OICA-CLEPA-EME comments on German proposal GRVA-25-07 to require the approval authority granting UN R155 or UN R156 type approvals to use CSMS or SUMS certificates signed by the same approval authority. OICA-CLEPA-EME identify that CSMS and SUMS are Management Systems covering entire manufacturer organizations, and mandating the same approval authority for Management Systems certificates and approvals will have significant consequences for original equipment manufacturers typically using multiple approval authorities in homologation. The submission proposes keeping text unchanged to allow different approval authorities for Management Systems certificates and type approval based on voluntary acceptance, implementing wording on information exchange if different approval authorities are involved, and establishing a horizontal approach for Management Systems with mutual recognition aspects considered.