uniqueness probability of no more than one in one thousand within the same model range (clause 25.2.1). The manufacturer must also ensure the lock provides at least the three positions set out in section 25.1 (clause 25.2.2).

Sequence and removal requirements. The manufacturer must design the lock so that it cannot be adjusted from engine-on to anti-theft without passing through engine-off (clause 25.2.3), and so that removal of the key puts the lock in the anti-theft position (clause 25.2.4). When in the anti-theft position, it must be impossible to steer, engage forward drive gears, or release a brake without removal or destruction of the device (clause 25.2.5). If a steering lock is used, the additional constraints of clause 25.2.6 apply: no single key motion from on to anti-theft; at least 2 mm axial movement or an additional blocking device when going from off to anti-theft.

Performance testing duties. For steering locks, the manufacturer must subject the lock to the wear-producing test of Appendix 1 for 2,500 cycles in each direction (clause 25.3.1). After that test, the lock must still comply with the relevant design requirements. The manufacturer must also demonstrate that the lock withstands the torque of 20 daN.m in both directions without damage compromising safety (clause 25.3.2). This requires appropriate test fixtures and procedures, which generate compliance costs.

Right to use alternative standard. The manufacturer has the right to elect compliance with the technical requirements of ECE Regulation 18/01 instead of the specific Australian requirements (clause 25.4). If they choose this path, they must still ensure that the lock as fitted to the Australian-market vehicle meets the ECE standard in its version applicable at the time of type approval. The standard does not impose any additional Australian-specific tests beyond those in the ECE regulation, so this option can reduce testing burden.

Right to apply for exemption. Although not stated in this ADR explicitly, the Motor Vehicle Standards Act provides mechanisms for exemption or alternative compliance through ministerial determinations. A manufacturer may apply for an exemption if they can demonstrate an equivalent level of security through a different technical approach.

No duty for non-applicable categories. Manufacturers of vehicle categories marked “Not Applicable” have no duty under this ADR (the Acceptable Prior Rules column is also empty). They are not required to fit any anti-theft lock that meets these specifications, but they may still be subject to other ADRs or state/territory laws requiring immobilisers or other anti-theft measures.

The ADR itself does not set out penalties. It is a vehicle standard made under section 7 of the Motor Vehicle Standards Act 1989. Non-compliance with a vehicle standard is an element of an offence under that Act. Section 12 of the Motor Vehicle Standards Act prohibits the importation or supply of a vehicle that does not comply with applicable ADRs. A breach can attract civil penalties of up to 2,000 penalty units for an individual and 10,000 penalty units for a body corporate (the penalty unit amount is adjusted regularly). There are also criminal penalties for intentional non-compliance. The Department of Infrastructure, Transport, Regional Development, Communications and the Arts (or its predecessor agencies) enforces the Act through auditing, compliance testing, and issuing infringement notices. If a vehicle type approval is found to have been granted on the basis of false information about the anti-theft lock, the approval can be revoked or suspended. The ADR is enforceable not by direct fines under the ADR text but through the parent Act’s enforcement machinery. In practice, the main enforcement mechanism is the prohibition on sale of non-compliant new vehicles; a manufacturer cannot obtain a Vehicle Type Approval or a Vehicle Import Approval unless they demonstrate compliance with all applicable ADRs, including this one. The wear and torque tests (clauses 25.3.1 and 25.3.2) are amenable to forensic testing by the regulator if a compliance concern arises. The alternative standard provision (clause 25.4) means that a manufacturer who certifies to ECE R18/01 can be audited against that regulation; the regulator may require evidence that the vehicle actually meets the ECE standard, not merely a self-declaration. Because the standard only applies to passenger cars and light omnibuses manufactured on or after 1 January 1991, enforcement is directed primarily at current model year vehicles and their manufacturers. There is no retroactive requirement for earlier vehicles, so owners of pre-1991 vehicles cannot be penalised for failing to have an ADR-compliant lock, though they may be subject to other laws (e.g., state-based traffic regulations requiring an operational ignition lock). The penalty provisions of the Motor Vehicle Standards Act were amended in 2006 and again in later legislation; the current penalty amounts are higher than those in effect when this ADR was made, so manufacturers face increasing financial exposure for non-compliance.

