Most QMS records are a matter of judgement. Was that counter conversation a complaint? Did that toolbox talk count as training? Reasonable people disagree, and a reviewer has to weigh what they are shown.
Label custody is not like that. A book is thirty sequential numbers. Every one of them is either on a windscreen, spoiled, reissued as a duplicate, or still in the book. There is no fifth category. Which makes this the one register on a WOF site that can be checked by arithmetic — and the one where "I'm sure it's fine" is the least defensible thing you can say.
What changed on 1 April 2025
NZTA announced in February 2025 that from 1 April every inspecting organisation would need to hold a duplicate WoF and CoF label register, capturing the reasons those labels were issued. The stated purpose was plain: NZTA wanted information on all duplicate labels issued nationally.
The requirement went into section 5.5 of the Model Quality Management System for CoF and WoF Inspecting Organisations, the section covering management of inspection and certification documents. That section already required you to keep documents out of public reach, to lock unused controlled documents away outside business hours, to file them so they can be readily retrieved, to hold sufficient stock, to report loss or theft immediately, and to keep an up-to-date controlled documents record. The duplicate label register was added to the end of that list.
The half of the section people skip is the half that says what NZTA will do. At review, a reviewer will talk to your staff, inspect your used and unused documents and the places you keep them, inspect how you file them, inspect your controlled documents record — and inspect your duplicate label register. It is a named line item, not an inference.
An example register file sits in the Portal under QMS In-service certification. Seventeen months on, plenty of sites have never downloaded it.
The three ways label custody actually fails
The book that does not add up. A label gets torn, misprinted or applied to the wrong windscreen and a fresh one comes off the book. Nobody writes it down, because at the time it is a two-second annoyance rather than an event. Six months later the book is short and there is no record saying why. The site knows what happened. It cannot show it.
The duplicate that was never recorded as one. A customer loses a windscreen, or the label is destroyed in a repair, and a replacement goes on. That is a duplicate, and since April 2025 it belongs in a register with a reason attached. This is the failure I expect reviewers to find most often over the next year, because the register is new and the practice predates it by decades — sites have been issuing duplicates correctly and recording them nowhere.
The label that is simply gone. This is the serious one. The loss or theft of a controlled document has to be reported immediately to the New Zealand Police and to NZTA on the notification form. Not investigated internally first, not raised at the next monthly meeting. A drawer of unaccounted-for labels is a document-control failure, not an admin oversight, and the absence of a Police reference number is what converts it from an incident into a finding.
Why the nil return is different here
With complaints or training, an empty register is ambiguous — it might mean nothing happened, or it might mean nothing was captured, and a reviewer has to form a view.
With labels there is a harder test available, and it is the reason a reviewer inspects unused stock as well as used. Count what is left in the book. Add the exceptions and the duplicates. Add the labels your check sheets say you issued. If those numbers do not reach the number you started with, the gap is a fact, not an impression — and every unexplained number in that gap is a controlled document you cannot account for.
That cuts both ways, which is the useful part. A site that logs its spoils and its duplicates as they happen can put the book in front of a reviewer and have the conversation finish in about ninety seconds. Nobody gets that outcome from a complaints register.
Where WoFMate sits
To be precise about what the platform does: the QMS Compliance Centre carries a WOF label register on Professional and above. A book is entered once — start number, end number, date received — and from then on the arithmetic runs itself. Issued labels are read off your own check sheets, not typed in again, so the count of labels on windscreens comes from the inspection records rather than from a tally somebody maintains. Spoiled and replaced labels are logged as exceptions against the book. Duplicates go into a separate duplicate label register carrying the label number, the registration, the reason and the date, and each one is deducted from its book's remaining count. Every entry records who made it and when. Lost and stolen documents have their own register, with the Police notification date and reference held alongside the NZTA form.
What that gives you is a book that reconciles continuously instead of at audit time, and a duplicate register that fills itself in as a by-product of recording the duplicate — which is the only way a new requirement survives a busy Friday.
What it does not do is make the decisions. Whether a label is mislaid or stolen is your call, and so is picking up the phone to the Police. NZTA approves digital check sheets, not QMS software — there is no approval regime for a QMS system, whatever a supplier implies.
Three things worth doing this month
- Reconcile your current book by hand, once. Start number, labels issued, spoils, duplicates, what is physically left. If it balances, you have just built your own evidence. If it does not, you have found something while it is still small enough to explain.
- Open the duplicate label register, even if it is a spreadsheet. One row per duplicate with a reason. It has been required since April 2025 and a reviewer will ask for it by name.
- Agree the lost-or-stolen trigger before you need it. Write down who decides and who calls the Police, so the decision is not being made for the first time by whoever happens to be on the counter. Label custody and stationery ordering are classic QMS tasks that everyone assumes someone else owns.
Label stock is the least glamorous thing in the registers an IO has to keep, and the one most likely to be straight already — the practice is usually sound and only the record is missing. That is a cheap gap to close before a reviewer arrives, and if the count does turn up short, closing it properly means a corrective action with an owner and a close-out test, not a promise to be more careful.