Questions and Answers from the Conformity of Production (CoP) Workshops 2021

This page was last updated on 2nd March 2023

During and after our CoP workshops at the end of 2021, we were received many questions about the GB Scheme. So, we thought it would be a good idea to list those questions and publish our response to them below. We have listed the questions into groups to make it easier to follow.

Terms and Explanations

Q. What is meant by the term ‘vehicle manufacturer’?

The term ‘vehicle manufacturer’ refers to the approval holder as used by . This is the same for single stage and multi-stage manufacturers.

Q. What is the VCA “risk rating” that is mentioned?

The risk rating process takes into consideration 10 areas of the CoP quality system and gives a score out of 10 for each element. Some areas, such as control plans, cover a higher weighting, so the overall score is out of 190. The risk rating score is used to determine the Conformity of Production (CoP) status for the manufacturer and determine the frequency of future surveillance audits. For each of the assessed areas:

A rating of 0 indicates that no process exists.

A rating of 1 to 4 indicates that processes exist that are either insufficient or not being adhered to.

A rating of 5 to 7 indicates that processes exist which are adequate and are generally being followed.

A rating of 8+ indicates that processes exist that are suitable and highly affective.

Control Plans

Q. Are control plans that are not in English accepted?

Possibly. If we have a trained auditor that can translate the control plan, then we will try to accept them. However, to reduce the time needed to assess the document, it is recommended they are supplied in English.

Q. Is there an expectation/requirement for when the complete testing of the control plan must be finalised for a given model year or is it agreed between the manufacturer and VCA?

This will be agreed with the manufacturer during the meeting.

Non-road mobile machinery (NRMM)

Q. If I produce a trailer that has a NRMM engine affixed to the chassis, am I subject to quarterly reviews?

No, you will not be subject to quarterly reviews. These reviews relate to holders of engine related approvals only and not engines that are not used for the propulsion of the vehicle.

Q. As the NRMM legislation is yet to be published, do you envisage the CoP requirements being any different to what has been explained?

This may change, but currently CoP for NRMM is likely to follow the same format as was presented.

Overseas Approval/Testing

Q. If vehicles are approved for sale in Japan and/or the United States of America, will they require CoP clearance and GB/UK(NI) approvals?

Yes, these vehicles will require GB/UK(NI) approvals and GB/UK(NI) CoP.

Q. If I conduct a CoP test outside of GB/UK, do I need to re-test in a facility in GB or Northern Ireland?

If the GB/UK(NI) product specification is the same as that tested and the test methodology is the same as GB/UK(NI) requirements, then there will be no need to repeat the tests.

Q. Do VCA audit assembly plants outside of the UK?

Yes. This may be supported by one of our satellite offices that are closer to the assembly plant in question.

Q. Does the Manufacturer / Approval holder need to be registered in GB/UK?

No, but in the case that they are not they will require an appropriate representative.  This would need to be a GB-based representative for the GB Scheme and either a Northern Ireland or EU based representative for the UK(NI) Scheme.

Phase 1 statements

Q. I hold e5 approvals where CoP is conducted by VCA. Do I need to sign the Phase 1 statement?

No, you will not be required to sign the Phase 1 declaration as VCA will consider GB/UK(NI) sold product as part of your CoP activity.

Q. Regarding Assembly Plant Statements, are these required for Joint Ventures?

This will depend on the relationship and the operation of each company. The necessity for a letter or not will be determined during the Phase 2 meeting.

Dealers/dealer stock

Q. If one product is retailed through a number of dealers, does each dealer need CoP clearance?

If the dealers are purely retailing an approved product then they do not need CoP clearance.

Q. If an authorised dealer completes the assembly (fits wheels, seat, and so on) and CoP paperwork to submit to the manufacturer for Certificate of Conformity (CoC) issuance, will that authorised dealer require CoP clearance and auditing?

As the dealer is part of the manufacturing process to complete the vehicle then yes, they will need to be included.  Whether they need to be considered an assembly plant and audited depends on the level of involvement and the potential safety implications.

Q. What happens to dealer stock approved to the Provisional GB Scheme after the switch to the full GB Scheme?

If the stock was manufactured prior to the expiration of the GB Provisional Approval, then vehicles can continue to be registered.  The exception is where there is a legislative deadline in regulation for new registrations to meet a certain standard which the vehicle does not comply with.

Miscellaneous Questions

Q. If I hold an approval for vehicle installation of an approved engine, am I subject to quarterly reviews?

Yes, you will be subject to a quarterly review, but the content will be greatly reduced as there will be less emissions reporting required.

Q. If I hold CoP through VCA, do I need to make a fresh application to cover GB/UK(NI) CoP?

You will need to have the scope in place to cover GB/UK(NI) approvals and this can be covered as an extension to your clearance; either as a separate exercise or at the time of renewal dependant on when you require it.

Q. If we purchase approved devices (such as lights) that carry an approval number do the suppliers need to be covered on our CoP clearance?

No. As the parts have their own approval the CoP for those parts is covered by the part manufacturer.

Q. Are accredited facilities needed to conduct CoP tests

In some cases, such as engine emissions and noise testing, yes. Testing can be conducted at manufacturers premises if suitable equipment exists. This does include engine emissions and noise if those areas are appraised by VCA.

Q. If an approval is extended during a period of CoP, does the CoP need to be re-assessed?

If there are no changes to the CoP scope (subject areas) or assembly plant/approval holder / representative structure, then no.

Q. Will small volume manufacturers have any exemptions? Especially on quarterly emission meeting (for example, reduced number of tests required with respect to large volume manufacturers)?

Small volume manufacturers will be treated in the same way as large manufacturers. However, testing requirements may not be as extensive if vehicles are approved using low volume schemes. We recognise that not all manufacturers have the same level of quality systems and control, so this should be proportional to the company size and nature of product.

Q. If we supply bolt-on kits, does this impact CoP in any way?

It depends what the kits are for. If the items impact the type approval, and the kits are added prior to registration, then the organisation adding those kits to the vehicle will need covering on the vehicle manufacturers CoP clearance. Alternatively, the organisation adding those kits could hold a second stage vehicle approval for the addition of those.

Q. For the additional label that is required with names and addresses, does this have to be separate from the VIN plate?

No, it can be part of the same label. However, the name and address must be outside the prescribed area for VIN plates (the label must comply with EU Regulation 19/2011).

If you have any questions, please feel free to send us a message.