The question seems quite simple at first – one could simply say, according to the wording, that the permit holder is the one who is the holder of a permit.

In principle, this is also not wrong, but ultimately leaves too many aspects undescribed, especially the rights and obligations of the permit holder.

Definition Permit Holder

Let’s look at the definition from an approval authority’s point of view: “The approval holder is responsible for the concerns of the type approval procedure and the conformity of production. Manufacturers, producers, agents or sole distributors of the producer may become permit holders. Authorized representatives, manufacturers, or suppliers do not become permit holders.”

Here it can be seen that the permit holder is not a natural person. The permit holder is therefore always a legal entity, embodied in a company.

Can anyone become a permit holder?

But not every company can be or become a permit holder. What is important is the role the company plays in manufacturing or placing the approved product on the market. In addition to the manufacturer, an importer can also become a licensee, but not an authorized representative or a manufacturer. (You can find out more about this in the CoP basic training course, or in the basic training course on approval procedures ) Care should be taken with the term “supplier”. A manufacturer for headlights, for example, can or will become a permit holder as a matter of course-its product is not only subject to approval, but typically approvable. A supplier is therefore not the same as a company that is a supplier from an OEM perspective.


The permit holder, if he wishes to be recognized as such by a licensing authority, must meet certain requirements. This must be demonstrated to the approval authority as part of an initial assessment. In fact, the initial assessment is not yet related to any products that this licensee wishes to place on the market. The focus is primarily on the trustworthiness of the licensee itself, for which an effective quality management system is indispensable.

Once the future licensee has cleared this hurdle, the only thing missing is the first approval for his product so that he is actually the licensee. And if he fulfills his obligations to the permitting authority, he will remain a permittee for a long time.

How can we support?

You will learn all the requirements for the permit holder in our training courses – from the initial assessment, to the approval. We also support you in an advisory capacity or within the framework of project work, in which our team assists you with the implementation.

And you are not sure whether your product is subject to approval or which? Or would you like to know whether your product is approvable? We clarify this quickly and to the point via an expert opinion.

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