NZEI SUBMISSION

Date:                    16 December 2025

Subject:               Proposed repeal of the Registered Engineering Associates regime

Name:                  M B Wheeler

Relationship:     President, New Zealand Electronics Institute (NZEI)

QUESTIONS from MBIE reference repel of EARB Act.

1. MBIE has found that the potential harm that could be caused by Registered Engineering Associates is low. Do you agree?
Selected: No, I disagree.
Explanation:
The potential harm is not low. Registered Engineering Associates (REAs) bring a combination of formal qualifications, established best-practice knowledge, and significant practical work experience. These factors directly reduce the likelihood of design errors, installation failures, and misinterpretation of engineering requirements. Removing or diminishing the REA framework could increase risk by allowing individuals without equivalent training or oversight to undertake work with safety or compliance implications.

2. MBIE has not identified any services that require the Registered Engineering Associate credential. Are there any services that require, use, or value it that MBIE has not identified?
Selected: Yes, there are.
Explanation:
The REA credential is recognised and valued across numerous engineering sub-disciplines, including civil, mechanical, electrical, and electronic engineering. In practice, the credential underpins a broad range of design, inspection, commissioning, maintenance, and certification activities. Its value is in providing assurance of competent, experienced practitioners in the mid-tier engineering sector. The breadth of its use is wider than what MBIE currently acknowledges.

3. Do you agree that the alternatives identified by MBIE, including those offered by Engineering New Zealand, are viable substitutes for the Registered Engineering Associate credential?
Selected: No, I disagree.
Explanation:
The proposed alternatives do not adequately cover the mid-tier engineering sector, nor do they offer a comparable value-for-money proposition. Many of the alternatives either operate at a higher professional-engineer level—creating unnecessary cost—or they do not provide the same structured, experience-based competency framework that REAs offer. The REA credential fills a distinct and important gap between tradespeople and chartered professionals.

4. Do you agree with the proposal to repeal the Registered Engineering Associate regime?
Selected: No, I disagree.
Explanation:
Repealing the regime would create significant risks. Without the REA framework, there is an increased likelihood of design errors, performance failures, non-compliant installations, and substandard engineering outcomes. In the worst cases, this may result in serious injury, death, or costly infrastructure and system failures. The regime provides a critical safeguard by ensuring that practitioners possess the required knowledge, experience, and professional accountability.

5. What impact would repealing the regime have on you and those you work with?
Repeal would result in additional work, increased costs for clients, and reduced efficiency. Practitioners above and below the mid-tier level may lack the applied engineering knowledge that REAs provide, leading to more errors, rework, and the need for extensive verification. REAs currently mitigate these issues by validating information, identifying risks, and ensuring that designs and installations meet technical and safety standards.

6. If the regime is repealed, how long should it remain in place, and what transition issues should MBIE consider?
The regime should remain in place until a fully developed and demonstrably superior replacement is available. Although improvements to the current Act are possible, the existing REA system continues to perform effectively and should not be removed prematurely. Any transition must ensure continuity of competency, public safety, and industry capability. Repeal without an equal or better replacement would create substantial gaps in oversight and technical assurance.

Other comments:
There are numerous examples of positive, cost-effective outcomes delivered by REAs due to their applied knowledge and experience. Conversely, there are many instances where work performed by individuals without the REA credential has resulted in expensive failures, safety issues, and avoidable rework. The REA framework provides tangible value to industry, clients, and public safety.