Proposal to add para. 3.2.3.1. requiring manufacturers to provide additional information on the Cyber Security Management System at request of the Approval Authority when the Certificate of Compliance for CSMS is issued by a different Approval Authority, add para. 5.1.5. allowing the Approval Authority to refuse type approval if insufficient information on the CSMS and its implementation was provided, and add para. 7.4.1.1. requiring all granting Approval Authorities to be included in reporting when different Approval Authorities are used for the Certificate of Compliance for CSMS and type approval of the vehicle type.

CLEPA welcomes questions raised by Japanese experts under doc TFCS-37-06 and identifies points requiring further clarification regarding component and STU type approval scope, technical integration, STU definition, implementation, risk assessment, impact and benefit, and post-market monitoring. CLEPA proposes that components or STUs required for initial vehicle type approval under Part I should not be subject to separate approval under Part II, noting that vehicle cybersecurity depends on vehicle-level system interactions and E/E architecture, the OEM has full visibility of system architecture, and Part I approval ensures integrated assessment.