What is CoP?
This page was last updated on 26th May 2022Conformity of Production Audit Procedures
What is Conformity of Production (CoP) and why is it needed?
EU, UNECE, GB and UK(NI) vehicle type approval legislation all require manufacturers to hold Conformity of Production clearance with the approval authority that issue their type approval certification. This clearance is needed before granting of the initial approval and must be updated at regular intervals for the approval to remain valid over the products life.
A vehicle Type Approval 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.
There are two key elements of CoP:
- 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 does the legislation say?
Details on the requirements for CoP are contained in Annex IV of EU Regulation 2018/858 and Schedule 1 of E/ECE/TRANS/505 for ECE Regulations. GB and UK(NI) legislation currently refer to the aforementioned legislation for CoP. These two pieces of legislation, with regard to CoP, are largely similar. Both state that there is an assessment of quality-assurance management systems and verification of the type-approval subject and product-related controls. They also say that accreditation to EN ISO 9001:2015 or ISO/TS16949:2009 may be taken into consideration, but it is not mandated. However, the scope of that certification must cover the product(s) to be approved and conformity of production must be covered by the quality management system. This will need to be demonstrated to VCA at the time of your application or renewal.
What approach do VCA take?
VCA will audit manufacturers who do not hold an ISO certificate for every CoP renewal, with manufacturers that hold EN ISO 9001:2015 or ISO/TS16949:2009 also being audited based or risk or legislation applied for/held.
What form will the audit take?
Audit visits are carried out on a mutually agreed date and to a pre-arranged programme. Audits will vary in length with factors that will be taken into consideration include: company size, previous risk rating and products manufactured. Audits however will be one or two days in duration.
A visit will usually involve:
- A brief opening meeting to clarify requirements and programme details
- A tour of appropriate areas of the manufacturing site(s)
- Examination of the control plan (see ‘Guide to Control Plans, COP-E-GU-09) and audit of the controls defined in that plan to ensure compliance to legislation
- Examination of how change control is handled
- Daily closing meetings to discuss and agree findings for that day
- Final closing meeting to review and agree all findings
A report of the visit is prepared and either left at the time of audit or sent shortly afterwards. Any non-conformances (NCs) will be identified during the audit and a summary of the NCs will be left during the closing meeting.
The closure time scales for the NC’s will be agreed at the end of the audit, and the auditor and technical team will be available to review your closure evidence and discuss suitability.
How could non-conformances affect my ability to produce?
In the case of an initial audit, serious NCs (classed as major) would prevent the issue of the Approval applied for until they were closed with reference to the root cause and may require a follow-up visit to verify rectification. Similarly major NCs on a monitoring visit would be referred to VCA senior management, would need to be rectified within an agreed timescale and could lead to an immediate request to cease production.
Minor NCs would require closure within an agreed time scale. Failure to close NCs with effective identification of the root cause, and good corrective and preventative actions would lead to withdrawal of COP and ultimately withdrawal of Type Approval.
What happens if a CoP Test indicates a non-compliance?
One of the systems we would expect to see would be a record of corrective action taken for all problems found on company CoP checks. In the more serious cases, we would expect a thorough investigation into the cause, including further tests to demonstrate that the problem had been rectified – sales release being suspended until fully satisfied.
Where the problem is found on one of the tests required to be performed at an approved laboratory (eg. seat belts), we should be informed immediately and will discuss and agree necessary action.
What is expected of the small Business?
We appreciate that a small business will not operate controls in the same way as those in large global operations, and the CoP auditors will discuss each situation according to the circumstances. However, the responsibility for quality must be clearly defined and appropriate systems seen operating.
What does it cost?
The maximum cost of an audit is set in Fees Regs 2009 No.719 paragraph 17 and fee number 60028, however a quote will be provided by the CoP department before work commences.
Further advice
If you have any other questions in relation Conformity of Production, our CoP Technical Officers are always prepared to discuss them with you. Please do not hesitate to contact VCA at copmailbox@vca.gov.uk to explain your particular situation
