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Manufacturer communication · Service bulletin

Subaru bulletin 09-109-23

What it saysThis bulletin announces diagnostic procedures along with availability of new Engine Control Module (ECM) reprogramming files to address DTC P2404 (Evap System Leak Detection Pump Sensor Circuit Range/Performance)… NHTSA’s full summary ↓

Subaru filed this with NHTSA as a service bulletin dated Jul 25, 2023, received Aug 2, 2023, about the electrical system. It names 6 model years (2016–2019). A service bulletin is not a safety recall: it is the manufacturer telling its dealers how to diagnose or repair a condition, and whether the work is paid for depends on the warranty in force. Quoting the number at a service desk can save a diagnosis.

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What the bulletin says

Source: NHTSA's summary of the manufacturer's communication

This bulletin announces diagnostic procedures along with availability of new Engine Control Module (ECM) reprogramming files to address DTC P2404 (Evap System Leak Detection Pump Sensor Circuit Range/Performance) detection.

Trouble codes it names: P2404 P2419 P2420 2 of 3 read from the document itself

Kind Service bulletin Manufacturer date Jul 25, 2023 Received by NHTSA Aug 2, 2023 Components Electrical System, Engine, Equipment

Document filed under this number

DocumentKindDatedNHTSA idAt NHTSA
09-109-23Service bulletinJul 25, 202310240121PDF, 1,345 KB

The summary is NHTSA’s abstract of the document, as filed under 49 CFR 579.5. One communication is usually filed as several documents — the bulletin, a dealer notice, an owner letter — and the number on any of them finds this page. A PDF link is shown only once NHTSA’s own server has been seen to serve that document; the rest are checked over the following nights. Quote the number at a service desk; it is what the dealer’s system is keyed on.

Doing the repair yourself, or pricing it before the shop does? Search the part by fitment on eBay Motors — the listing and the price are the seller’s.

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Model years it names

Source: as the manufacturer filed them

A vehicle page’s bulletin list shows the newest few communications filed against that model year; the count there is every one.

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What owners reported

Source: NHTSA complaint database

Owners of the 6 model years this bulletin names have filed 3,912 complaints with NHTSA since 2015. 1,685 of them name Electrical System, Engine — the same broad component group this bulletin is filed under. NHTSA groups complaints coarsely, so that means the same area of the vehicle, not necessarily the same fault.

On the 2017 Subaru Legacy/Outback, the 179 owners who gave an odometer reading for Electrical System reported it at a median of 32,000 miles. That figure is one model year’s, not the whole range this bulletin covers — medians from different model years are not averaged.

While backing out of my garage, the radio unit froze making the backup screen inoperable. This is a brand new car with 200 miles on it. According to the dealer, they will have to replace the head unit. They were able to get the unit working, hopefully until the new head unit arrives, by physically disconnecting the car battery.

2019 Subaru Outback · Electrical System · filed with NHTSA Jun 6, 2019

When I go to park my 2017 Subaru Legacy, I put my car in park and the key will not turn. It gets stuck and the engine will not turn off. Consequently, I AM not able to turn off my car and take my key out. The dealer told me to back up my car and thrust my gear shifter into park. Then I was able to turn the key off.

2017 Subaru Legacy/Outback · Engine · filed with NHTSA Oct 22, 2019

Rear tail gate opens without activation at 35 MPH while vehicle is in motion. I have a video but it is too big to send. My wife and I were on a busy highway after just purchasing flowers and plants at a local nursery when the tailgate just started to open all by itself spilling some of the plants on the highway.

2018 Subaru Outback · Electrical System · filed with NHTSA May 4, 2018

A complaint is one owner’s account, not a defect finding, and a bulletin is not a recall. Nothing here says this bulletin was issued because of these complaints, or that the repair it describes fixed them. Complaint files on this site begin in 2015.

More bulletins about the electrical system

Source: same model, same component group

97 other manufacturer communications filed against these Subaru models under the same component group (electrical system), newest first. The eight newest are listed; the rest are on the Subaru list.

NumberKindDatedNHTSA’s summary
15-342-26Service bulletinAug 31, 2026This bulletin announces an inspection procedure for the Smart Rear View Mirror Assembly.
15-261-20RService bulletinAug 31, 2026This bulletin announces reprogramming file availability and provides a software update installation procedure to optimize the new Gen 4 Dens…
15-308-23RService bulletinAug 20, 2026This Service Information Bulletin outlines a systematic procedure for diagnosing parasitic draw (dark/standby current) in vehicles experienc…
15-305-22RService bulletinAug 20, 2026This bulletin announces a reprogramming file availability and provides a software update installation procedure to optimize the new Gen 4.5…
15-331-25RService bulletinAug 14, 2026This Bulletin has been developed to outline the steps for gathering basic but essential information during diagnosis of Infotainment concern…
15-304-22RService bulletinAug 13, 2026This Bulletin has been developed to outline the steps for gathering basic but essential information during diagnosis of Infotainment concern…
15-333-25RService bulletinAug 1, 2026This bulletin contains illustrations of exchange components and their manufacturer as well as a description of the proper exchange procedure…
15-340-26Service bulletinJul 31, 2026This bulletin announces the availability of reprogramming files for the Central Electronic Control Module (C-ECM). The updated logic has bee…

Quote the number at the service desk. It is what the dealer’s system is keyed on.

Every manufacturer communication NHTSA holds for Subaru, by the number printed on the letter.

Photo: Christian Buehner / Unsplash

Common questions

Source: NHTSA, 49 CFR 579.5

Is Subaru 09-109-23 a recall?

No. A service bulletin is a manufacturer communication filed with NHTSA under 49 CFR 579.5; a safety recall carries an NHTSA campaign number (two digits, a letter, six digits) and a federal duty to repair for free. Check the vehicle’s recalls by VIN at nhtsa.gov/recalls, or on its page here.

Is the 09-109-23 repair free?

Not automatically. A service bulletin describes how to diagnose or repair a condition; who pays depends on the warranty in force, any extension, and the dealer. Quoting the number can save a diagnosis either way.

Which vehicles does 09-109-23 cover?

The manufacturer filed it against 6 model years: 2019 Subaru Legacy, 2018 Subaru Legacy, 2017 Subaru Legacy/Outback, 2016 Subaru Legacy/Outback, 2019 Subaru Outback, 2018 Subaru Outback. Whether one particular vehicle is affected is a matter of its VIN and its build, not its model year alone.