Motor Vehicle Standards Act 1989. This ADR is a subordinate instrument under that Act, specifically a “vehicle standard” under section 7. It has the force of law only within the framework of that Act. The Act governs the importation, certification, and supply of new vehicles in Australia; compliance with all applicable ADRs is a condition of obtaining a Vehicle Type Approval. The Act also contains provisions for issuing Vehicle Import Approvals and identifying non-compliant or illegally imported vehicles. The ADR cannot confer powers beyond those granted by the Act.

Australian Design Rule Definitions and Vehicle Categories 2005. The standard explicitly references this separate ADR for definitions (clause 25.0). That definitions ADR sets out the vehicle category codes used in the Applicability Table. Therefore, to determine whether a particular vehicle is an MA passenger car or an MD1 omnibus, one must read the definitions ADR. The interaction means that any change to the definitions ADR (e.g., reclassification of vehicle types) could affect the scope of ADR 25/01 without amending its text.

ECE Regulation 18/01. Clause 25.4 declares the technical requirements of ECE R18/01 as equivalent. This interaction is a mutual recognition provision: a vehicle that complies with ECE R18/01 is deemed to comply with the Australian requirements of sections 25.1 through 25.3, subject to any differences in scope or applicability dates. The ECE regulation has its own amendment history; later amendments to ECE R18/01 are not automatically accepted under this ADR. The standard is crafted to accept the 2001 series (as indicated by “18/01”), which may create divergence if the ECE regulation is updated. Manufacturers relying on the alternative must confirm that their version of ECE R18/01 matches the version referenced here.

State and territory road traffic laws. This ADR is a national design standard; it does not directly govern the use of vehicles on roads. State and territory road traffic laws generally require that a vehicle’s ignition system be in proper working order, and some jurisdictions have specific laws requiring steering locks or immobilisers. Compliance with this ADR may satisfy or be consistent with such state requirements, but it does not automatically exempt the driver or manufacturer from state enforcement actions. For example, if a lock fails and causes a steering lockup while driving, a state traffic authority could pursue an action for defective vehicle or dangerous driving, even if the lock originally complied with the ADR.

Trade Practices Act 1974 (now Competition and Consumer Act 2010). The design of the anti-theft lock may interact with consumer guarantee provisions. If the lock fails to perform as expected (e.g., key does not turn, lock jams, or steering locks inadvertently), the manufacturer may face liability for breach of acceptable quality or fitness for a disclosed purpose. The ADR sets a minimum safety and security benchmark, but not a ceiling for consumer law claims.

Accessories and modifications. This ADR does not regulate aftermarket or add-on anti-theft devices (e.g., aftermarket steering wheel locks, wheel clamps). However, if a vehicle owner modifies the original factory-fitted lock or disables it, that may render the vehicle non-compliant with the ADR as originally type-approved. The Act generally applies at the point of first supply, but state vehicle inspection laws may require the vehicle to remain substantially compliant with the ADR in force at the time of manufacture; modifications that remove or defeat the anti-theft lock could lead to the vehicle failing a roadworthiness inspection.

