Given the 'single swipe' restriction, it's impossible not to extend that argument to changing the radio, adjusting your seat or turning on the AC.
Touchscreens lack that ability, you have to look at them to interact with them
Not touchscreens?
Playing the next track on the phone may actually be less distracting than changing the radio station because many built-in radios lack voice control whereas on the phone you might be able to use the phones voice assistant to change the track.
Of course even this is kind of moot, because a lot of car manufacturers put vital controls on the touchscreen. I mean, Teslas have the fucking gear shift on the touchscreen.