The role of the product safety and conformity representative (PSCR) in the automotive supply chain was redefined by the new VDA guideline published in July 2026.
In this article we focus on the two most frequently asked questions: who needs to appoint a PSCR, and should one person carry out all these tasks?
First, a naming correction
This guideline is often referred to as “VDA 2.” That is wrong.
VDA 2 is a separate volume dealing with production process and product approval (PPA). The product safety and conformity guideline is volume 2 of the VDA Product Compliance series: VDA Product Compliance – Volume 2: Product Safety and Product Conformity, 1st edition, July 2026.
This volume replaced the old VDA “Product Integrity” (Produktintegrität) volume published in 2018. The term “Product Integrity” has given way to the concept of “Product Compliance.”
Using the correct name in purchasing and audit correspondence prevents confusion.
Who needs to appoint a PSCR?
The obligation arises from three sources:
OEM expectation. German OEMs began asking their suppliers to appoint a product safety officer from the mid-2010s; over time this request became standardized as the PSCR. The VDA recommendation is to appoint one PSCR per production site.
IATF 16949 and customer-specific requirements. Product safety is among IATF 16949’s own requirements, and the appointment of a PSCR is frequently stipulated through customer-specific requirements (CSRs).
Product liability legislation. The European Union’s new product liability regulation is being transposed. For suppliers exporting to the EU market, being able to demonstrate conformity documentation and the chain of responsibility is becoming increasingly critical.
The practical answer: check your contracts and your customer’s CSR document. If you manufacture in the automotive supply chain, you most likely have an obligation.
Product safety and product conformity are not the same thing
This distinction is one of the most valuable contributions of the new guideline and the point most often skipped in practice.
Product safety meets the basic expectation of product safety legislation: that the product is free from unacceptable risks.
Product conformity focuses on meeting all applicable requirements for the product and is directly linked to product liability.
In practice many organizations lump the two under a single checklist and leave the conformity side incomplete. The new guideline separates the tasks belonging to these two areas more clearly.
The check question you can ask yourself: you have records showing your product is safe. Do you have a separate set of records showing it meets all applicable legal and customer requirements?
Should one person do it all?
No. This is one of the most practical innovations of the new guideline.
The guideline explicitly defines the difference between the management and the execution of PSCR tasks. Organizations can delegate these tasks through appropriate processes to one or more persons, functions or roles.
The overall responsibility, however, cannot be delegated; it remains with top management.
This distinction solves a problem frequently seen in practice: an unrealistic burden of responsibility piled onto a single person. Development-phase tasks can be allocated to the product development team, series production monitoring to the quality team, field incidents to the customer quality team — as long as coordination and overall oversight are defined.
Other topics introduced by the new guideline
Clearer documentation expectations. How, to what extent and for how long the results of PSCR activities are to be documented has been defined more explicitly. This was one of the most frequent sticking points in audits.
Concrete development-phase tasks. Which tasks the PSCR takes on during product and production process development phases has been detailed. The role is no longer confined to series production and deviation management.
First reference to hazard assessments. Hazard assessments during development and safety goals such as fault tolerance time have been brought into the scope of the guideline for the first time.
Interface with audit types. The importance of linking to the results of VDA 6.5 product audits, VDA 6.3 process audits and CoP checks was emphasized.
A framework separate from management systems. The guideline’s provisions do not directly affect quality management systems such as ISO 9001 or IATF 16949 and are not used to interpret those standards.
If you already have PSCRs
Since the guideline has been renewed and the role redefined, your competence records are expected to be based on the current edition. For experienced PSCRs, a short update programme focused on the differences may be sufficient.
Checklist
- Has a PSCR been appointed for each production site?
- Is a deputy PSCR defined?
- Have the management and execution of tasks been separated?
- Is the allocation of tasks defined in writing?
- Are there separate sets of records for product safety and product conformity?
- Are competence records based on the current edition?
- Are development-phase tasks defined?
Next step
You can join our PSCR training, where we work through the PSCR role, task allocation and documentation structure hands-on, or make use of our consulting services to have your current set-up evaluated against the new guideline.
