Rules of achieving and maintaining IATF recognition - Determining audit days

Crimpshrine13

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I need someone provide me a clarification on chapter 5.5 of Rules of achieving and maintaining IATF recognition - 4th edition for ISO/TS 16949.

Supporting functions on site or remote (e.g. product design, contract review, purchasing, warehouse, etc.) shall be audited as required to support a site but shall be included in the initial stage 2 audit, at least once more during the surveillance audit cycle, and at the recertification audit. The only exception is that clients with product design responsibility shall have their design function(s), on site or remote, audited at least once within each consecutive twelve (12) month period.

When planning the initial stage 2 audit, the remote supporting function shall be audited prior to the site.

Additional audits of remote support functions may be necessary based upon their demonstrated performance as seen at the site(s) they support.

The certification body shall document how the days are distributed between the site(s) and any supporting functions on site or remote.
In the first paragraph, it says "The only exception is that clients with product design responsibility shall have their design function(s), on site or remote, audited at least once within each consecutive twelve (12) month period." Does "product design responsibility" in this paragraph really specific to the design of the product itself, or is it design activities in general including tooling (process design)?

Our company is a tier 2 automotive brake component manufacturer, and our parent company oversea designs the tools to make these parts. The product drawings are provided by OEMs, but our parent company does the tooling (process) design for us (7.3.2.2), which require a support location audits.

What is so confusing to me is that in chapters 5.0 and 6.0, it talks about "product design" and "non-product design," but at the same time, it talks about 7.3's Design as a whole thing. For example, on chapter 5.4-a), it says:

a) non-product design-responsible (see section 6.1) client entitles (site including remote support functions) may reduce onsite audit days by 15%,
Then if I go to 6.1 to read about design, towards the end of section 6.1, it says:

If the client provides evidence that it is not design responsible, the certification body shall exclude ISO/TS 16949, 7.3 Product Design from the client's audit scope.
But, 7.3 is really "Design and development" which includes "7.3.2.2 Manufacturing process design input," so to me, if it has anything to do with design, whether it is the product design or process design, it is considered as "Design."

Our CB thinks that we do not have to get audited every year because we're not design responsible (design of the final product), but I disagree because we still have tooling design (remote location).

What is the correct interpretation in this?
 
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