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.

Draft form for pre-testing participants to use in reporting errors, concerns, or other issues during the validation phase of the international whole vehicle type approval regulation.

Vehicles of categories M₁, N, O, R, S and T may fall out of scope of UN R155 or UN R156 if they lack ECUs or do not permit software updates. Approval authorities currently make individual determinations regarding whether vehicles are in or out of scope, and justification for out-of-scope decisions must be recorded to ensure vehicles remain out of scope during the lifetime of whole vehicle approval. UN Regulation No. 10 provides precedent by allowing approvals for vehicles where certain equipment is not relevant. A similar provision could be incorporated into UN R155 and UN R156 by amending the scope and adding provisions to section 5 allowing manufacturers to obtain approvals for vehicles that do not permit software updates, with requirements of paragraph 7 not applying.