European regulations, one more time

[Arbol]

It is still not 100% clear to me how can a bike with a kit be 100% compliant with European regulations.

EN 15194 requires (among other things):

- 25km/h max speed
- 250W max nominal power

There are several ways to cope with these regulations:

a. The first way would be to limit max speed mechanically (and also max nominal power mechanically, through a 250W Euro compliant label). According to the approximate formula: max speed = 25km/h * (wheel diameter / 26'') * (battery voltage / 36V) * (rpm of the motor / 201) * 1.1 factor (?), a 26'' bike, with a 201rpm motor and a 36V battery will have its max speed around 25km/h

b. Most "legal" configurations do not satisfy (a), i.e. the "legal" bike is capable of more than 25km/h max speed (eg a 270rpm motor, such as the "legal" 250W BPM CST). Then:

b.I. Some controllers have a max speed regulator, such as the KU63
b.II. Some controllers with a LCD can limit the max speed with the settings (but supposedly the motor should be 250W nominal max power compliant)
b.III. Cycle Analyst allows different modes. One could set a mode being "Eco Legal", with say 36V 15A (540W, but I believe that due to losses and all that, this config is considered as legal) and 25km/h max speed. There could be other modes to be run only outside open roads. Under this option, the motor would not need to be 250W nominal max power compliant
b.IV. Dongles, for I believe at least Bosch: the bike is "legal", but it has the option to adopt a dongle that unlimits the bike
b.V. BH uses 350W motors but "restricted to" 250W. I do not know what does mean, and how they perform that limitation, if either directly to the motor (unlikely) or through current limitations on controller / battery

I am quite sure that the prevalent interpretation of the law is NOT 1.a., which would be the really legally compliant. As a consequence, it seems there is the prevalent idea one "can do things" while respecting the law.

I do not even know what most reputable e-bike sellers / producers in Europe / UK do. I believe, but I am not 100% certain, that b.I, b.II and b.V are considered as "legal".

It seems b.III. would not be considered as "legal", but why not? If one is breaking the law with the 25km/h speed, and one is allowed to restrict max speed via an LCD, why not doing the same with the power? Of course, one should stop the bike to change the settings, either way. My main point here is that despite the fact most people focus on "Euro compliant motors", I believe EN 15194 is about "Euro compliant e-bikes" not motors. So, despite having a more than 250W nominal motor, if the bike itself is limited to 250W nominal, it should be legal (is this the way BH uses b.V?). So, a CA limited bike with a powerful motor should be legal ... if the issue of changing settings is allowed, since I believe to remember there was a "by construction" statement or similar. But wahat is "by construction"? Mechanical hard wiring? electronic settings? electronic settings inside a case not to be manipulated by a biker while biking?

May I ask opinions?

 

[shemozzle999]

There is no need to run an ebike illegally in the UK now that the next generation of motors have been released. It is the Chinese that have solved the problem by developing true 250W motors capable of hill climbing and removed the excuse that higher powered motors are needed to climb the hilly parts in the UK. It just needs the UK dealers to adopt them.

 

[Arbol]

There is no need to run an ebike illegally in the UK now that the next generation of motors have been released. It is the Chinese that have solved the problem by developing true 250W motors capable of hill climbing and removed the excuse that higher powered motors are needed to climb the hilly parts in the UK. It just needs the UK dealers to adopt them.

I am thinking about Lightningrods kit.

 

[shemozzle999]

There is now no barrier for the UK to adopt the EN 15194 standards and have 100% compliant ebikes.

 

[Deleted member 4366]

I think that you've misinterpreted the regulations regarding power. There is no power limit, but the motor must be of 250w nominal rated power, which means that the manufacturer must mark it as 250w. A motor that's marked any more than 250w doesn't comply regardless of how much you restrict it, but on the other hand, if Bafang or whoever sticks a 250w label on it, you can pump as much power through it as you want.

 

[trex]

It is still not 100% clear to me how can a bike with a kit be 100% compliant with European regulations.

