- Technical standards are both global public goods that facilitate international exchange and an arena for commercial and ideological competition. China’s growing presence in international standards organizations has raised concerns among American and European actors that the Chinese government is abusing its role to advance its own interests.
- Safety and testing standards for autonomous vehicles (AVs) is a unique case study of China’s standards ambitions, sitting at the center of complex technical and ethical questions for a crucial emerging industry. China’s leadership in one key working group for AV safety standards (ISO TC22 / SC33 / WG9) helps to illustrate how the Chinese bureaucracy can shape standards in emerging technologies.
- China has built up a sophisticated domestic standards bureaucracy for AVs that mirrors some key international standards bodies. That bureaucracy provides support to official Chinese representatives to formulate mature Chinese proposals that can be brought to the international body.
- In this case study of AV safety standards, China so far does not appear to be abusing its leadership role of the working group, such as stacking it with Chinese representatives or forcing the international bodies to adopt Chinese standards. This may be due to the relative immaturity of the AV industry, making it a less commercially contentious area of standards.
China’s technology ambitions, and US and European concerns about those ambitions, have moved beyond the technology itself. The setting of international technical standards—the detailed specifications for how different technologies should be built, and how they should interface with each other—has now become deeply contested terrain.
From the dimensions of cargo containers to detailed internet protocols, technical standards are the invisible threads that stitch together modern infrastructure and global trade. When agreed upon by countries and companies around the world, these shared standards facilitate the seamless movement of physical and digital goods. But they can also be an arena for fierce commercial, ideological, and increasingly geopolitical competition.
Technical standards cover a diverse gamut of industries and technologies, but the countries guiding that process have historically been homogenous: for much of the 20th century, American and European technologists presided over nearly all the key standards-setting organizations (SSOs).
Today, that prolonged western dominance is being eroded as Chinese technologists, companies, and government bodies become increasingly active in the standards-setting process. Chinese representatives are submitting more standards proposals and taking on more leadership posts in international SSOs (see Figure 1). On one level, this should come as no surprise: as a country and its companies develop stronger technological capabilities, both their motivation and ability to shape international standards will grow as well.
Figure 1. ISO TC & SC Secretariats by Country, 2011 vs. 2021
Note: 2021 totals as of May 2021. Totals do not include “twinned secretariats.”
Source: ISO and NIST.
But that growing Chinese presence has been met with concern by many American and European observers. They argue that Chinese representatives aren’t just participating in SSOs—they’re actively manipulating those organizations to advance Chinese government interests.
They point out that the Chinese government subsidizes its companies that set standards, and claim it forces those participants to vote for Chinese standards proposals. These actions are said to unfairly tilt the playing field in what should be an apolitical process, one in which the best technology wins regardless of who created it.
Evaluating these claims about Chinese influence requires getting into the weeds of actual SSOs writing specific technical standards. This case study, then, focuses on one key batch of emerging standards: safety and testing standards for autonomous vehicles (AVs).
Sitting at the intersection of emerging technologies, a promising global industry, and complex ethical questions, AV standards can illustrate both why technical standards are important and China’s role in shaping some of them. The following analysis dissects one standard currently under development by a Chinese-led working group, using it as one window into how China is interacting with international standards.
But first, a quick look at the nature and impact of technical standards, as well as the AV standards landscape, is in order.
Technical Standards as Public Goods and Commercial Competition
Designing a product requires making dozens of decisions about detailed product specifications, everything from the dimensions of physical components to the structure of software.
When these specifications only affect an individual company’s products, they’re often left up to the companies to decide. But when they affect how different products interact with each other—what’s called “interoperability”—or impact public safety, they are good candidates for common technical standards.
Interoperability is the grease in the wheels of the global economy. When products are not interoperable—think of different electrical outlets in different countries—they force the duplication of supply chains and limit the mobility of goods and services.
When products are highly interoperable—think of computers around the globe connecting to (basically) the same internet—it accelerates the exchange of products and ideas. While standards put forth by SSOs are not legally binding, they often become the default setting for a given product or across an industry.
But technical standards are not merely a public good. They’re also an arena for fierce commercial competition. Companies often patent competing technical solutions to the same problem. If one company can get its patented solution adopted as an international standard, they can earn revenue by licensing this standards-essential patent (SEP). The revenue from SEP licensing can be substantial: tech giant Nokia earned around $1.5 billion from licensing SEPs in 2017.
Beyond technical and commercial considerations, standardization can take on ideological and ethical dimensions. Standards made in the early days of the internet steered it in the direction of openness, while standards for data storage have major impacts on user privacy.
This mix of technical, commercial, and ethical considerations makes SSOs some of the most important behind-the-scenes players in the global tech landscape.
