By Liyi Signal Product Team | September 28, 2026
Buyers see one document: the approval certificate. Behind it sits an obligation that lasts as long as the approval is used — the requirement to demonstrate that series production still matches the sample that was approved.
Under the 1958 Geneva Agreement, that obligation is verified through Conformity of Production activity. In Spain, the approval authority — UCA, the body responsible for initial factory and COP audits — commissions authorised technical services to carry out the inspections. One form this takes is a COP document audit: a structured review of the manufacturer’s records, conducted before or alongside on-site verification.
Understanding what that audit requires is useful for buyers, because it is the clearest available picture of what a genuine manufacturer has to maintain.
The Documents an Approval Holder Must Produce
The requirements fall into eleven practical areas.
1. Legal and organisational identity
Business licences for both the manufacturer and the production factory, translated into English, plus the system certificates held by each (ISO, TS, and similar) and the organisation structure of both entities.
The separation of “manufacturer” and “production factory” in this list is deliberate: where production is carried out by a different legal entity, both must be documented.
2. Quality system
The quality manual — which must define the authority and responsibilities of the person responsible for ECE certification, and must match the person registered with the authority, including name and contact details. Alongside it: the second-level procedure files and their index, plus management review and internal audit records.
3. Personnel competence
Competence requirements for the homologation responsible role, with training records. The certified person has to be a real, documented position, not a name on a form.
4. Homologation management
The E9 homologation management documents, regulation update management with records of updates since certification, and documented procedures for communication with authorities — covering product recall, cessation of production, technical or administrative modifications affecting approvals, and changes to the registered signatures of the manufacturer or its representative.
5. Design control
The design and development process, and specifically the design change management procedure for products covered by an approval. This is the mechanism that keeps a certified product identical to what was approved.
6. The COP control plan
A formal plan for the certified product covering the homologation type, test items, test frequency, test methods, acceptance criteria, the analysis data and recorded results, rectification measures, and how nonconforming product is controlled. It must be a controlled document bearing the company name and a valid controlled seal.
7. COP test evidence
Annual COP test reports produced according to that plan, together with calibration certificates for the equipment used in the tests.
8. Production statistics
Annual production figures for every E9-certified type or component, recorded against the matching approval number, in a defined format covering make and type, approval number, regulation, product description, annual production, and the corresponding COP test report number.
This is what makes an approval traceable to physical volume: the authority can see how many units were produced under each approval and which test reports cover them.
9. Subcontracting
Where processes such as annual COP testing are subcontracted, an agreement covering production authorisation of homologated products, plus the subcontractor’s ISO/IEC 17025 certificate and the scope it covers.
10. Purchasing and supplier control
The purchasing process itself, supplier evaluation, selection and monitoring, and — critically — supplier monitoring records that include confirmation of COP conformity for suppliers of components used in certified products.
11. Marking
Photographs showing the approval marking applied to the homologated product or component.
Two further items in the list — end-of-series management and COC management for EWVTA vehicle types — apply to vehicle manufacturers rather than component suppliers.
Two Operating Notes
The audit plan may be modified as the audit progresses, and the manufacturer is required to provide every document the audit verifies. Neither point is negotiable in practice: an approval holder that cannot produce the records on demand is not in a position to demonstrate conformity.
What This Means for Buyers
Most of these documents are internal. Four of them are worth requesting directly:
The design change management procedure — proof the supplier can notify you before a certified product changes.
The COP control plan — shows what the supplier tests, how often, and against what criteria.
The most recent annual COP test report — evidence the production currently being shipped is still covered.
Supplier monitoring records covering component conformity — the link that makes traceability complete when a failure occurs.
A reseller cannot produce these. That is the practical value of the list: it separates manufacturers from intermediaries more reliably than any statement in a sales presentation.
Liyi holds E9 approval registered to its own entity and, supported by an ISO 9001 quality system, has maintained its annual production conformity inspection cycle for more than a decade.
FAQ
Q: What is the difference between a COP document audit and a factory inspection?
A: A document audit reviews the records and systems behind an approval — quality manual, procedures, test reports, statistics, and supplier control. A factory inspection verifies the records against what is actually happening on the production line. Both support the same conformity obligation.
Q: Does a new company need to have completed all of this before applying?
A: No. The requirements describe what an approval holder must maintain continuously, from certification onwards — including update records kept since certification and annual test reports produced year by year.
Q: Why does the audit ask for both the manufacturer’s and the production factory’s documents?
A: Because the conformity obligation applies to where the product is actually made. Where these are different legal entities, the approval framework requires the relationship to be documented and both entities to be capable of meeting the requirements.
Before you place an order against an approval, ask for the supplier’s design change procedure, COP control plan, most recent annual COP test report, and component supplier conformity records. LIYI provides these documents on request.
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