EN 15194 requires (among other things):

- 25km/h max speed
- 250W max nominal power

There are several ways to cope with these regulations:

a. The first way would be to limit max speed mechanically (and also max nominal power mechanically, through a 250W Euro compliant label). According to the approximate formula: max speed = 25km/h * (wheel diameter / 26'') * (battery voltage / 36V) * (rpm of the motor / 201) * 1.1 factor (?), a 26'' bike, with a 201rpm motor and a 36V battery will have its max speed around 25km/h

b. Most "legal" configurations do not satisfy (a), i.e. the "legal" bike is capable of more than 25km/h max speed (eg a 270rpm motor, such as the "legal" 250W BPM CST). Then:

b.I. Some controllers have a max speed regulator, such as the KU63
b.II. Some controllers with a LCD can limit the max speed with the settings (but supposedly the motor should be 250W nominal max power compliant)
b.III. Cycle Analyst allows different modes. One could set a mode being "Eco Legal", with say 36V 15A (540W, but I believe that due to losses and all that, this config is considered as legal) and 25km/h max speed. There could be other modes to be run only outside open roads. Under this option, the motor would not need to be 250W nominal max power compliant
b.IV. Dongles, for I believe at least Bosch: the bike is "legal", but it has the option to adopt a dongle that unlimits the bike
b.V. BH uses 350W motors but "restricted to" 250W. I do not know what does mean, and how they perform that limitation, if either directly to the motor (unlikely) or through current limitations on controller / battery

I am quite sure that the prevalent interpretation of the law is NOT 1.a., which would be the really legally compliant. As a consequence, it seems there is the prevalent idea one "can do things" while respecting the law.

I do not even know what most reputable e-bike sellers / producers in Europe / UK do. I believe, but I am not 100% certain, that b.I, b.II and b.V are considered as "legal".

It seems b.III. would not be considered as "legal", but why not? If one is breaking the law with the 25km/h speed, and one is allowed to restrict max speed via an LCD, why not doing the same with the power? Of course, one should stop the bike to change the settings, either way. My main point here is that despite the fact most people focus on "Euro compliant motors", I believe EN 15194 is about "Euro compliant e-bikes" not motors. So, despite having a more than 250W nominal motor, if the bike itself is limited to 250W nominal, it should be legal (is this the way BH uses b.V?). So, a CA limited bike with a powerful motor should be legal ... if the issue of changing settings is allowed, since I believe to remember there was a "by construction" statement or similar. But wahat is "by construction"? Mechanical hard wiring? electronic settings? electronic settings inside a case not to be manipulated by a biker while biking?

May I ask opinions?

You can buy a motor with EN15194 test certificate (most 250W Chinese motors do have) but it's just covering the motor, not the bike. The bike has to pass EM test, configured with the motor.
That will require obtaining a test certificate - costing $7000 for one or 2 bikes in Shanghai or £10,000+ in Europe or a certificate of conformity. You cannot make your own declaration of conformity unless you can substantiate your claims with other bikes that you make that have been certificated.
Therefore you can't own a kit that is 100% EN15194 compliant.

 

[Arbol]

OK, here we have two apparently contradictory claims:

- d8veh: "if Bafang or whoever sticks a 250w label on it, you can pump as much power through it as you want"
- trex: "you can't own a kit that is 100% EN15194 compliant"

Which is the right claim? It seems as if trex's claim is the right one, because EN15194 is intended for bikes, not only for motors.

Having said that, normal usage seems to back up d8veh's claim, since there are sooooo many e-bikes with kits in Europe. Can it be all these e-bikes are illegal???

In fact, what do UK / European e-bike sellers do? Do they pay these amounts of money to certify each model they sell? I see some e-bike sellers here in the forum having say 10 or more different models. Do they certify each model they sell??? This would be about 100,000 pounds, according to trex's numbers.

 

[trex]

the cost of certification is not much - typically, a Chinese factory will pay for the certificates (usually SGS) for bikes that they reckon will sell for more than 2,000 pieces in their first year. That works out $1.5 per bike in the worst case scenario. Small modifications of this bike (eg changing forks, brakes, saddle, wheel sets, this sort of things), the test certificate remains good enough for a self issued COC. The cost of certificating is negligible.
No kit is sold with test certificate. If the sellers say otherwise, they lie.

 

[Arbol]

What is the solution to the riddle, then?

We have at least 4 scenarios:

A. kits added to a non-electric bike, by a single user. This is apparently illegal, despite the fact it is normal practice in Europe
B. Fully fledged e-bikes, such as I guess Haibike, KTM and all that. I guess these bikes are completely legal
C. e-bikes sold by reputable UK / European vendors, but which are non-electric bikes with an electric kit. I believe many vendors follow that path. Are they being illegal??? I cannot imagine that.
D. Chinese e-bikes sold by reputable UK / European vendors. I imagine this case follows under the umbrella of the Chinese producer having certified the bike in China, so it is legal then.

 

[trex]

A, B, D are correct.
C. I don't know of any example that fits your criteria.

I can speak of my own bike, the BBS01 is certified, my bike is EC certified (but not EN15194 because it's not electric). I don't have an EN15194 test certificate and I don't have an EN15194 label affixed to the bike. So I guess my bike is not compliant.
I have never been stopped by the police and I am not volunteering to go ask them about it just in case they decided to crush my bike.