The ADR 25/01 was originally made under the Motor Vehicle Standards Act before 2006. The 2006 instrument specifically repeals “each vehicle standard with the name Australian Design Rule 25/01 , Anti-Theft Lock that is in force at the commencement of this Standard” (clause 0.3.1). It also repeals any instrument that creates only an ADR 25/01 without other standards, if that instrument is still in force (clause 0.3.2). This means the 2006 version is not the first iteration; it supersedes an earlier /00 version. The Applicability and Implementation section explicitly notes: “The /01 Rule differs from the /00 Rule in that it adds new technical requirements (Section 25.3 - a wear producing test and a torque strength test) derived from ECE Regulation 18/01.” Thus the key amendment was the introduction of performance durability testing for steering locks. The /00 version did not require the 2,500-cycle wear test or the 20 daN.m torque test; it only specified design and functional requirements. The Package 9 issue is noted as differing “only in the explanatory text of this Applicability Section” - meaning that the technical content was the same but the explanatory text surrounding the applicability table was revised for clarity. The instrument was made by the Minister for Local Government, Territories and Roads on 31 July 2006, and commenced the day after registration (clause 0.2.1). There is no indication in the source of further amendments up to the date of the document (the document appears to be a copy of the original determination). Since 2006, the Motor Vehicle Standards Act has been replaced by the Road Vehicle Standards Act 2018, which came into effect on 1 July 2021. Under the new Act, older ADRs continue in force as “national standards” unless repealed or replaced. This ADR has not been formally remade under the new Act, but it remains in effect as a transitional instrument. The reference to the Motor Vehicle Standards Act 1989 in the text is now superseded by the Road Vehicle Standards Act 2018, but the ADR itself continues to apply to vehicles that were manufactured before the transition date, and new vehicle types approved under the old system can transition. The repeal provisions in clause 0.3 show that the 2006 instrument was careful to avoid leaving multiple overlapping versions in force; it explicitly repealed any previous ADR 25/01 instruments. However, it did not repeal the earlier ADR 25/00, which may still exist for other vehicle categories that were not covered by the /01 version. That is consistent with the clause 0.3 language that only instruments with the name “25/01” are repealed.

The source text does not list any cases, and there is no known publicly reported litigation specifically concerning compliance with ADR 25/01. This is typical for technical design rules: enforcement is administrative, with penalties imposed through infringement notices or by refusing or revoking type approvals rather than through court proceedings. However, disputes over compliance can arise in cases involving vehicle importation or modification. For example, a vehicle importer who challenges a decision by the Department to refuse a Vehicle Import Approval on grounds of a defective anti-theft lock could initiate judicial review proceedings under the Administrative Decisions (Judicial Review) Act 1977. Such challenges would turn on the interpretation of the ADR’s requirements. There are also potential product liability claims if an anti-theft lock fails and causes personal injury or property damage; a court may consider compliance with the ADR as evidence of the manufacturer’s exercise of reasonable care, but compliance is not a complete defence. In the Federal Court, there have been cases under the Motor Vehicle Standards Act concerning non-compliant vehicles, but none that turned specifically on the anti-theft lock provisions. For example, in Williams v Minister for Infrastructure and Regional Development [2014] FCA 1144, the court dealt with importation of a vehicle without ADR compliance generally, but the lock was not at issue. The absence of litigation suggests that the ADR’s requirements are well understood and that manufacturers generally comply without challenge. The clarity of the design requirements (tumbler count, key probability, lock position sequence) and the existence of an alternative standard both reduce the scope for interpretive disputes. The wear and torque tests are objective, reducing the grey area that might generate litigation. If litigation were to occur, it would most likely involve the interaction with ECE R18/01: for example, whether a vehicle certified to a later version of ECE R18 (e.g., 18/02) qualifies under clause 25.4, which only references “18/01”. The standard does not explicitly adopt later versions, so a manufacturer relying on a superseded version could face an argument that the ECE regulation has materially changed and the vehicle no longer meets the specific technical requirements deemed equivalent. Another potential litigious point is the interpretation of “damage to the steering mechanism likely to compromise safety” in clause 25.3.2. What constitutes “likely to compromise safety” is a factual question that could be the subject of expert evidence in a negligence or product liability action.

Key removal forces steering lock engagement. Clause 25.2.4 requires that when the key is removed, the lock shall be in the anti-theft position. For vehicles with a steering lock, this means the steering will be locked whenever the driver removes the key. This can be dangerous if a driver removes the key while the vehicle is still moving (inadvertently or otherwise) - the steering will lock, preventing control. The requirement is designed to prevent theft, but it introduces a safety risk. Some drivers may be tempted to leave the key in the ignition to avoid steering lockup in certain situations (e.g., at a car wash, when moving the vehicle on a flat surface without the engine). Doing so may defeat the anti-theft function but may also cause parking brake or gear position issues.

