What Is the Connected Vehicle Rule?

So the connected vehicle rule is an ICTS rule, under the ICTS authority of the Department of Commerce, which is the Information Communication Technology Services Authority, which stems from a law called IEPA, International Emergency Economic Powers Act, which is essentially the authority that most sanctions regimes come from. And it's really a first in kind, regulatory regime, that is is focused on risk in a specific category of the ICTS sector, and and in this case, the connected vehicle sector. And to just to start, connected vehicles sounds like it's some special kind of car that, you know, is is different or, you know, is it just EVs? They the commerce department made clear now. This is every car that's been made for the last, I don't know, a decade really is what they're talking about because all cars have some sort of connectivity. And we'll talk about, you know, where the the national security concerns are coming from, but really what they're focused on, are the the rules are targeted at China and Russia and, particularly specific types of hardware and software in in, connected vehicles, which are the vehicle connectivity system hardware, as well as software, associated with the VCS, as well as software associated with autonomous driving, particularly above level three. What the rule does is that it prohibits, the import of VCS hardware, that is designed, developed, manufactured, or supplied, by person's own control. They're subject to jurisdiction or direction of China or Russia. Those are long terms. I'll I'll shorten them going forward, but that's kind of the framework that we're operating in. So first one is you can't send in the, you can't import the VCS hardware. The next one is that, connected vehicle manufacturers, cannot import vehicles that completed vehicles that incorporate covered software. The third one is that connected vehicle manufacturers, cannot knowingly sell, vehicles that incorporate, covered software that is tied to China and Russia. And then the last prohibition, the fourth one, is basically saying that if you are a connected vehicle manufacturer and you fit within this, category of being tied to China and Russia, you are not allowed to sell your cars in the United States, and you're not allowed to offer your cars for commercial services, in the US. These are this is a major disruption to the supply chain. So there's a delayed effective date. You know, these these rules, they were the final rule was issued in January. The hardware rules don't go into effect until twenty nine or thirty, kinda depending on, the specific hardware. And then the software rules and the OEM rules on on Chinese and Russian OEMs, don't go into effect until model year twenty seven. There are general and specific authorizations that can allow you to proceed even if you fit within these rules. We'll talk about, specifically the the specific, the specific authorizations, further. But one final point just to wrap up on on this is, like, the way that this is going to be enforced is through this idea of a declaration of conformity that an importer or a connected vehicle manufacturer, will need to submit on an annual basis to basically say that they've done the diligence to make sure that that they don't have they're not violating these rules with respect to the cars that they're selling or the hardware they're importing into the, United States.