Who has to submit eCoCs? The manufacturer's legal obligation explained
The question we hear most often from the market is a simple one: who actually has to produce and submit the eCoC? The answer is equally simple. The manufacturer that holds the EU type approval for the vehicle issues the Certificate of Conformity, and from 29 November 2026 it must deliver that certificate as a digitally signed IVI 2.0 XML file to a National Access Point (NAP). Nobody else in the chain is obliged to do it, and nobody else can do it in their own name.
What the law says
The Certificate of Conformity is created by Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles. Article 36 is explicit: the manufacturer shall deliver a certificate of conformity, as a paper document or in electronic form, with each vehicle that is manufactured in conformity with the approved vehicle type. Article 37 adds that the manufacturer shall make the certificate available as structured data in electronic format, which is the eCoC, and the Commission's implementing rules define that format as the IVI (Initial Vehicle Information) XML exchanged through the EUCARIS network and the national access points.
Under the same regulation, "manufacturer" means the natural or legal person that is responsible for all aspects of the type approval of a vehicle, system, component or separate technical unit, and for ensuring conformity of production. In other words, the obligation follows the type approval certificate. Whoever is named on the EU type approval as the manufacturer is the party that must issue the eCoC for every vehicle built under it.
If you are new to the subject, our explainer onwhat a Certificate of Conformity is and how the eCoC replaces the paper CoCcovers the basics. This article focuses on the question of responsibility.
Who is obliged to submit eCoCs
The following parties carry the legal duty to generate, sign and submit eCoCs, because each of them is a manufacturer in the sense of Regulation (EU) 2018/858:
- Vehicle manufacturers (OEMs) holding an EU whole-vehicle type approval for M, N or O category vehicles, whether built in the EU or imported from outside it.
- Second-stage and later-stage manufacturers in a multi-stage type approval, such as body builders, converters and trailer manufacturers that hold their own type approval for the completed vehicle.
- Small-series manufacturers with an EU small-series type approval, and manufacturers of medium series. The eCoC duty applies to all series sizes.
- Non-EU manufacturers (for example Chinese, Korean, US or UK OEMs) selling type-approved vehicles into the EU. The duty stays with the manufacturer named on the type approval, not with the EU entity that imports the cars.
Who is not obliged
Equally important is who does not have to submit eCoCs. These parties handle vehicles and may need to see or forward a CoC, but they are not manufacturers and have no duty, and no right, to issue an eCoC in their own name:
- Dealers and retail networks. A dealer receives the vehicle with its CoC and hands it to the customer. The dealer never issues or submits an eCoC.
- Importers and distributors. Regulation 2018/858 gives importers and distributors duties to check that a CoC accompanies the vehicle and to withhold non-conforming vehicles from the market. It does not make them the issuer of the certificate.
- Fleet operators, leasing companies and private buyers. They register the vehicle using the eCoC that the manufacturer has already submitted.
- Registration authorities and technical services. They consume eCoC data through the NAP; they do not produce it.
- Body builders and converters without their own type approval. If a conversion is covered by the base manufacturer's approval, or is handled through national individual approval, there is no separate eCoC duty for the converter.
At a glance
| Party | Must submit eCoC? | Why |
|---|---|---|
| Vehicle manufacturer (OEM) | Yes | Holds the type approval; Article 36 and 37 of Regulation (EU) 2018/858 |
| Multi-stage manufacturer with own approval | Yes, for its stage | Each stage approval holder certifies its own stage of completion |
| Non-EU manufacturer | Yes | The obligation follows the type approval, not the place of import |
| Manufacturer's EU representative | On behalf of the manufacturer | May operate the submission; responsibility stays with the manufacturer |
| Importer / distributor | No | Must ensure the CoC accompanies the vehicle, but does not issue it |
| Dealer | No | Not a manufacturer; passes the CoC to the customer |
| Fleet / leasing / private buyer | No | Uses the eCoC to register the vehicle |
| Converter without own type approval | No | No approval of its own to certify against |
Which vehicles are covered
The eCoC mandate applies to new vehicles of categories M (passenger cars, buses and coaches), N (goods vehicles N1, N2 and N3) and O (trailers and semi-trailers) that are placed on the market under an EU type approval from 29 November 2026. It applies to complete, completed and incomplete vehicles alike, and to full, medium and small series approvals.