The Landscape of AV Standards
AVs currently exist in a sweet spot for technical standardization: somewhere in the wide valley between laboratory experimentation and widespread commercial adoption. The technology is mature enough to have substantive debates about technical specifications and requirements, but not so entrenched that the leading companies have already created their own de facto standards via internal design decisions.
There are several dozen AV safety and testing standards currently under development, ranging from how to validate driving simulation results to how to clean a vehicle’s external sensors. To get a concrete sense of what some of these standards do, see the table below for a small sample of standards under development (see Table 1).
Table 1. Sample of AV Safety and Testing Standards
Source: Author; public documentation from SSOs.
Scanning through these standards, it becomes clear that AV standardization is still in its early days. Many standards seek to simply define key terms or performance metrics, building up a conceptual foundation for future work. Others seek to anticipate the needs of safety regulators, standardizing the data gathered by AVs.
The early-stage nature of these standards also affects their formulation. For more mature technologies like 5G, the standards influence patents worth billions of dollars. AV standards have fewer immediate commercial implications, making them slightly less commercially contentious.
While the United States and Europe remain the standards leaders on AVs, China has made some headway in increasing its role (see Figure 2). On the early and highly influential UL 4600 standard, the United States accounted for 25 of the 34 members of the technical panel, while China had just one. At the IEEE group, the United States is by far the largest source of members, with China in a distant second place. For the ITU focus group, the chairperson comes from a UK-based non-profit, but the vice chair comes from China Telecom, and Chinese representatives are tied for second in number of attendees.
Figure 2. Membership of Select AV Standards Bodies
Note: IEEE and UL data are based on official membership. ITU data is based on attendance at FG meetings.
Source: Author, public information from SSOs.
There is also major variation between SSOs in the types of Chinese organizations participating. At IEEE P2846, the majority of Chinese members come from private companies without strong state ties. At the ITU focus group, however, Chinese membership draws heavily from state-owned enterprises (SOEs).
To better understand Chinese participation in AV standards, and entanglements with its government bureaucracy, a single AV standards working group where Chinese representatives have taken the reins provides a unique window.
Case study: Working Group 9
In early 2018, Chinese representatives at the ISO proposed the establishment of a new working group for AV standards. The WG would be placed under TC 22 (“Road vehicles”) and SC 33 (“Vehicle dynamics and chassis components”) and tasked with writing standards for “Test Scenarios of Automated Driving Systems.” In April 2018, the ISO approved the Chinese proposal, formally creating ISO / TC22 / SC33 / WG9 and placing it under the leadership of a Chinese representative.
Deliberations and documents from WG 9 are not yet public, but liaison documents and public presentations from other standards groups describe the content of the standards. WG 9 is tasked with drawing up a detailed taxonomy of different driving scenarios AVs might encounter (the nature of the road lanes, position of the “ego vehicle” and surrounding vehicles, etc.), with an emphasis on scenarios leading to accidents or traffic violations. That taxonomy then becomes the foundation for a structured database of scenarios, which can be used to test AVs for safety, either at physical test sites or through driving simulations.
The creation of WG 9 was a milestone for Chinese auto standards, marking the first time that China convened a WG on auto standards at the ISO. The landmark nature of WG 9 also generated significant domestic media coverage, coverage that pulled back the curtain on how the Chinese standards bureaucracy interacts with international SSOs.
It revealed a complex Chinese standards bureaucracy that often mirrors the organizational chart of the ISO. The organizations on the Chinese side of that mirror contribute to and shape ISO standards where possible, but they also take the international standards in and adopt them domestically. To see that process in action, a detailed organization flow chart of the key players is instructive (see Figure 3).
Figure 3. Organizational Charts for AV Standards in China and the ISO
Glossary of Common Standards Abbreviations Note: The direction of the arrow connotes the direction of influence over, management of, or contribution to a certain group. When arrows are bidirectional, the influence or contribution is going in both directions.
Source: Author; CATARC.
ISO is a multilateral SSO, meaning its membership is composed of countries, not companies or individuals. This multilateral structure of the ISO makes it an easier fit with China’s own state-led domestic processes. Each country is represented at ISO by a national standards body. In the case of the United States, that’s the private non-profit American National Standards Institute (ANSI), while in China’s case it is the state-run Standardization Association of China (SAC).
Underneath SAC are a plethora of Chinese institutions, some purely governmental and some public-private partnerships, that work on standards for a particular technology or industry. In the case of the auto industry, there is the National Technical Committee of Auto Standardization (NTCAS), which sits within the China Automotive Technology and Research Center (CATARC), a state-run research institution that supplies technical and policy expertise on China’s auto industry. CATARC itself reports up to the State-owned Assets Supervision and Administration Commission, the government agency charged with managing China’s SOEs.
In China’s AV standardization at the ISO, CATARC took the lead. The deputy director of CATARC’s standards institute, Wang Zhao, was named convener of WG 9. In that role he calls and convenes WG meetings, proposes agendas, reports up to ISO leadership within SC33 and TC22.
