Written by / Cow Heel Shang
Edited / Meng for
Design / Shi Yuchao
OTAs, which are talked about by electric vehicle pioneer Tesla, China's new car-making forces, new energy vehicle companies, and luxury brands, have encountered stricter national supervision.
On April 15, the Equipment Industry Development Center of the Ministry of Industry and Information Technology issued a notice to carry out online upgrades of automotive software (also known as OTA upgrades) in car companies.
The basis for the filing work is the "Measures for the Administration of Road Motor Vehicle Manufacturers and Product Access" and the "Opinions on Strengthening the Management of Access to Intelligent and Connected Vehicle Manufacturers and Products" and other relevant provisions.
The scope of the filing includes the vehicle manufacturers that have obtained the road motor vehicle production access license, their automotive vehicle products with OTA upgrade functions and the OTA upgrade activities implemented, referred to as the "three filings".
The highlight of the notice is that the Ministry of Industry and Information Technology requires OTA upgrades to be reported: First, for relevant upgrade activities that do not involve changes in technical performance such as product safety, environmental protection, energy saving, and anti-theft, enterprises can directly carry out upgrades after filing.
Second, for related upgrade activities involving changes in technical performance such as product safety, environmental protection, energy saving, and anti-theft, verification materials should be submitted to ensure that the products comply with relevant requirements such as national laws and regulations, technical standards and technical specifications. Among them, related upgrade activities involving the change of technical parameters of the Announcement, enterprises should apply to the Ministry of Industry and Information Technology for product changes or expansions in accordance with the administrative provisions of the Announcement before filing, and can carry out upgrades after completing the product access of the Announcement according to the process to ensure the consistency of production of automobile products.
Third, the relevant upgrade activities involving the automotive autonomous driving function (driving automation classification level 3 and above) should be approved by the Ministry of Industry and Information Technology.
Fourth, in addition to making relevant requirements for the software upgrade of the vehicle itself, it also puts forward filing requirements for the management ability of the software upgrade of automobile enterprises.
Automotive Business Review learned from relevant enterprises and channels that the state will further evaluate and certify the software upgrade management system within automotive enterprises.
At the critical moment of the rapid development of intelligent and connected vehicles, how to interpret the requirements for the core and hot technology of automotive software upgrades from the national regulatory level?
Filing does not begin today
2020 can be described as the first year of smart electric vehicles.
With the explosive growth of new energy vehicles from July 2020, the intelligence and networking of electric vehicles have become the selling point of this new species.
In the meantime, in the competition with Tesla and the new forces of Chinese car manufacturing, the head and waist companies in some well-known luxury cars will include the intelligence of OTA upgrades as a killer.
Just like the spontaneous combustion incident that occurred in electric vehicles, it is very easy to form a public hot spot event, and the BUG, slot point and complaint about OTA have also attracted the attention of market supervision.
It is said that on November 25, 2020, the General Office of the State Administration for Market Regulation issued the Notice on Further Strengthening the Supervision of Remote Upgrade (OTA) Technology Recalls of Automobiles, "The Quality Development Bureau of the State Administration for Market Regulation will organize relevant units to strengthen research on automotive OTA safety supervision technology, explore the establishment of an OTA regulatory data platform, organize OTA safety technology assessment and strengthen relevant recall supervision work".
The circular emphasizes that producers (including enterprises established in Accordance with the law in China that produce automobile products and issue product certificates in their names, as well as enterprises that import automobile products from outside China and sell them in China) who use OTAs to carry out technical service activities for sold vehicles should file with the Quality Development Bureau of the State Administration for Market Regulation in accordance with the requirements of the Regulations on the Administration of the Recall of Defective Automobile Products and the Implementation Measures for the Administration of the Recall of Defective Automobile Products.
Four months later, on the eve of the 2021 Consumer Rights Day, Mercedes-Benz (China) Automobile Sales Co., Ltd. and Beijing Benz Automobile Co., Ltd. filed a recall plan with the State Administration for Market Regulation, with a total recall of 2601043 vehicles, involving almost all Mercedes-Benz models. This is the largest single recall in mercedes-Benz's history in China.
It has been reported that Mercedes-Benz's recall is due to software problems with communication modules, and most of these models will be resolved through remote vehicle upgrade (OTA) technology.
In response to the filing notice issued by the Ministry of Industry and Information Technology this time, a senior person who specializes in FOTA told automotive business reviews, "There were also filings before, and generally the filings were after-sales or warranty filings, similar to recalls." ”
"But there are some problems, the manufacturer is not recalled, secretly do it for you when you enter the station maintenance." Now, it is equivalent to the release of the document to make it clear, there are similar OTA lock power, lock power, some upgrades will affect the ministry of industry and information technology (release) energy consumption data. The person, who did not want to be named, revealed.
