Document presents initial considerations for approving Automated Driving Systems as Separate Technical Units under UN R185. It explains how component and STU approvals divide responsibility between suppliers and vehicle manufacturers, provides examples from other regulations such as lighting, tyres, glazing, and fuel systems, and discusses potential benefits and challenges specific to UN R185 application. Benefits include independent audits and avoiding repeated assessments for different vehicle types. Challenges include difficulty splitting requirements, potential information withholding, and unclear legal responsibility. Proposes flexible approaches with shared Safety Management System requirements and validation in vehicles.