Questions and answers - Designation of technical services

Here you can find questions often asked about Designation of technical services

Can an accreditation replace a designation?

An accreditation is not sufficient for designation as technical service by the KBA.

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Can an accreditation be taken into consideration in a designation procedure?

An accreditation can be taken into consideration by the KBA in a designation procedure when

• The accreditation body is located in the European Community
• The accreditation is issued according to Regulation (EC) 765/2008
• At least one of the standards relevant for the designation is accredited.

On basis of such an accreditation, the KBA checks the

• Fulfilment of the approval relevant requirements
• Standards and test procedures which are not included in the accreditation.

If requested, after appropriate checking of the delta, the designation can cover other revisions of relevant regulatory acts.

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Are foreign designations recognized by the KBA?

The designation of other EU member state can be taken into consideration in designation procedure analogous to an accreditation.

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Can the laboratory of a manufacturer be designated as technical service?

A laboratory of a manufacturer can only be designated as a technical service when the relevant regulatory act explicitly allows this. Otherwise, the manufacturer’s laboratory should consider the option that a designated by the KBA technical service supervises the tests in the manufacturer’s laboratory and creates the test report.

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Test laboratories and certification bodies of which countries can be designated as technical services?

Laboratories and certification bodies must have its commercial registration in the European Union. Subsidiaries in other countries can be included in the designation when certain preconditions are fulfilled.

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Where can I find more detailed information on the KBA designation procedure?

You can find detailed information in the Designation section. Designation rules and application forms can be found in the download section. Please contact also our staff of the department in charge (benennungsstelle@kba.de, +49 351 47385-0).

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Which test laboratories and certification bodices have been designated by the KBA?

The section "Downloads" contains directories of all technical services that have been designated by the KBA with information on the scope of the designation, sorted from various points of view. After notification, the designated technical services are published also on the Internet pages of the EU and UNECE.

Test laboratories: "Type Approval procedure"

Certification bodies: "Initial assessment and Procedure for Verification of Conformity of Production"

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Which support is given by the KBA in the designation procedure? Is training offered?

The KBA supports the laboratory or certification body in the run-up to the application with consultations. No fee will be raised when such consultation is held at the KBA offices. There is also the possibility of making arrangements for a preliminary assessment.

Training sessions are held on basic knowledge of the designation procedure and for qualification of persons authorized to sign test reports and auditors. If you are interested, please send your request per e-mail to benennungsstelle@kba.de.

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What is the nature of a designation?

The type-approval authority confirms by a designation that a technical service

• Fulfils the standard (EN ISO/IEC 17020/17021-1/17025) as given by the relevant regulatory acts and the specific requirements of the KBA type-approval procedure, and
• Is so competent to carry out testing as stated in the scope of designation.

The KBA designation procedure is based on the requirements of the EG-Fahrzeuggenehmigungsverordnung (EG-FGV) and corresponding UNECE requirements. The procedure is also used for the national regulatory acts. The “designation” term is synonymous with the “recognition” term, as is used in the EG-FGV.

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Why is designation necessary?

In its type-approval procedure, the KBA uses only test reports from laboratories that have been designated as technical services by the KBA. Orders for checking whether a product is produced in conformity with the approved type are also given only to such laboratories.

When a certification body for quality management systems wants to be active in the type-approval procedure, it must also be designated as a technical service by the KBA.

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Which certificates are accepted in the KBA type-approval procedure?

The following conditions must be fulfilled for a certificate to be accepted in the KBA type-approval procedure:

• The certification body has been designated by the KBA as a technical service and shows this on the certificate, or accompanying attestation of the fulfilment of approval relevant requirements.
• The document explicitly details for which of the products to be approved (or approved products) the approval-relevant requirements are fulfilled.
• A Report on CoP is submitted.

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Questions and answers - Issuing of type-approvals

What must be observed when there is a change in the production plant?

The type-approval holder must inform the KBA when there has been a change in the legal entity, the name and/or the place of residence of the production plant, whether legally dependent or legally independent production plants.

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What is to be observed on a threatened insolvency?

The KBA must be timely informed on the threatened insolvency.

