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Cybersecurity and Software updates: Proposals for amendments to the draft UN Regulations
Document GRVA-05-17
5 February 2020

Proposal submitted by the expert from FIGIEFA for amendments to the draft regulations on Cyber Security and Software Updates (GRVA/2020/2, GRVA/2020/3 and GRVA/2020/4) to address concerns regarding service and maintenance and the use of replacement parts.

Submitted by FIGIEFA
Status: Informal GR review
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Previous Documents, Discussions, and Outcomes
5. (a) | Cyber security and data protection as well as software updates

36. The expert from the United Kingdom and Northern Ireland, Co-Chair of the group introduced a proposal for a new UN Regulation on Software Updates and Software Updates Management System (ECE/TRANS/WP.29/GRVA/2020/4 amended by GRVA-05-04 and reproduced in GRVA-05-06 in a consolidated version). He explained that the group would prepare an interpretation document but that no resolution would be necessary.

37. GRVA adopted ECE/TRANS/WP.29/GRVA/2020/4 amended by Annex III of the GRVA session report and requested the secretariat to submit it (without square brackets) to WP.29 and the Administrative Committee AC.1 for consideration and vote at their June 2020 sessions.

38. The expert from the United Kingdom and Northern Ireland introduced ECE/TRANS/WP.29/GRVA/2020/5, proposing provisions for software identification numbers. GRVA adopted the proposal and requested the secretariat to consult WP.29 on the best way to implement these provisions in existing regulations.

39. GRVA noted the report of the test phase prepared by the TF (ECE/TRANS/WP.29/GRVA/2020/6) and discussed that the TF on CS/OTA should be renamed IWG on CS/OTA.

5. | Automated/autonomous and connected vehicles
5. (b) | Cyber security and data protection

18. The expert from Japan, Co-Chair of the Task Force on Cyber Security and Over-the-Air Software Updates presented GRVA-02-03, containing a status report of the group’s activities since the previous GRVA session and introducing ECE/TRANS/WP.29/GRVA/2019/2. He mentioned that the group responded in writing to all the questions and comments received on the proposal.

19. The expert from FIA welcomed the proposal produced by the group but mentioned that it did not reflect their position regarding life time requirements.

20. The expert from OICA wondered whether such aspect raised by FIA would belong to the scope of the 1958 Agreement. The secretariat answered that some precedents could help answering this question e.g. UN Regulation No. 49 (including conformity of in-service vehicles/engines provisions), UN Regulation No. 59 (Replacement (retrofit) silencing systems), UN Regulation No. 83 (including durability requirements and “in use” requirements), UN Regulation No. 90 (Replacement braking parts) and UN Regulation No. 133 (Recyclability of motor vehicles). He stated that he was not aware of any provision of the Agreement that would limit the activities under this Agreement only to the performance of new vehicles. The expert from OICA, Secretary of the Task Force agreed to submit in written an informal document highlighting the difficulty faced by the group with this aspect. He presented, on the last day of the second GRVA session, GRVA-02-46 that described the issue of post-production, understood as the product lifetime starting after the production is definitely discontinued.

21. The expert from Germany and the Netherlands stated that the document should address the three following phases: system/vehicle development, production and post-production.

22. The expert from Japan supported the proposal ECE/TRANS/WP.29/GRVA/2019/2 and stated the need to adopt this document during this session, since the new UN Regulation proposed in the document was one of the important and needed Regulations for the improvement of vehicle safety.

23. The expert from EC provided comments on the proposal (GRVA-02-37).

24. The expert from IMMA presented GRVA-02-18, proposing to exclude vehicles of category L from the scope of the document.

25. The expert from Japan, Co-Chair of the Task Force, responding to the advice received from the previous session of GRVA, reported on its proposal for a test phase to assure the draft produced. He presented the aim and the desired output of this activity.

26. GRVA agreed to keep the documents under this agenda item for continued review at next GRVA session. GRVA invited the Task Force to address the comments received and to proceed with the test phase. GRVA noted the need to make further progress on this item and requested the secretariat to explore the possibility to organize a special session of GRVA in May or June 2019.

5. (c) | Software updates (incl. Over-The-Air updates)

27. GRVA noted that the presentation of GRVA-02-03 also introduced ECE/TRANS/WP.29/GRVA/2019/3, that the proposal for a test phase would also apply to the software updates work stream. The expert from Japan also supported the document ECE/TRANS/WP.29/GRVA/2019/3. He indicated Japan’s support for the earliest adoption (during this session), since the issue was important and a UN Regulation was needed for the improvement of vehicle safety.

28. The expert from EC provided comments on the proposal (GRVA-02-37).

29. The expert from IMMA presented GRVA-02-18, proposing to exclude vehicles of Category L from the scope of the document.

30. The expert from ITU stated that regulating communication would require specific expertise and that the precedent at the Working Party on General Safety provisions with the UN Regulation No. 144 (Accident Emergency Call Systems) ignored communication aspects and durability provisions. He raised the question whether a vehicle equipped with safety systems based on communication would still be roadworthy in case the communication would no longer function e.g. when the communication system would be obsolete. GRVA agreed that the Task Force on Cyber Security and Over-the-Air Software Updates was a good example demonstrating that WP.29 was able to attract the required experts with the right expertise and to make very quick progress on such strategic issues. GRVA agreed about the need to discuss the roadworthiness of vehicles in case of the vehicle communication unit obsolescence would impact the well performing of safety systems.

31. GRVA agreed to keep ECE/TRANS/WP.29/GRVA/2019/3 and GRVA-01-18 on the agenda of the next GRVA session.

Related and Previous Documents
GRVA/2019/2
GRVA/2019/3
GRVA/2020/4
Relates to UN R155 | UN R156 |