Does a vehicle produced at two factories in two countries require COP assessment at both locations? The answer must be established from the applicable regulations, the role of each facility and the evidence of quality control for the completed vehicle.
Clarifying this before implementation helps businesses plan assessments, estimate costs and prepare documentation that matches the actual requirements.
One vehicle, two production facilities
Consider an illustrative scenario: a van is produced at a factory in Europe and then sent to a facility in Asia for conversion into a passenger vehicle before export to Vietnam.
The first factory manufactures the base vehicle. The second facility makes the changes that create the completed configuration. The business needs to clarify which facilities fall within the COP scope, which operations require assessment and which documents demonstrate quality control between the two parties.
Different approaches can affect staffing, factory schedules and overseas assessment costs. COP scope therefore needs to be clarified during project preparation.
COP must relate to the product and actual production activities
COP — Conformity of Production — concerns conformity in production. Article 8 of the original Circular 54/2024/TT-BGTVT sets out assessment content for overseas automobile manufacturing and assembly factories, including the quality-control system and actual production, assembly and final quality-inspection activities.[1]
For the illustrative scenario above, LotusTSE proposes starting with an analysis of the responsibilities and evidence at each facility:
- Which characteristics differ between the base vehicle and the completed vehicle?
- What operations and inspections does each facility perform, and how far does its responsibility extend?
- Who is responsible for the configuration, quality and documentation of the completed vehicle?
- How are the base-vehicle inspection results transferred and controlled?
- Which documents verify the changes made at the conversion facility?
These questions provide a foundation for a documented explanation. They do not replace verification against the applicable regulations or the conclusion of the competent authority.
When interpretations have not yet been aligned
An initial requirement may need further clarification when the documentation does not fully describe the production chain or the allocation of quality-control responsibilities.
Specialist advice adds value by identifying the precise point of disagreement: the entities subject to assessment, the operations to be examined, the extent of product changes or the potential use of existing evidence.
LotusTSE can help businesses assemble technical documents, examine the legal basis and present an approach for consideration by the competent authority. Each proposal needs to identify its basis, conditions of application and the responsibilities that the business and manufacturer must fulfil.
Evidence-based technical dialogue helps the parties understand the issues and work towards an appropriate approach.
From scattered information to a persuasive dossier
For a project involving multiple production facilities, the proposed advisory method has three steps.
First, reconstruct the production chain. The process diagram must show manufacturing, transfer, conversion, inspection and release, with the responsible party identified at each stage.
Second, compare requirements with evidence. Factory documents, type documentation, change descriptions and inspection results need to be reviewed to identify what is clear, what is missing and what requires clarification.
Third, prepare the documented explanation. The dossier needs to present the proposed COP scope, the basis for each element, supporting evidence and the issues requiring consideration by the competent authority.
Advisory deliverables may include a responsibility diagram across facilities, a requirements-and-evidence matrix, a list of additional documents and a written explanation of the assessment scope.
Protecting business interests starts with identifying obligations correctly
Once the scope and implementation approach have been confirmed, the business has a basis for more accurate planning, fewer rounds of document preparation and avoiding unnecessary assessment activities.
Time or cost savings can only be established from the actual results of an individual project. In some cases, the analysis may show that additional controls or a broader assessment are needed to meet the requirements fully.
Protecting business interests also means identifying those obligations early, before delivery schedules are committed or substantial costs are incurred.
For LotusTSE, the value of advice lies in connecting regulations with technical realities, developing clear reasoning and helping businesses select a compliance approach supported by evidence.
If your product is manufactured or completed at multiple facilities, provide the process diagram, a description of the changes and the available technical documentation so LotusTSE can conduct an initial review before COP planning.
LotusTSE — Understand the regulations. Build evidence-based arguments. Protect legitimate client interests.
The scenario illustrates an analytical method. It does not report a completed case or an approved COP approach.
Reference source
[1] Article 8, Circular 54/2024/TT-BGTVT
The cited source is the original text. For a project, check amendments and the regulations in force at the time of implementation.