TL;DR “Not Possible”.
1. Barrier for FSD Localization
In August last year, the Ministry of Natural Resources issued the “Notice of the Ministry of Natural Resources on Promoting the Development of Intelligent Connected Vehicles, Maintaining Geospatial Information Security and Management”. Certain aspects of this notice (excerpted) are clearly defined:
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- The collection, storage, transmission, and processing of geospatial information data, such as the spatial coordinates, images, point clouds, and attribute information of vehicles and surrounding road facilities during the operation, service, and road testing of intelligent connected vehicles with satellite navigation positioning receiver modules, inertial measurement units, cameras, and lidars, etc., constitute the surveying and mapping activities as defined in the Surveying and Mapping Law of the People’s Republic of China and shall be standardized and managed in accordance with relevant laws, regulations, and policies on surveying and mapping.
…- Those who collect, store, transmit, and process geospatial information data such as spatial coordinates, images, point clouds, and attribute information generated during the operation, service, and road testing of intelligent connected vehicles are the entities responsible for surveying and mapping activities and must abide by relevant regulations and legally bear corresponding responsibilities.
Based on the current situation of the market, the collection, storage, transmission, and processing of data are mostly provided by vehicle manufacturers, service providers, and some intelligent driving software providers, and intelligent connected vehicle drivers and passengers who only obtain assisted driving services are not the actors in the surveying and mapping activities.
…- Ground mobile measurement, navigation electronic map production, and other fields belong to the field where foreign investment is prohibited according to the “Special Management Measures for Foreign Investment Access (Negative List) (2021 Edition).” Domestic companies that have obtained surveying and mapping qualifications in these professional categories shall strictly implement relevant national regulations.
According to the first clause, the process of training data for Tesla using data collected from thousands of cars delivered is regarded as surveying and mapping activities under the Surveying and Mapping Law of the People’s Republic of China.
According to clause two, the main body of surveying and mapping activities is Tesla (vehicle manufacturers, service providers, and some intelligent driving software providers), not car owners.
According to clause four, as a foreign-owned enterprise, Tesla is prohibited from entering the surveying and mapping domain.
Therefore, whether or not Tesla’s FSD can be promoted in China is no longer just a matter of data centers being located in China or whether data is being exported. As long as Tesla remains a foreign-owned enterprise, directly collecting training data through the sale of vehicles cannot be compliant with Chinese regulations.
After reading this “Notice,” I had an idea of selling cars, because Tesla in China is basically locked into the version that recognizes traffic lights, and it is difficult to switch to the new engine based on Convolutional Neural Network (hereinafter referred to as BEV engine). This suspicion was further confirmed when Tesla removed its ultrasonic radar from the 3/Y sold in China in October last year, and the Chinese version has not caught up yet.
2. Leaving FSD, HW4 almost has no benefits
Now, HW4 is here. According to the information currently disclosed, the camera layout of HW4 has been adjusted. By expanding the field of view, improving the resolution, and adding cameras (not yet confirmed), it further reduces the close distance blind zone. Assuming that the HW4 in China will be updated simultaneously and the ultrasonic radar will be removed, what new features can these new vehicles with Chinese versions of HW4 get?
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Short-range perception will be replaced with BEV engines, and the model for short-range perception has no regional differences, so the model data trained in foreign countries can be used directly.
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NOA still has not implemented Single Stack switching, so HW4 probably will have a NOA system that still uses the existing AP engine to switch with FSD dual-stack. China can continue to use the AP engine transplanted to HW4 for AP / NOA functions.
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Clearer cameras and larger field of view may further improve the upper limit of AP/NOA capability, but the current upper limit is already very high and may be difficult to perceive.
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Since Tesla’s intelligent summon function without ultrasonic or radar has not returned yet, it is likely to switch to the FSD stack, which may be beyond China’s reach.
Conclusion
In summary, upgrading HW4 in China almost gives no benefits. Therefore, why not clear the inventory while continuing to fight price wars? Therefore, I speculate that the HW4 modification of Tesla will not be updated simultaneously in China, and may have to wait until the inventory of HW3 is used up or when the cost of HW4 does not have a significant difference compared to HW3.
This article is a translation by ChatGPT of a Chinese report from 42HOW. If you have any questions about it, please email bd@42how.com.