 

[Arbol]

One example (not 100% certain, because I am talking about reputable companies I do not fully know) of C is a reputable vendor in this forum, saying he is not going to build BBS-01 motors anymore due to lack of availability of single components in case of component failure and need of replacement.

I imagine (but as said, not 100% certain; I would like to have the participation of that reputable forum member) the BBS-01 is fully certified, but only certified as a motor+controller, not as a whole bike.

As a consequence, this seems an example of C: a reputable vendor installing certified motors in a non-certified bike, resulting in a non-certified e-bike.

 

[peerjay56]

One example (not 100% certain, because I am talking about reputable companies I do not fully know) of C is a reputable vendor in this forum, saying he is not going to build BBS-01 motors anymore due to lack of availability of single components in case of component failure and need of replacement.

I imagine (but as said, not 100% certain; I would like to have the participation of that reputable forum member) the BBS-01 is fully certified, but only certified as a motor+controller, not as a whole bike.

As a consequence, this seems an example of C: a reputable vendor installing certified motors in a non-certified bike, resulting in a non-certified e-bike.

I don't think cycleezee ever built bikes for sale with the BBS-01. I think he provided a fitting service to purchasers bikes.
Xipi (no longer on the forum) and I think Alien Bikes (now sadly defunct) are examples of C.

 

[trex]

xipi builds off-road bikes, clearly outside EN15194.
In Alien case, if the kit is the same electronics as in one of their certificated imported bikes, they may be able in principle to issue individual COCs.
Somehow, I don't think this was the case, not for the Golden motor kits anyway.

 

[flecc]

The EN15194 test for a pedelec's power can be one of two options, one of them having considerable flexibility in the way the design can be made to pass the test while allowing very much more than the legal 250 watts maximum continuous power.

It is as stated a test of a complete e-bike. The alternative test of power with no flexibility is at the motor shaft, so some kits could be tested that way. However the regulations don't state as much.

I believe to be truly legal a completed kit e-bike should be submitted to the country's Vehicle Inspectorate to be tested to see if it avoids registration under the EU's two and three wheeled motor vehicle type approval law. The Inspectorate could them determine if it is a pedelec as specified in the exemptions from that law as stated in Section 1, sub-section 1.h.

 

[trex]

even if the vehicle passes inspection and approved as pedelec, it is still not EN15194 certified, so you still can't ride it in other EU countries.

 

[flecc]

even if the vehicle passes inspection and approved as pedelec, it is still not EN15194 certified, so you still can't ride it in other EU countries.

Agreed, the method I described would only hold good for the country of inspection.

 

[Gubbins]

With regard to policing.. I would expect that very few of the police that you are likely to encounter on a day to day basis will know anything about whether its a legal or illegal e bike. In fact a friend is a police officer and he didn't even know they existed..

 

[flecc]

With regard to policing.. I would expect that very few of the police that you are likely to encounter on a day to day basis will know anything about whether its a legal or illegal e bike. In fact a friend is a police officer and he didn't even know they existed..

Two groups in the police do sometimes have knowledge of pedelec law. First are officers in forces who have tried or regularly use e-bikes for various patrol duties. Second are Traffic Department officers who have shown themselves to have that knowledge on some occasions.

In forces where both those apply, that knowledge is even more likely to be apparent.

And of course in addition we do have some serving and ex police officers as members of this forum. About one person in 250 of our population is a serving police officer, so pro-rata we might reasonable expect to have about 28 serving police officers as members, although only two have declared themselves to be so.

 

[Arbol]

I understand that most policemen do not know about all this. But my concern is not so much about tickets (it is "only" money) but a potential accident, when the e-biker is not guilty, but the insurance agent finds out regulations are not satisfied. Then, it is not "only" money. I know this is an extreme situation, but I think forum members are so knowledgeable and deep into this subject, that I believe it makes sense to raise the question.

 

[KTM Bike Industries UK]

I spoke at length with a variety of levels of Police Officers at the Welsh Cycle Show at the weekend...

They reinforced our concerns that whilst you might "get away with it" day to day and even for a number of years, especially whilst eBikes are relatively underground. The problem will come if you are involved in an accident and someone spots that you are riding an illegal bike on the roads. Then the costs and penalties could go up very very quickly.

Also you're going to find that with big bike brands like us an Cube now selling volume of eBikes in the UK, we'll be pushing to make sure the guys who are selling bikes that are over powered are brought to the attention of the powers that be, so that we're all competing on a level legal playing field.

Its the same as anything really... you can drive your car round with no insurance or tax for months and get away with it.

whether you'd want to then be involved in a crash or not is something on the individual can decide.

Col