Japan CS/OTA 15th session, Geneva 27-28, August 2019 Proposal for amendments on Software Update Draft Regulation Considering the Case Not Including RxSWIN Japan CS/OTA 15th session, Geneva 27-28, August 2019

Reminder RxSWIN is the tool to manage software versions relevant to type approval and to link the relevant software sets and the relevant UNR. The requirements of current draft of Annex A cover the case which does not apply RxSWIN in general.

Reminder The upper level of the requirements, such as 7.1.1.2, 7.1.2, requires manufactures to maintain the management and documentation of software versions in their processes also for the case without RxSWIN. On the other hand, the current texts may not be workable for TS/AA to verify the manufactures’ processes in some cases without RxSWIN.

Observation 1 Declaration of the relationship between software sets and relevant UNR is not an obligation in the current texts. On the other hand, 7.1.2.5 b) says “Documentation for all software updates for that vehicle type describing What systems or functions of the vehicle the update may affect”. TS/AA is not able to verify these manufactures’ processes without knowing the relationship between the software sets updated and relevant UNR. For example, the authority is not able to verify the process in the case which the manufacture judge “no influence” with the update.

Proposal 1 To amend adding the following as the same level of 7.1.2.3. “For cases which RXSWIN is not used, there shall be documentation describing the software relevant to the UNRs of the vehicle type before and after an update. This shall include information of the software versions and their integrity validation data for all relevant software for the identifier defined by the manufacturer.”

Observation 2 There is no similar requirement with RxSWIN for reading out the information from the vehicle.

Proposal 2 A new term as 7.2.1.3 should be added as follows. “Each software version of any relevant type approved systems except for ones to which paragraph from 7.2.1.2.1. to 7.2.1.2.3. apply shall be easily readable in a standardized way via the use of an electronic communication interface, at least by the standard interface (OBD port).”