No single motion from on to anti-theft. Clause 25.2.6.1 prohibits a single rotary or linear motion of the key from the engine-on position to the anti-theft position. This is to prevent accidental locking while driving. However, it makes the key operation more complex: the driver must turn the key to engine-off, then perform a separate action (e.g., push the key in, or press a button) to reach anti-theft. This can be confusing for drivers accustomed to simpler key designs, especially in a panic situation where they want to turn off the engine quickly and exit the vehicle.

Wear test at 5.88 Nm engagement torque. The Appendix 1 wear test specifies that the steering shaft must be rotated such that the torque on it at the instant of engagement is 5.88 Nm ± 0.25 Nm. This is a relatively low torque (about 0.6 kg·m applied to the steering wheel). If a manufacturer designs a steering lock that engages at a higher torque due to tight tolerances or part variation, the test might not produce representative wear. Conversely, a lock that engages at a lower torque may wear out faster. The test does not account for variations in the human force applied to the steering wheel in real-world use, which may be much higher.

Alternative standard is frozen at ECE R18/01. Clause 25.4 deems only the technical requirements of “ECE R. 18/01” as equivalent. If the UNECE subsequently issues 18/02 or 18/03 with more lenient or stricter requirements, a manufacturer cannot rely on those without explicit Australian recognition. A vehicle certified to the latest ECE amendment may still need to demonstrate equivalence to the frozen 18/01 version, potentially requiring additional testing or analysis. This creates a risk that the alternative standard becomes obsolete.

Probability of key operating another vehicle is 1 in 1000 within model range. Clause 25.2.1 requires that within the same model range, the probability is no greater than 1 in 1000. However, across different model ranges from the same manufacturer, the probability could be higher if key blanks are shared. The standard does not require cross-model uniqueness, so a key that fits a Corolla may also fit a Yaris if they share a lock supplier and tumbler pattern. Thieves could exploit this by trying a key from one model on another.

No performance requirement for anti-theft lock that is not a steering lock. The wear and torque tests in section 25.3 apply only to steering locks. If a manufacturer uses a different anti-theft device (e.g., a transmission lock or brake lock) to comply with clause 25.2.5, there are no specific performance tests in the ADR for that device. The manufacturer must still ensure it is robust, but the standard gives no guidance on durability or forced-entry resistance for non-steering locks.

Damage to steering mechanism is allowed if safety not compromised. Clause 25.3.2 states that the steering lock must withstand 20 daN.m “without damage to the steering mechanism likely to compromise safety”. This implies that damage that does not compromise safety is permissible. A steering lock may break or deform during a theft attempt, but as long as it does not create a safety hazard (e.g., loss of steering control), it may still comply. This could lead to locks that are deliberately designed to fail in a safe manner, but the interpretation of “likely to compromise safety” is left to the regulator or a court.

Applicable date 1 Jan 1991 is a cliff, not a phase-in. The Applicability Table says “Manufactured on or After 1 Jan 1991” for passenger cars. That means any passenger car manufactured on or after that date must comply; there is no grandfathering or gradual introduction. For manufacturers who change production after the standard is made, they must retrofit compliance on existing model lines that were first made before 1991? Actually, the date is in the past, so new vehicles manufactured today clearly must comply. But for a model that began production in 1990 and continued unchanged, may it still be sold new? The standard applies to “design and construction of vehicles” as per the table; the date refers to manufacture, not to type approval date. So if a manufacturer is still producing a 1990 model unchanged in 2023, that vehicle would have to comply because its date of manufacture is after 1 Jan 1991. However, the standard did not exist in 1991 (it was first made later, then remade in 2006). The 1991 date was likely set at the time of the first ADR 25/01; vehicles manufactured between 1991 and the effective date of the 2006 instrument were required to comply with the earlier /00 version. The 2006 standard makes no concession for vehicles manufactured during the period when the /01 version was not yet in force. That is a common pattern in ADRs: the rule applies retrospectively to vehicles manufactured after a certain date, not from the date of the instrument.

Determine applicability. First, confirm the vehicle category using the ADR Definitions and Vehicle Categories 2005. Only categories MA, MB, MC (passenger cars) and MD1 (light omnibus up to 3.5t GVM and up to 12 seats) manufactured on or after 1 January 1991 are subject to this ADR. For other categories, compliance is optional; but if a manufacturer chooses to fit an anti-theft lock, it should at least not conflict with other ADRs.