The Interplay: Chinese Institutions and International Standards
But CATARC didn’t merely select Wang as its representative. It also equipped him with the bureaucratic and technical spport to run the group, and to ensure that Chinese representatives are equipped with standards proposals ready for submission (see Figure 3 above).
Through its own subcommittee on intelligent vehicles, CATARC created the “expert support group” for the project. The group is composed of CATARC employees, academics, and technologists from leading Chinese companies such as Huawei and SAIC Motor. Wang gave it three tasks: 1) supporting China in its role as convener of WG 9; 2) providing draft proposals for Chinese representatives to submit; and 3) helping transfer or adapt ISO standards into domestic Chinese standards.
The benefits of this kind of bureaucratic and technical support were on display in the creation of the first WG 9 standards proposal: ISO / CD 34501. Titled “Terms and definitions of test scenarios for automated driving systems,” the group was tasked with creating a technical “glossary” to be used when writing other AV test scenario standards. Wang’s CATARC colleague Sun Hang was appointed to lead the project.
In the process of drafting 34501, Sun and Wang relied heavily on the expert support group for drafting proposals and resolving comments from the larger group. Following an April meeting of WG 9 in which Wang called for preparing a Committee Draft (CD) of the proposal ready to be voted on, Sun hosted a meeting of the expert support group in July. That meeting drew more than 70 attendees, including representatives from Huawei and SAIC, and was used to review all the proposals under consideration and discuss any remaining problems.
That fall, Sun led the 34501 group in producing CD 34501, and in January 2021 it was officially submitted for voting by members of the parent organization, TC 22. It is impossible to know how the content of the final proposal compares to what emerged from the expert support group. But it appears to be a prime example of one of the tasks of the expert support group: providing mature proposals for Chinese representatives to submit at the ISO.
Voting on the current draft of ISO / CD 34501 closed on April 23, 2021, with the results to be released soon. If approved by members of the TC, 34501 would ultimately be put up for a vote by all members of the ISO. If it smoothly passes, it would be the first ISO auto standard to emerge from a Chinese-led working group.
China as Influencer and Adopter
Did China leverage its power as the convener of WG 9 to manipulate the group or shove through Chinese proposals? It’s impossible to know for sure, but the public documents and Chinese accounts do provide a far more nuanced account than the most alarmist narratives of a Chinese takeover of SSOs.
They reveal a process in which the Chinese government deploys significant bureaucratic and commercial resources to ensure Chinese representatives make an impact, but does not seek to dominate that process entirely. Perhaps surprisingly, China also seems to willingly adopt international standards—a win for SSOs and interoperability.
First, the influence of the Chinese government bureaucracy. At almost every level, the Chinese actors in the ISO process hail from state-run, or heavily state-influenced, organizations. Along with Wang’s leadership of WG 9, prominent members of the expert support group are often state-owned (SAIC Motors) or closely tied to the state (Huawei), with occasional contributions from fully private companies like Alibaba’s Cainiao.
And yet, China does not appear to have used its leadership over WG 9 to shove through Chinese priorities. The 34501 standard creation headed by Sun was not the only one launched under Wang at WG 9. There are currently three others—34502, 34503, and 34504—created by the group, and these are led by experts from Japan, the United Kingdom, and Germany, respectively.
The only other project that was to be led by a Chinese expert—the proposed 3405—was ruled too immature, and as of this writing has been shelved. Looked at from this angle, it does not appear that China has abused its position to pack the group with its members or proposals.
Notably, WG 9 has also not been an outlet for China to foist its already-decided domestic standards on the world. While China’s standards bureaucracy has created a broad subcommittee for intelligent vehicles, it has not yet created a domestic equivalent to WG 9. Instead, it has focused its efforts on contributing to WG 9 via the expert support group, and then adopting whatever final standard comes out of the ISO and turning it into a domestic standard for China.
At least at this stage, there appears to be a healthy back-and-forth between China’s standards bureaucracy and the ISO, one in which China tries to make its mark on the international system but ultimately adheres to what it produces. This could be influenced by the early stage of AV commercialization: there currently aren’t major profits to be made off patents, and most participants appear invested in advancing standards so that the market as a whole can grow.
This has implications for governments around the world grappling with China’s growing sway in standards bodies. There have been well-documented cases of abusive practices at some SSOs, such as forcing all Chinese representatives to vote for Chinese proposals. But these practices appear to cluster in standards for more mature technologies, such as 5G, where the commercial or political impacts are highly salient. Organizations hoping to counter those practices would do best to focus their resources in these more immediately competitive areas.
Matt Sheehan is a Fellow at MacroPolo. You can find his work on tech policy, AI, and Silicon Valley here.
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