The KBA must be informed at the latest on the opening of the insolvency procedure. During the insolvency proceedings, the KBA further provides new type-approvals and extensions. The application for these must be made via the legally appointed insolvency administrator. The type-approval will be first sent to the type-approval holder after the receipt of the approval charges.

The existence of a type-approval is bound to the existence of a legal entity (type-approval holder). If the legal entity (type-approval holder) is no longer existent after the closing of the insolvency proceedings, the type-approval becomes invalid.

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What must be observed when a company changes its name or legal form?

The KBA must be timely informed on such changes. The company must prove that the type-approval holder up to now has only be renamed or converted. The presentation of an actual official registration document (commercial register excerpt, for example) can confirm that the legal entity further exists.

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The company will soon be sold, what must be given attention to?

The validity of a type-approval is bound to the existence of the legal entity (type-approval holder). It is fundamental, that type-approvals cannot be transferred. It is essential to inform the KBA early in such a case, so that it can be examined if there is a legal successor. The type-approval can only remain valid when the legal entity is maintained.

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What must be considered on external production, i.e. when the final approval-related production step is taken by an other company?

A type-approval holder himself or herself can manufacture in legally dependent and/or legally independent production plants. In the case of legally dependent production plants, the KBA must only be informed.

In the case of legally independent production plants, an original contract or one-sided declaration on the basis of the manufacturer’s capacity must be provided to the KBA (forms in the Information sheet on Initial assessment (MAB))

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What are approval-relevant requirements?

The approval-related requirements are given in the document “CoP information”. In the main, the following requirements are to be fulfilled:

• approval-conform production; fulfilment of the basic rules and the type-approval itself
• quality management that ensures the planning and effective implementation of preventive, control and corrective measures
• sufficient product testing and data recording (if given by the rules, is sufficient)
• traceability and recall of non-conform products from the market
• influence on possibly used external manufacturers
• timely information to the KBA on all (planned) changes with regard to the data, that is given as basis of the type-approval and that are informed upon in the application procedure

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How long must the type-approval holder keep the type-approval documents?

From the extinction of the type-approval on, the storage time for the documents is to be the same as the anticipated life cycle of the product, but at least 3 years.

These storage times are only valid for the relationship between the type-approval holder and the KBA. They do not replace any legal requirements from other regulations nor stipulations of contracts (e.g. suppliers-OEM).

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How will the approval mark look?

How a approval mark must look is determined by the selected rule. When there are uncertainties as to the appearance, the intended approval mark should be submitted together with the application documents.

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How long will the type-approval process take?

A rapid issuing of a type-approval requires complete and fault-free documents. When this is the case, the KBA attempts to keep to times of 14 calendar days.

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What does a type-approval cost?

The cost is calculated according to the Gebührenordnung für Maßnahmen im Straßenverkehr (GebOSt – German scale of fees for road traffic measures). How much a single type-approval costs can be determined from the cost scale.

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Which special duties does the holder of a type-approval have against the end-user?

In national type-approvals for vehicle parts according to §§ 22 (Allgemeine Betriebserlaubnis (ABE)) or 22a (Allgemeine Bauartgenehmigung (ABG)) Straßenverkehrs-Zulassungs-Ordnung (StVZO – German law for authorization of vehicles for road traffic), he or she must provide the buyer with a print of the type-approval.

He or she must provide information on the installation conditions and the limitations of use of the vehicle parts in both national and international type-approvals.

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What is to be observed when the production of the approved product is temporarily or permanently closed down?

When the KBA has knowledge of whether production is temporarily or permanently closed down, all participants save expenditure and costs (e.g. the taking of products for conformity testing).

The KBA must be informed immediately when the production is permanently closed down.

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How long must test samples be kept?

Test samples are only to be kept when they are for type-approval obligatory parts (refer to § 22a of the Straßenverkehrs-Zulassungs-Ordnung (StVZO – German law for authorization of vehicles for road traffic)).

When nothing else is determined in the type-approval, the storage time is 5 years from the extinction of the type-approval.

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A QM certificate is available. What must it contain to be recognized?

The certificate must

• be made out by a KBA designated technical service (certification body) and point to the designation (logo and/or registration number)
• certify the maintenance of approval-relevant requirements and
• the certificate and the written confirmation must relate to the production of the product that is to be approved.

