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.
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.
Proposal to insert new paras. 27 and 28 in Part C Guidance for the application of UN Regulation No. 155 to transformed vehicles. Para. 27 states the requirement that the Certificate of Compliance and type approval are issued by the same Approval Authority applies only within the scope of the type approval granted to the manufacturer concerned. Para. 28 states where a vehicle manufacturer modifies a vehicle with existing type approval and applies for new type approval covering the modification, they need not use the same type approval authority as was used by the original vehicle manufacturer.
OICA, CLEPA, and CLCCR oppose the requirement in GRVA/2026/30 for a single Approval Authority to issue the Certificate of Compliance for CSMS/SUMS and vehicle type approval. They contend the approach would create multiple approvals of the same Management System, imposing administrative burden and creating unresolved legal consequences if a CoC is challenged. The organizations propose adding a new paragraph 5.1.5. instead of paragraph 5.1.3. e) to permit mutual agreement between Approval Authorities, allowing usage of a CoC issued by another Approval Authority, with such agreement documented in type approval documentation.
Proposal to amend GRVA/2026/27, which proposes amendments to UN R13, UN R13-H, UN R79, UN R89, UN R130, UN R131, UN R139, UN R140, UN R152, UN R156, UN R157, UN R171, UN R175, and UN R178:
Proposed changes to align RxSWIN provisions with the RxSWIN template adopted through WP.29-197-06, remove the proposed requirement to comply with UN R156/01 or later from R157 and R171, remove amendments to UN R155 as decided by the IWG CS/OTA, apply the RxSWIN amendments also to earlier series of amendments in R13, R13-H, R79, R131, R152, R157, and R171, update references to the latest version of R.E.3, ECE/TRANS/WP.29/78/Rev.8, in earlier series, and correct paragraph references and improve structure in R89, R139, R140, R155, R156, and R171.