Proposal to amend para. 9.(a) to clarify expansion of the protection scope of electrical and battery safety, including thermal propagation in cases of V2X, parking, and charging. The modification addresses new vehicle functionalities like V2X, defined in UN GTR No. 22, where traction batteries cover external power and energy demand. Additional requirements must be added, including isolation resistance requirements for coupling systems for charging the REESS, as defined in para. 5.1.1.2.4.4. of UN GTR No. 20.

Proposal to correct a reference to paragraph 3.6.1.1.3. that should read 5.6.1.1.3. and to correct a misspelling.

Proposal to insert new clauses to section 8 of the Consolidated Resolution on the Construction of Vehicles (R.E.3) to add provisions 8.40.1. through 8.40.9. establishing requirements for:

• Periodic technical inspection of vehicles, including verification of proper condition and functionality through testing equipment, electronic vehicle interface, scan-tools and manual/visual inspection,
• access to in-vehicle data without changing approved vehicle design or affecting software integrity, functionality of installed safety systems, and cyber security measures,
• manufacturer provision of technical information for testing equipment, electronic vehicle interface, scan-tools and methods,
• vehicle construction providing access to Diagnostic Trouble Code with regard to identify failure of vehicle, equipment and parts,
• definition of failure,
• requirement that Diagnostic Trouble Code be accessible by scan-tools compliant with international standards without manufacturer-specific, user-specific, or tool-specific restrictions,
• cyber security measures not affected,
• application limited to authorized test centers and workshops.

Japan comments on the draft 04 series of amendments to UN R51 (Noise of M₁–M₃ and N₁–N₃ Categories of Vehicles). Japan highlights several editorial and technical issues. Regarding para. 2.24.1, Japan suggests the table of symbols for Annex 3 should state symbols are “used for the first time” consistent with ISO standards. For para. 3.1.2.1.4.3, Japan requests deletion of “but no more than 2.0 m/s²” as unnecessary for RD-ASEP applied to electric vehicles. Japan notes para. 6.2.3.4 should reference appropriate appendices for the RD-ASEP statement of compliance requirement. Paragraphs 11.1.4 and 11.1.5 are identical and one should be deleted. Japan flags para. 3.2.3.4.2 requires tyre conditioning on outdoor test tracks for indoor testing. For Annex 6, para. 3 should clarify that compliance assessment references para. 5 of Annex 7 for expected sound pressure level limits applicable to conformity of production testing.

Questions concerning cyber security amendments for approvals of STU submitted by the expert from Japan that address timing of working document submission to GRVA, whether Part II components may include certificated base vehicle equipment under UN R155 multi-stage categorization, whether STU definition includes ECUs within base vehicle E/E architecture, examination of use cases and implementation challenges, consistency of applicant terminology between Section 3.3.1 and Section 7.6, whether approval authorities for Parts I, II, and III must be identical, clarification of end of support period requirements in para. 2.7(b), installation agreement requirements in para. 5.1.2.1(d), and whether total Cyber Security Risk Assessment Process for whole vehicle with other equipment than ESAs is necessary after ESA installation under para. 7.4.10.

Proposal to amend para. 7.2.1.2.2. to delete, in cases where RXSWINs are not held on the vehicle, the requirement that the manufacturer shall declare the software version(s) of the vehicle or single ECUs with the connection to the relevant type approvals to the Approval Authority and that this declaration shall be updated each time the declared software version(s) is updated, and add that the link between the software version(s) and the RXSWINs shall be declared.

Japan submitted comments on RXSWIN assignment at the 38th CS/OTA IWG. Q.1 asks whether, when a type approval is extended from UN R156-00 to UN R156-01, RXSWIN may be assigned at extension time, and if a UN Regulation refers to RE.3 Annex 7 through a supplementary amendment after UN R156-01 transitional provisions become applicable, whether RXSWIN is assigned at that time. Q.2 asks whether Approval Authorities other than the Authority granting approval are expected to have access to the OEM’s Auditable Register, as access information appears provided only to the Approval Authority concerned through paragraph 9.5.2. Q.3 asks whether software updates affecting type approval can be performed under Regulations that do not reference RE.3 Annex 7.