Further information is given in Information sheet on Initial assessment (MAB)

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What is meant by type designation and what are versions?

Type designation is a technical term of the type-approval regulations. Type defines a certain technical specification of a product to be approved well. How different the technical specification of a product within a type can be is regulated by the chosen rule. The limits of a type are regulated by the so-called type defining criteria.

There can be several versions within a type.

The applicant can determine the designations of the type and the versions.

Type designations used for sales purposes are frequently not sufficient for the requirements of the type from the rules and regulations of the type-approval procedure. It is therefore seldom appropriate to use sales designations as type designation.

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What happens when a type-approval is sold to an other company?

The type-approval becomes invalid.

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Can type-approvals be transferred to an other company?

A transfer to an other company is possible under some conditions. It is essential to integrate the KBA early in such a case otherwise the type-approval will become invalid.

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Must the contract or the declaration for the establishment of the manufacturer’s capacity be submitted for each new type-approval?

No. The documents only need to be again submitted when the actual contract or declaration do not list the new object to be approved.

Tip: To avoid the renewed making out of a contract or declaration, only give the type of equipment or vehicle class instead of a concrete type.

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Must the contract or the declaration for the establishment of the manufacturer’s capacity from the Information sheet on Initial assessment (MAB) be submitted with original signature?

The contract or the declaration for the establishment of the manufacturer’s capacity must be filled in and signed and this original version must be submitted to the KBA.

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Can the number of the type-approval pre-approved?

The number of the type-approval can pre-approved.

Basic condition here is a completed initial assessment. An application is to be given for a type-approval which additionally applies the announcement of the type-approval number in advance.

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Which technical service will test my product?

The technical service must be designated by the KBA according to the relevant test procedure (the relative scope).

For information on which technical service can carry out the testing for national type-approval (Allgemeine Betriebserlaubnis (ABE), Allgemeine Bauartgenehmigung (ABG)) in individual cases, the Designation body of the KBA must be contacted.

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Why do manufacturers need an initial assessment?

A type-approval does not only provide rights but also duties. The legal identity is checked so that it is clear who is responsible for the compliance of duties. The QM process is evaluated so that an estimation can be made on whether the production is type-approval-conform and if appropriate reaction can be given in case of deviations.

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Questions and answers - Conformity checks

Here you can find questions often asked about Conformity checks

Are CoP-Q inspections carried out when a type-approval holder is audited in a 3-year rhythm in the scope of verification?

An inspection can become necessary when

• either the confirmation of verification only comprises of a "Teilegutachten" (vehicle part test report) and national (ABE, ABG) or international type-approval (EC, UN-ECE) are to be acquired,
• or the KBA has not been informed on an actual verification of the production of the type approved object.

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Are CoP-Q inspections carried out by KBA when a type-approval holder is subjected to an audit for a recognized standard (e.g. DIN EN ISO 9001 or similar) each year?

An inspection is regularly carried out when the KBA has no knowledge on whether a technical service designated by the KBA regularly checks fulfilment of the approval-relevant requirements.

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How long is the interval between CoP-Q type-approval holder inspections?

CoP-Q inspections are spot checks. When no grave non-conform facts are determined, no further regular inspection is carried out.

Exceptions: see the following question

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When are CoP-Q type-approval holder inspections carried out?

CoP-Q inspections are carried out:

• according to an annual plan that is created by those responsible section,
• reason-related, when the KBA receives factual information that pertains to the conformity of the approved object or the perception of other type-approval holder obligations that make an inspection necessary
• or when the KBA is not informed that a technical service designated by the KBA as certification body regularly checks fulfilment of the approval-relevant requirements.

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What is the matter and content of a CoP-Q type-approval holder inspection?

The implemented QM-system and, in particular the measures and procedures that have been introduced, are checked in the framework of a CoP-Q inspection to determine if they are effective and further suitable to ensure the conformity of the products produced with the approved type. In addition, a check is made on whether other obligations of the type-approval holder against the KBA are attended to.

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Questions and answers - General questions

Here you can find questions often asked about General questions