Vehicles of categories L (two- and three-wheelers, quadricycles) and T, C, R and S (agricultural and forestry vehicles) are not yet within the mandatory eCoC scope, although the IVI 2.0 format already carries fields for them. Vehicles registered under a national individual approval do not carry an EU CoC at all, so there is nothing to submit. Used vehicles moving between Member States are registered on the strength of the CoC issued when they were new.
Multi-stage builds: one eCoC per approval holder
Most commercial vehicles are built in stages. A chassis manufacturer produces the incomplete base vehicle under its own type approval; a body builder completes it under a second-stage approval. Each approval holder is a manufacturer for its stage and issues its own certificate. The base manufacturer submits an eCoC for the incomplete vehicle, and the body builder submits a second eCoC for the completed vehicle that references the previous stage. The IVI 2.0 format records this through the StageOfCompletion and PreviousStageTypeApprovalNumber fields, and the national access points validate that the two certificates are consistent.
The practical consequence is that second-stage manufacturers who today receive a paper CoC from the chassis supplier and staple their own to it will need to obtain the first-stage data electronically and generate a conforming XML for their stage. That is a change in process for many mid-sized body builders, and it is where most of the questions about responsibility arise.
What "submitting an eCoC" means in practice
The obligation is not met by emailing a PDF. For each vehicle, the manufacturer must produce an IVI 2.0 XML file with roughly one hundred more technical fields than the paper CoC template, pass it through the EUCARIS Information Checking Module (ICM) rules and the XSD schema, apply a qualified electronic signature in XAdES format under eIDAS, and transmit the file to the national access point of the Member State through its portal or API. A file that fails validation is rejected, and from IVI 2.x a submitted record cannot be deleted, only corrected.
Which access point to use, and which are already live, is tracked in ourEU and UK NAP readiness tracker. The Netherlands and Germany are among the markets adopting ahead of the EU date.
Can the manufacturer delegate the work?
Yes, the work can be delegated. The legal responsibility cannot. A manufacturer's representative established in the EU, a group entity or a software platform such as CoCDesk can generate, sign and transmit the files on the manufacturer's behalf, using the manufacturer's signing certificate and account at the NAP. The eCoC is still issued in the manufacturer's name, and conformity of production remains the manufacturer's responsibility. An importer or dealer acting on its own account cannot step into that role.
Frequently asked questions
Do dealers need to submit eCoCs?
No. A dealer is not a manufacturer. The eCoC for the vehicle is submitted by the manufacturer before or at the point the vehicle is placed on the market, and the dealer simply passes the certificate reference to the customer for registration.
Do importers of non-EU vehicles have to submit eCoCs?
No. An importer must make sure the vehicle is accompanied by a CoC and must not place a non-conforming vehicle on the market, but the eCoC itself is issued by the manufacturer that holds the type approval. A non-EU OEM can appoint an EU representative or a platform to carry out the submission in its name.
Our company converts vans under the base manufacturer's approval. Do we submit?
Only if you hold your own type approval for the completed vehicle. If the conversion is covered by the base manufacturer's approval or by national individual approval, there is no eCoC duty for you.
Does the eCoC duty apply to small-series type approvals?
Yes. The obligation attaches to every EU type approval for M, N and O vehicles, regardless of series size.
What happens if a manufacturer does not submit?
Without a valid eCoC in the national access point, the vehicle cannot be registered in the Member States that have switched to electronic processing. A paper CoC will no longer be accepted for new vehicles once the NAP is live.
Is the obligation the same in the UK?
The UK retained Regulation 2018/858 as assimilated law and the VCA operates its own eCoC portal with the same principle: the type approval holder issues the eCoC. Vehicles sold in both markets need both submissions.
How CoCDesk takes the work off the manufacturer
CoCDesk is built for the party that carries the obligation. The platform handles the whole eCoC workflow, so the manufacturer stays responsible but does none of the manual work:
- Prepare data: vehicle data is pulled from your MES, ERP and digitised type approvals. No re-keying.
- Create XML: every eCoC is generated automatically as an IVI 2.0 compliant XML, including second-stage files built from the first-stage certificate.
- Validate: each file is checked against the XSD schema and the current ICM business rules before it leaves your system, so nothing is rejected at the NAP.
- Sign: the correct XAdES signature format for each NAP is applied automatically under your signing certificate.
- Submit: files go to the national access point through its API, with a dashboard showing the status of every certificate.
- Every category and stage: from M1 passenger cars to multi-stage N and O manufacturers, in the EU and the UK.
Not sure whether the obligation falls on you?
Book a live demo. We will look at your type approvals and your build stages, confirm who has to submit what, and show how the submission runs end to end on CoCDesk.
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