The focus of "three filings"
On April 15, 2022, the Equipment Industry Development Center of the Ministry of Industry and Information Technology of China issued a notice saying that car companies should complete the filing of enterprise management capabilities, the filing of models and functions and the filing of specific upgrade activities in turn as required before they can implement OTA upgrade activities.
According to the impact assessment of the upgrade activities, the specific upgrade activities shall be filed at different levels: the relevant upgrade activities that do not involve technical performance changes such as product safety, environmental protection, energy saving, and anti-theft, can be upgraded directly after filing.
Related upgrade activities involving changes in technical performance such as product safety, environmental protection, energy saving, and anti-theft should submit verification materials to ensure that the products comply with relevant requirements such as national laws and regulations, technical standards and technical specifications.
Relevant upgrade activities involving the automotive autonomous driving function (driving automation classification level 3 and above) should be approved by the Ministry of Industry and Information Technology.
In terms of consumer rights, the notice emphasizes that enterprises should fulfill their obligation to inform, inform vehicle users of the purpose, content, duration required, impact of the upgrade, precautions and other information before the upgrade is implemented, and inform the vehicle users of the upgrade results after the upgrade is implemented.
In the filing of enterprise management capabilities, car companies should carry out OTA upgrade management capability assessments, and submit enterprise management capabilities for filing and relevant certification materials. The filing period is 3 years, and if the validity period expires or the enterprise management ability cannot be maintained continuously, a new application for filing is required. The filing of models and functions, the filing of specific upgrade activities and the implementation of upgrading activities shall be carried out within the validity period.
In terms of model and function filing, after the release of this notice, if you apply for the admission of new products, you should submit the model and function filing and related certification materials within 15 working days after the release of the product announcement, in accordance with the filing information and requirements listed in the online upgrade filing system of automotive software. Products that have been announced before the issuance of this notice shall complete the supplementary filing within 60 working days after the filing of the enterprise management capacity.
In the filing of specific upgrade activities, before enterprises carry out specific OTA upgrade activities, they should submit the specific upgrade activities for the record and related certification materials in accordance with the filing information and requirements listed in the online upgrade filing system for automotive software. Within 5 working days after the completion of the upgrade activity, submit a report on the implementation of the specific upgrade activity. Where the interval between the start and end of the upgrade activity exceeds 6 months, a phased report on the implementation status shall also be submitted every 6 months.
In this regard, the professional's interpretation is, "In the past, you only managed to file, what you want to rise; now, you have to change, such as power parameters, these affect the announcement, then you must first announce, first complete the announcement change, before you can initiate the task; if you only upgrade an entertainment host, then you can file the record, you can send." Just can't be blind! ”
The heat and pain of OTA upgrades
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Zhao Fuwei, director of technical information of Lantu Automobile, said that it has been carrying out the filing work in accordance with national requirements, and as the first batch of units participating in the "software upgrade management system certification" organized by Tianjin Huacheng Certification Center, the certification evaluation work will be carried out in the near future.
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According to the "2021 National Consumer Association Organization Acceptance of Complaints Analysis" released by the China Consumer Association, consumer disputes and complaints about new energy vehicles have become a new hot spot, and the primary concern of everyone is safety issues, including the failure of the automatic driving system, etc., and these complaints correspond to the social hot spots on the hot search.
On the eve of March 15, 2022, there were media reports that the owner of Xiaopeng Automobile said that the mileage of the car after the OTA was significantly reduced, and it was suspected that Xiaopeng officially "locked the electricity" of the vehicle through OTA. One of the P7 owners revealed to the media that the apparent endurance of his car after the OTA in late 2021 fell from the original 480 km to 430 km, less than 90% of the original.
According to statistics, in 2021, the average cycle of OTA version updates of China's mainstream smart electric vehicle products is about 2 weeks, and under the general trend of commonly used vehicles and software-defined cars, these OTA upgrades not only bring new functional scene experiences and surprises to car owners, but also appear negative information such as "locking the power" without informing users.
The "Notice" issued by the Ministry of Industry and Information Technology this time makes the OTA upgrade of car companies traceable to a certain extent, and also emphasizes the obligation of car companies to inform regulators and consumers when they involve changing product parameters and safety performance through OTA upgrades.
Zhao Fuwei, director of technical information of Lantu Automobile, said that it has been carrying out the filing work in accordance with national requirements, and as the first batch of units participating in the "software upgrade management system certification" organized by Tianjin Huacheng Certification Center, the certification evaluation work will be carried out in the near future.
"We've been filing." A leading electric vehicle company communicator commented on the automobile business, "This notice has no impact on us and will be strictly enforced." ”
However, some people in the industry are worried that if there are too many mothers-in-law and too strict requirements at the national regulatory level, will it affect or even inhibit the development of emerging smart electric vehicles?
This article was originally produced by Automotive Business Review
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