no clue.
My Friend the certifier promised me to ask a colleague who is doing §21.
… but this may take time …
I’d hope that it were ours to supply information.
They just check whether it meets their expectations for safety (which I think may even differ from certifier to certifier).
So if we say “product number 1232435346245234545 from FooBarCo” instead of “ISO ABC type” it were our own fault when we sewed the skirt to narrow.
I’ve sent him the drawing from this post
so the AOG can never block the orbitrol from the cylinder.
And proposed to add manually operated cutoffs between the tee and the valve block.
Complemented by operating instructions that forbid to drive on public roads when those cutoffs are open.
So best what can happen that he forwards that to his colleague and he says “sure”, then we were fine. 
(as you may know, hope is the last thing to die…)