EV Guard Oy manufactures battery guards for hybrid and electric vehicles using 3 mm marine aluminum and 8 mm recycled PET composite to protect battery packs, liquid-cooling systems, and electrical connectors. The guards distribute impact force, reduce temperature fluctuations, improve energy efficiency, and are 100% recyclable. The company supplies guards to authorized repair shops. No valid regulation currently applies to aftermarket battery shields; UN R100 does not cover this product, representing a structural gap in regulation.
Proposal to add animals and children to examples of safety-relevant objects in para. 6.1.2.8. The revision inserts “Animals and children (in or adjacent to the roadway, under the vehicle carriage, etc)” into the illustrative and non-exhaustive list of safety-relevant objects. The proposal removes ambiguity for manufacturers developing safety cases and ensures consistent treatment across ADS requirements, making explicit that animals and children are safety-relevant objects even though they cannot be expected to respond predictably based on vehicle signals, traffic rules, or common conventions.
Proposal to add animals and other road users as examples of entities an ADS may encounter in driving situations and test scenarios. The revised text adds “animals, or other road users” to the illustrative example in para. 2.33 and para. 2.34, and replaces “pedestrians” with “these entities” in the corresponding sentence about scenario design. This ensures scenario design used to demonstrate ADS competency explicitly accounts for animal encounters alongside pedestrians and other road users.
Proposal to delete “the examples given below is not the only possible approach,” add clarification that examples are non-comprehensive and represent one possible approach for documenting claims, arguments and evidence, modify example descriptions to point to regulation requirements 5/7.3.3.2 (a) and (b), and incorporate examples from ADS-20-09 by removing the placeholder “Examples to be provided.”
Proposal to remove the placeholder for guidance on expectations concerning mitigation risk condition end states in para. 7.3.1.14. and replace it with text from ADS-20-09 with one paragraph removed based on ADS-20-50. The revised text specifies that while ADS Performance of DDT requirements set out when an MRC is required, they do not specify the process to achieve the MRC or its end state. MRC end states are expected to be fully stopped with parking brake applied and could include activation of hazard lights. The process to reach an MRC is expected to vary depending on the situation and system capabilities, and possible end state examples include stopping in lane, on shoulder, exiting highway, or navigating to nearest parking spot.
Proposal to remove brackets from the ODD paragraph in section 7.3.1.3. The proposal removes square brackets that were included as a result of the ADS-20-46/Rev.3 discussion. The bracketed text addresses scenarios where a new area falls within existing ODD bounds, where deployment in that area might not require ODD modification, and where modifications to the area of operation would not require ODD modification provided conditions and environment in new areas of operation have been considered, but where operation in an area with different traffic laws or behaviour than those for which the ADS’s ability to comply has been demonstrated would require an amendment to the safety case.
Proposal to clarify guidance on reporting of system failures that compromise DDT performance by amending the description of reportable system failures, including modifying language regarding loss of redundancy or reduction in capabilities of ADS features to perform the entire DDT, replacing “failure in an actuator used by the ADS” with “hardware failure that compromises the capability of an ADS feature to perform the entire DDT,” and retaining the existing provision regarding degradation in computational capability.
Proposal to clarify guidance on reporting uncompleted system-initiated deactivations by deleting “i.e.” and “the user has not properly taken over control of the”, inserting “is left to the user,” after “vehicle control”, inserting “An” before “ADS”, inserting “feature” after “ADS”, inserting “, or” after the clause on driving responsibility, and inserting “The user is not properly re-engaged as defined paragraph 4.2/6.2 of the regulation.” as an additional reporting criterion.
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