Etra (European Twowheels Retail Association) is currently lobbying the European Parliament for better technical regulations for electric bikes and light electric vehicles. Whilst the association was arguing its case on the basis of “encouraging a shift to sustainable mobility” it has found itself unintentionally in a cyclists versus electric cyclists confrontation.
Etra is asking the industry whether it wants the market to remain limited to bicycles with pedal assistance up to 25 km/h (15.5 mph) and a motor output limit of 250W, or:
if it wants the market to grow to its full potential allowing different types of electric bikes and light electric vehicles to become widely and easily available. For example:
city pedelecs, speed pedelecs, electric tricycles, electric mountain bikes, electric cargo bikes, pedicabs, electric recumbents, velomobiles, …
It is inviting the industry to assist ETRA in convincing the European Parliament and Commission that a considerable part of the electric bike business is behind the ETRA proposal.
Today, there are 2 different European regulatory frameworks for electric (bi)cycles and light electric vehicles:
1. The Machinery Directive in combination with the EN 15194 standard applies to (bi)cycles with an electric motor that assists up to 25 km/h and has a maximum continuous rated power of 250 W.
2. The type-approval procedure for motorcycles applies to (bi)cycles with an electric motor that assists above 25 km/h and/or has a maximum continous rated power of more than 250W, as well as to all bicycles that can be propelled by the motor itself.
The differences between the 2 regulatory frameworks are very important:
1. Classification under the Machinery Directive + EN 15194 means: .
a. that the manufacturer can self-certify. There is no legal obligation to use an accredited lab to test their vehicle;
b. that the vehicle as a whole needs to comply with the rules, not the separate components;
c. that components can be freely replaced, provided the whole vehicle continues to comply with the rules;
d. that components do not need to be type-approved if used as spare parts;
e. that the vehicle is classified in such a way that the rider can use it with no further obligations;
2. Classification under the type-approval for motorcycles means:
a. that the manufacturer can only obtain certification through an accredited lab;
b. that not only the vehicle needs to be type-approved but also most of its components;
c. that components can only be replaced by type-approved components;
d. that changing a component means going back to type-approval;
e. coping with type-approval requirements that are designed for motorcycles, thus technically not adapted for electric bicycles and light electric vehicles;
f. classification of the vehicle as a moped as a result of which riders can only use it with a helmet, drivers’ licence, insurance, number plate, …
At the end of 2010, the European Commission developed a proposal aimed at updating the type-approval procedure but has omitted to introduce any changes for the benefit of electric bicycles and light electric vehicles. On the contrary, the European Commission proposes even more inapppropriate requirements such as for instance On Board Diagnostics, anti-tampering measures for the powertrain (which includes gears, brakes, …) and wheels that should be able to rotate at different speeds at all times for safe cornering. This proposal is now in the European Parliament that is expected to amend the Commission’s proposal.
ETRA has been lobbying the European Parliament for 3 main issues:
1. as for bicycles with a motor that assists up to 25 km/h irrespective of their motor output limit: exclusion from the type-approval for motorcycles and inclusion in the regulatory framework of Machinery Directive + EN 15194
2. as for bicycles and light electric vehicles with an electric motor that can propel the vehicle itself which do not weigh more than 25 kg: exlusion from the type-approval for motorcycles and inclusion in the regulatory framework of Machinery Directive + EN 15194
3. as for all other electric bicycles and light electric vehicles that will be included in the type-approval for motorcycles: requirements that are adapted and appropriate to these vehicles.
In ETRA’s position paper that was submitted to the European Parliament and Commission it includes a detailed explanation, as well as all the amendments that are needed to implement the 3 principles above.
Today, the members of the European Parliament are confused. They are being lobbied by representatives of cyclists and of the bicycle industry who argue that more electric (bi)cycles and light electric vehicles on the road will endanger the safety of “conventional” cyclists. They want to make sure that the market remains limited to (bi)cycles with pedal assistance up to 25 km/h and a motor output limit of 250W.
ETRA believes that its proposal will have no negative effects on road safety. ETRA believes on the contrary that there is a huge potential for developing the market of electric (bi)cycles and light electric vehicles, a potential for convincing people and companies to swap from cars to electric cycles for certain trips. More electric cycles on the road will mean less cars thus improved road safety for all vulnerable road users. However, this potential cannot be unlocked if manufacturers are confronted with a regulatory framework that is not appropriate, which is the case today.
– If the industry wants the market to remain limited to bicycles with pedal assistance up to 25 km/h and a motor output limit of 250W, it does not need to do anything.
– If the market is to grow to its full potential allowing different types of electric (bi)cycles and light electric, i.e. city pedelecs, speed pedelecs, electric tricycles, electric mountain bikes, electric cargo bikes, pedicabs, electric recumbents, velomobiles, … to become widely and easily available, ETRA needs to convince the European Parliament that a considerable part of the electric (bi)cycle business is behind the ETRA proposal.
The industry can show support ETRA by co-signing the joint letter on the ETRA website.
The draft report of the European Parliament on the review of the type-approval has been published on 5 May 2011. The Rapporteur, Wim van de Camp, has not yet introduced any provisions for the benefit of electric cycles and light electric vehicles because he is still considering the safety issue. The deadline for such provisions is end of June. It is our intention to send the joint letter to him, to all other MEPs and EU officials in order to convince them of the necessity and the support for the ETRA proposal.