TFCS-38-09
Component/STU type approval under UN R155
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CLEPA welcomes questions raised by Japanese experts under doc TFCS-37-06 and identifies points requiring further clarification regarding component and STU type approval scope, technical integration, STU definition, implementation, risk assessment, impact and benefit, and post-market monitoring. CLEPA proposes that components or STUs required for initial vehicle type approval under Part I should not be subject to separate approval under Part II, noting that vehicle cybersecurity depends on vehicle-level system interactions and E/E architecture, the OEM has full visibility of system architecture, and Part I approval ensures integrated assessment.
Original Equipment Manufacturer: The original vehicle manufacturer
Separate Technical Unit: Refers to the approval of a component in a larger system subject to the same regulation.