Proposal to insert new Part C providing guidance for the application of UN R155 to transformed vehicles. Part C addresses identification of cyber-relevant transformations, impact on original vehicle architecture, connection risks, and impact on cyber security management systems. It specifies that transformations require new approval unless the manufacturer provides clear evidence that the original approval remains valid, and outlines critical factors and examples of cyber-relevant actions. It details documentary evidence expected from manufacturers regarding functional descriptions, connections with original vehicle types, added components and functions, and arguments demonstrating negligible intrinsic risk.
Proposal to amend para. 3.5.1. in Annex 3 to require the manufacturer to demonstrate to the Type Approval Authority at least every three years that the safety management system continues to comply with requirements for software and hardware employed in the system to manage safety and continued compliance throughout the product lifecycle. This amendment resolves outstanding issues in the 01 series of amendments to UN Regulation No. 171.
Proposal to insert a new para. 5.1.12. requiring that manufacturers provide information on the method by which the initiation signal of any system intervention required by the Regulation can be objectively identified and retrieved, including specific flags, status bits, or event codes on in-vehicle networks, and that manufacturers provide clear instructions and all necessary tools for the technical service to extract and interpret the signal, with the procedure for identifying the initiation of the system intervention and corresponding data appended to the test report.
Proposal to amend para. 5.1.6.3.4. to specify that the intervention shall generate the signal to activate hazard warning lights and to clarify that for verification of timing requirements applicable to Risk Mitigation Functions, the signal to activate hazard warning lights is deemed to start the intervention, and amend Annex 8, para. 3.6.1.(b) to specify that the signal to activate hazard warning lights is generated at the earliest five seconds after the warning signal specified in para. 5.1.6.3.2. has been generated.
Proposal to amend Annex 3, paragraph 1.1.1. to delete the sub-paragraph referring to bedding of brake linings according to manufacturer’s instructions. A defined bedding procedure of brake linings was introduced in paragraph 1.1.2. of Annex 3 with Supplement 9 to the 01 series of amendments to UN Regulation No. 90. The last sub-paragraph of paragraph 1.1.1 had not been deleted in Revision 2 and 3 of UN Regulation No. 90, leading to different interpretations of the bedding procedure, which this proposal resolves.
Proposal to amend para. 5.3.2. to require notification of assessment methods and criteria including paras. 8.2. and 8.3., insert new paras. 8.2. and 8.3. establishing criteria for equipment installation without further assessment, and amend Annex 1 to require disclosure of equipment excluded from assessment pursuant to paras. 8.2. and 8.3. The amendments clarify that equipment with negligible intrinsic cyber security risk installed according to manufacturer specifications and not introducing cyber security risk, and standard non-automotive equipment connected solely for power supply with no increased cyber security risk, shall not invalidate approval of the original vehicle type under UN Regulation No. 155.
Proposal to insert a new sub-paragraph 5.6.1.1.4.1 to establish exemptions for Automatically Commanded Steering Function Category A functions designed for off-road low-speed vehicle recovery manoeuvres, and amend para. 5.6.1.2.7 to increase the specified maximum Remote-Control Parking operating range from 6 m to 15 m.
Proposal to amend UN R155 by inserting new para. 5.1.3.(e) establishing that the Certificate of Compliance for the Cyber Security Management System shall not be issued by a different Approval Authority than the one granting type approval, and amend UN R156 by inserting new para. 5.4. establishing that Approval Authorities shall not grant type approval if the Certificate of Compliance for the Software Update Management System has not been issued by the same Approval Authority granting type approval. Justification includes ensuring holistic cybersecurity assessment, clarifying reporting obligations under para. 7.2.2.2.(g), addressing unharmonized mutual recognition of management system certificates, maintaining consistency between regulations, and upholding the fundamental principle that approval authorities retain responsibility for all aspects of type approval.
GRVA may wish to consider any other proposal, if available.