GeneralComplianceInfo
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Confidential − level two material | 2019−06−28 | P1941 V300_T3;0 | GeneralComplianceInfo | 6.3.0 (5.1.0) | © Robert Bosch GmbH reserves
all rights even in the event of industrial property rights. We reserve all rights of disposal such as copying and passing on to third parties.
I General Compliance Information
1. Exhaust gas emission legislation (including intrusive OBD monitors) and noise emissions legislation
1. This document may include one or more "Algorithms to review" chapters showing additional Compliance−related calibration hints.
The customer has to pay particular attention to disclosure requirements to the authorities (e. g. AECD, AES/BES) with regard to any
functions included in the "Algorithms to review" chapters.
All information in the "Algorithms to review" chapters are given to the best of our knowledge and are largely based on the legal require-
ments in the EU and the US. However, they do not claim to be accurate or complete and shall not dispend the OEM from its responsi-
bility and its obligation (i) to verify and demonstrate the conformity of the application of the calibrated software in the vehicle with any
laws applicable in the relevant target markets and (ii) to comply with the relevant type approval and disclosure requirements under any
applicable laws in the relevant market. The laws and obligations mentioned in (i) and (ii) in the target market may be different to those
applicable in the EU and the US. The content of the "Algorithms to review" chapters does not include any kind of legal advice and does
not reduce the responsibility of the OEM to review the applicable legal situation.
The "Algorithms to review" chapter includes Compliance hints in regard to exhaust gas emission legislation (including intrusive OBD
monitors) and noise emissions legislation.
2. Exhaust emission functions mean those functions that can be modified by software / calibration data with an effect to any part of the
emission control system under conditions of normal vehicle operation and use.
Emission control system means, in the context of the OBD system, the electronic engine management controller and any emission−re-
lated component in the exhaust or evaporative system which supplies an input to or receives an output from this controller. In other
contexts, the emission control system may, in addition, also include components related to fuel consumption and CO2 emissions (in
particular the case under U.S. law).
3. If the calibrated function reduces the effectiveness of the emission control system, the function may be an illegal defeat device under
the applicable law if active under conditions which may reasonably be expected to be encountered in normal vehicle operation and use,
unless
I. the device (function) is needed in terms of protecting the vehicle / engine against damage or accident, or
II. the device does not function beyond the requirements of engine starting, or
III. the conditions are substantially included in the applicable test procedures. (Please note that the legal definitions may vary in the
relevant jurisdictions and should be checked carefully.)
4. Functions including intrusive OBD monitors which influence the emission control system, in particular those functions which reduce
the effectiveness of the emission control system, may qualify as an auxiliary emission control device (AECD) under U.S. law and shall
be disclosed to and approved by the relevant authority as part of the type approval.
Under EU law those functions may qualify as an auxiliary emission strategy (AES) or as part of the base emission strategy (BES) which
are subject to disclosure and approval obligations. Similar disclosure obligations may apply in regard to functions with influence to CO2
emissions if part of the fuel system control logic, to timing strategies and to switch points during all modes of operation.
5. Under certain requirements, functions which (i) are approved AECD because they are needed in terms of protecting the vehicle against
damage or accident and (ii) which reduce the effectiveness of the emission control system under conditions which may reasonably be
expected to be encountered in normal vehicle operation and use, may qualify as an emission increasing AECD (EI−AECD) under U.S. law
and shall be disclosed to the authorities as part of the certification application.
Various places of the SW where different emission strategies may be chosen include EI−AECD counters. These EI−AECD counters do
not claim to be complete. They are provided as a precaution. Whether parts of the SW qualify as an AECD needed in terms of vehicle
protection and an EI−AECD counter is required may depend on the emission strategy as set by the customer and has to be checked by
the customer under its own responsibility on the basis of the respective emission strategy.
6. Any calibration strategy for optimization has to be coherent throughout the entire range of operation occurring under normal operating
conditions. Using criteria for optimization in a different manner under operating conditions relevant in the test cycle than under off−-
cycle conditions is not permitted except in case of legally justified defeat devices.
External interfaces of the vehicle must not be used to optimize or bypass test cycles.
Compliance with emission limits and with the prohibition of defeat devices shall prevail over the utilization of strategies for optimiza-
tion.
When using optimization strategies which aim at balancing several (at least two) pollutants, for which legally set limit values exist (e.g.
NOx and HC/CO), or which aim at balancing at least one pollutant and CO2, the following is to be attended to:
− Any optimization can only address (further) reduction of at least one pollutant below the level of the respective limit value or on a
reduction of CO2 emission when adhering to the respective limit values of pollutants.
− The strategy of optimizing pollutants as a whole, and not only any single pollutant on its own, has in principle to be approved by the
certification authorities in charge for the respective target market. This has to be ensured by early information and consultation of the
respective certification authorities.
Additionally, attention has to be paid to any differences between the countries' views on CO2 emission with respect to disclosure state-
ments and the prohibition of defeat devices.
7. Vehicles with driver−selectable modes (e.g. eco mode, sport mode or even start stop functionality) must − in all driving modes − fulfil
the limits of criteria emissions applicable in the respective countries.
8. If a component is detected as defective, the ensuing signal (e.g. FID) may only be used for the purpose of ensuring operation of the
vehicle in spite of the defective component. If the signal leads to a reduction of the efficiency of the emission control system, this fault
reaction must be limited to the extend necessary. The fault reaction is only allowed, if the fault is stored as MIL relevant in the fault
memory.
9. Noise emission: Under EU−law the manufacturer is obliged to demonstrate compliance with statutory noise emission limits in specific
type−approval tests. Functions with the effect that the noise emissions of the vehicle shall not deviate in a significant manner under
