What is CoP?
This page was last updated on 23rd February 2023Once a Type Approval is issued by the VCA, the defines the approved specification range of the vehicle. The manufacturer is then responsible for ensuring all the vehicles manufactured, sold and registered in the applicable market conform to this specification.
Conformity of Production (CoP) is a means of evidencing the ability to produce a series of products that exactly match the specification, performance and marking requirements outlined in the Type Approval documentation. Whether you are a manufacturer, or the agent applying for approvals on behalf of a manufacturer, and whatever your product is, suitable CoP arrangements must be made.
Key elements of CoP
There are two key elements that are required for CoP through the applicable legislation, these are:
- Quality Management System – A system of processes and procedures which control the production of vehicles from design through to sales. One method of demonstrating this is holding ISO9001 accreditation as an organisation, however this is not mandatory.
- Control Plans – A document that demonstrates how ongoing compliance will be ensured for each Type Approval subject, for example inspections or tests which are undertaken during production
What do VCA look for in a Quality Management System?
The Quality Management System should be supporting the business in demonstrating ongoing compliance. VCA will be particularly focused on the elements which relate to the manufacture of products and supporting functions. This includes areas such as calibration, goods receiving, labelling of products and change control.
Change control should be embedded in the Quality System. This is important as helps prevent unapproved changes to products manufactured. If there is a design change implemented into an approval through an extension, how is this change communicated to the plant? If the plant needs to request a change how does the approval holder control this and ensure approval documentation is updated before implementation?
Having appropriate access to legislation is vital for ensuring the continued compliance of the product against changing Type Approval standards. We expect the approval holder to have direct access to the applicable legislation and staff trained to assess the legislation changes and understand the impact on the approvals they hold.
What do VCA look for in a Control Plan?
A control plan should detail the actions being taken by the approval holder to ensure legislative compliance for Type Approval. Control plans must:
- Be owned and controlled by the approval holder
- Have a document reference, version level, be dated and be part of, or referenced within the Quality Management System
- Contain references to the legislation the item is tested / checked against
- Explain what tests and checks are to be done including the inspection of marking
- Outline the test frequency
- Identify who conducts the test
- Indicate the pass / fail criteria
We also need to consider the context of the control plan as part of the CoP clearance and would consider the following:
- Does the control plan relate to the approval issued?
- Does it refer to the correct CoP legislative testing? (if applicable)
- Are the controls in place suitable to determine conformity in relation to the manufacture?
- Are the manufacturing processes the same as previously used for approval?
- Do they relate to the correct assembly site?
- Are component labels checked?
How long will my CoP clearance last?
The maximum time between onsite visits will be 3 years, however this may be shorter based on legislative requirements and the risk-rating that was determined at the audit. However, VCA reserves the right to undertake an audit at any point during the clearance length.
More information of the clearance for the GB Scheme can be found here.
What is the difference between a Supplier and Assembly Plant?
If an item can hold Type Approval in its own right, then it comes from an assembly plant. If the item is a single component which cannot be approved, then it comes from a supplier to be assembled by the approval holder into a product.
Suppliers will provide items such as brake discs, seats, raw materials or mouldings, or air conditioning pumps.
Assembly plants would manufacture the whole or a sub-section of the product, for example a trailer A frame with coupling and axle.
Supplier of component approved items such as lighting, seat belts or spray suppression will already hold CoP in their own right and would not need to be reassessed by VCA as part of the vehicle manufacturers scope.
Test Data
Some legislation requires test data to be submitted periodically, one common example of this is emissions legislation. The VCA CoP team will request data when needed or this may be reviewed as part of a regular meeting agenda item.
The CoP test data will be evaluated by a VCA Compliance Engineer and follow up action may be needed if any questions are raised. Failure to supply data can result in approvals being withdrawn so it is important to follow the tests agreed within the control plan.
Depending on the subject, facility appraisals may be carried out on test facilities where they are different to the lab which undertook the original Type Approval test. VCA will notify you of a need to undertake a facility appraisal.
Common Issues
Not having the required CoP scope and clearance will prevent a Type Approval from being issued or extended. Therefore, it is important to ensure the scope is correct and changes are managed before they are needed. Common issues which delay the issuing of CoP clearance include:
- Approval marking position and content not contained within Control Plan
- Not enough detail in the Control Plan
- Change control does not consider Type Approval
- New assembly plants not included in existing scope
- Application for a new Type Approval subject not included in existing CoP scope
- Address used in CoP Clearance does not match the one in the Type Approval documentation
How to Apply for CoP or Notify us of a Change
If you are not an existing VCA customer you will need to set up an account with us. A Customer Account Application Form can be found in the publications area of our website
Once you hold an account with VCA, please direct all correspondence regarding CoP to copmailbox@vca.gov.uk. We can then discuss your requirements with you to ensure common understanding and then arrange the required audits.