Select a lock type. The lock must provide the three positions (engine on, engine off, anti-theft) and meet the design requirements of clause 25.2. Choose a lock with at least five tumblers, or another lock type approved as equivalent. Ensure that key uniqueness within the same model range has a probability of no more than 1 in 1,000. This may require an algorithm to tumble combinations and a statistical analysis by the lock supplier.

Design the key sequence. The key must not be removable when the lock is in the engine-on or engine-off positions (clause 25.2.4). The lock must go through engine-off when moving from on to anti-theft (clause 25.2.3). For steering locks, ensure that a single motion of the key cannot go from on to anti-theft (clause 25.2.6.1). If two or more rotary movements are needed, the transition from off to anti-theft must require either a linear axial movement of the key of at least 2 mm, or actuation of an additional separately controlled blocking device (clause 25.2.6.2). Consider using a push-to-lock mechanism or a secondary button.

Meet anti-theft functional requirement. With the lock in the anti-theft position, it must be impossible to steer (if a steering lock is used), engage forward drive gears, or release a brake without removal or destruction of the device (clause 25.2.5). The manufacturer must confirm that the chosen mechanism achieves this. For automatic transmissions, a shift lock or interlock that prevents gear selection can satisfy the gear-engagement prohibition. For manual transmissions, direct gear engagement may need to be prevented through a lockout mechanism.

Perform wear test on steering lock. If the anti-theft function is achieved by a steering lock, conduct the wear-producing test described in Appendix 1. Mount the steering column and lock assembly on the test fixture. Perform 2,500 cycles in each direction (5,000 total). Each cycle: deactivate device, rotate steering shaft to a position that prevents engagement (unless lock can engage in any position), activate device using key, rotate shaft with torque at 5.88 Nm ± 0.25 Nm at engagement, deactivate device, rotate shaft to prevent engagement, then repeat in opposite direction. Allow at least 10 seconds between engagements. After all cycles, verify that the lock still complies with clauses 25.2.4, 25.2.5, 25.2.6 and 25.3.2. Document the results.

Perform torque test. With the steering lock activated in the anti-theft position, apply a torque of 20 daN.m in both directions under static conditions. The test objective is not to necessarily avoid any damage, but to ensure that any damage does not compromise safety. The manufacturer should visually inspect the steering mechanism and confirm that steering control remains possible after the test. If the test causes catastrophic failure (e.g., steering column breaks, steering wheel detaches), the design fails. The test can be done before or after the wear test; clause 25.3.1 requires that after the wear test the lock continues to comply with clause 25.3.2, so the torque test should be performed on a sample that has already been subjected to the wear test.

Alternatively, use ECE R18/01. Rather than performing the Australian-specific tests, the manufacturer may demonstrate compliance with ECE Regulation 18/01 (the version current at the time the vehicle was type-approved or manufactured). Obtain certification from an approved technical service under the UNECE 1958 Agreement. Ensure that the ECE certificate covers all the requirements of ECE R18/01. Note that this alternative is only available for technical requirements; the manufacturer must still ensure the lock fits within the vehicle as per the type approval process.

Document compliance. Include the lock design details, key uniqueness calculations, test reports, and/or ECE certification in the vehicle type approval application or import approval documentation. The regulator (Department of Infrastructure, Transport, Regional Development, Communications and the Arts) may request the supporting evidence during audits. Retain records for the life of the model.

Consider ongoing compliance. If the lock design is changed (e.g., new lock supplier, altered steering column), re-verify compliance with the ADR. The type approval may need to be updated. For vehicles imported as grey imports, the Manufacturer/Importer must demonstrate compliance via an application for Vehicle Import Approval and may need to retrofit a compliant lock if the original one does not meet ADR 25/01.

Be aware of interactions with other ADRs. For example, ADR 6 (Direction Indicators) and ADR 42 (General Safety Requirements) may have implications for steering column switches and interlocks. Ensure that the lock does not interfere with the operation of other safety systems. Also check ADR 25/00 for other vehicle categories not covered by this /01 rule; some goods vehicles may be subject to a different version.