Kia ora Aidan Thornton,
 
On behalf of the Ministry of Business, Innovation and Employment I
acknowledge your email of 6/11/2025 requesting, under the Official
Information Act 1982, the following:
 
2.1 Question 1:
Traditionally, paper copies of critical documents like standards,
procedures, and manuals would be amended by providing replacement pages
for a bound copy, or instructing the user to hand-write modifications in
the margins.
Given paper copies of standards are no longer commonplace, and all digital
copies of the Standards with ESAR “modifications” are:
   • Subject to copyright
   • Copy protected (cannot be readily annotated or marked-up)
   • Available with official amendments pre-applied (e.g. AS/NZS
3000:2018+A3)

What is the plan to ensure copies of the Installation Standards with the
ESAR 2025 “modifications” pre-applied are readily available to Electrical
Workers and other users, and/or allow users to apply these modifications
themselves?

2.2 Question 2:
IANZ/NATA and equivalent accredited test houses are required to undertake
product testing to the product Standards as written.
What work has occurred with IANZ/NATA to ensure that the “modifications”
to product standards within ESAR 2025 will:
   • Be enforced when testing product intended for the New Zealand market
   • Be referred to on test certificates in a distinct manner from
unmodified versions of the standards
   • Not invalidate the testing for other jurisdictions using unmodified
versions of the standards
   • Be compatible with the remainder of the Standard, without introducing
contradictions or unintended consequences

2.3 Question 3:
Given New Zealand is a small place that is subject to the same physics and
international standards availability as the rest of the world, what is the
basis for requiring bespoke New Zealand specific standards and rules?
Please provide any available analysis of the cost effectiveness and/or
benefits of these bespoke requirements, particularly regarding concerns
that it could:
   • Unnecessarily result in 'New Zealand only” or “not for New Zealand”
equipment that increases cost and diminishes choice for New Zealanders
   • Cause test certificates issued by New Zealand providers to not be
accepted in other jurisdictions
   • Require expensive and unnecessary double-testing

2.4 Question 4:
Given the choice to regulate prescribed electrical work and electrical
products using Standards as a vehicle rather than using secondary
legislation directly (e.g. ECPs and SWIs), why was the Standards
development process insufficient to ensure the Standards were suitable
without further modification?
 
We will endeavour to respond to your request as soon as possible, and no
later than 4/12/2025, being 20 working days after the day your request
was received. If we are unable to respond to your request by then, we will
notify you of an extension of that timeframe. If you have any enquiries
regarding your request feel free to contact us via email to
[1][MBIE request email].
 
Nāku noa, nā
Ministerial Services
Strategy and Assurance
Ministry of Business, Innovation & Employment
15 Stout Street, Wellington 6011 |  P O Box 1473 Wellington 6140

References

Visible links
1. mailto:[MBIE request email]