The subject of retrofitting kit systems was raised at the meeting. DfT stated that such vehicles might need single vehicle approval. We are going to be revisiting this subject at the next meeting, I believe it will take place February but to-date I don't have confirmation.
As I will be at the meeting, I would be more than happy to make representations on behalf of Pedelecs members if you would like me to do so.
All the best
David
Interesting that they raised the notion of SVA, yet they also mentioned grandfather rights!
At present the law does not require that a DIY conversion or kit ebike be Type Approved, so I would be very resistant to the notion that some form of approval by introduced. This would be a retrograde step and would introduce more regulation than we have at present.
UK law has, since 1983, allowed anyone to convert an ordinary pedal cycle into an electrically assisted pedal cycle. The only technical regulatory requirement is that the motor continuous rated power has to be less than 200W. In principle this allows a kit or parts supplier to sell a motor that has been tested to the required British Standard and provide a copy of the defined power output of the motor to the builder. The builder then only has to include this figure on the data plate on the bike and they are, provided they have met the other requirements, legal.
Things have clearly moved on since 1983, and no kit or parts suppliers that I know of are able to supply a motor/controller with a power defined by the required BS. This has meant that all kit or DIY converted ebikes have been illegal for many years.
There is a general principle in regulation that there needs to be a good reason for making it tighter. I can see no good reason in removing the ability for individuals to build kit or DIY conversions provided that these do not increase the risk to the general public.
The simple assessment of maximum weight and speed, plus braking function, that I mentioned earlier is all that is required for a DIY or kit conversion. In the same way that the EPAC power limit is irrelevant because it can legally be circumvented during approval testing, so any similar restriction on a DIY or kit converted ebike is also irrelevant.
I'll try and draft something and put it up on a specific thread here for discussion, and if there is no significant objection suggest that it be put forward to the DfT as representing the wishes of UK consumers. If you could either raise this on our behalf, David, or better still persuade the DfT (and your fellow BEBA members) to allow one of us to put the case to them from consumers, then that would be great.
