Conformity of Production (COP) CERTIFICATION PROCEDURE 14 Conformity of Production (COP) The general COP process of 2007/46/EC should be followed Verification of conformity shall be consistent with the requirements for the certification. In case of a process oriented certification, the COP therefore has to focus on process checks. The COP should only include parameters that the manufacturer can control, i.e. testing of input data and internal routines/management systems Component specific COP Process specific “COP” (review)

Component specific COP CERTIFICATION PROCEDURE 14 Component specific COP The legal framework for the RRC values needs to be clarified! Conformity Non-Conformity Remedial Measures

Process specific “COP” (review) CERTIFICATION PROCEDURE 14 Process specific “COP” (review) Identification of objects for review, according to agreed control plan Review of procedures for: Verification of vehicle configuration vs. segmentation definitions and scope Input data management and storage, incl. input data updates Use of certified input data for CO2 calculations corresponding to the vehicle configuration CO2 values storage, including traceability to input data Providing CO2 values for vehicles put on the EU market Are required procedures established and maintained ? Non-Conformity Conformity Remedial Measures

Vehicle testing for validation / verification CERTIFICATION PROCEDURE 14 Vehicle testing for validation / verification Validation of the simulated CO2-values has been done during concept proof Future checks regarding the need of method update are necessary, to improve the methodology step by step, to improve default values, etc. This activity could be required in the CO2 Regulation, but is clearly outside the CO2 “certification” (under EC responsibility). Verification of the calculated CO2-values by vehicle testing shall not be required under a certification based on simulation. The VECTO simulation tool has been assessed and proven sufficient before the introduction in the regulation. If a simplified vehicle test is seen necessary to check input data, the design of this test needs to be evaluated carefully to ensure The objective is clear and understood by all stakeholders The accuracy of the vehicle test is sufficient for all vehicle classes (to be decided), in order to fulfil the purpose of the test To avoid OEM shifting focus towards testing of vehicles under most unrealistic conditions instead of simulating real world condition to assist the customer, the result of the simplified test shall be kept between the vehicle OEM and the “authorities”. The competition between the OEMs will also be a control mechanism of the declared FC/CO2-values...

CO2 regulation for CO2 declaration Complementing testing program CERTIFICATION PROCEDURE 14 Vehicle test for verification / validation – Possible development scenario Certification – Monitoring /Reporting CO2 regulation for CO2 declaration - Certification input data + process - COP of input data + process CO2 regulation update Improvements of procedures - ? (verifications etc ...) “Ex-post validation”, separate activity OK OK Test develop-ment Complementing testing program (Few vehicles/OEM, year) Need of VECTO data updates? Need of additional verification? Useful ? Accuracy/robustness ? Risk of misuse ?