Just happened across this but can't comment on its accuracy

Storcker

Pedelecer
Nov 24, 2012
46
0
Unfortunately it's not. This is Statute Law, so the onus is on the manufacturer (who may be the person that fits a kit to a bike) to prove that the motor can only deliver 200W output, as defined by the method described in BS1727:1971.


If you want chapter and verse then this is what the Road Traffic Act (in UK SI 1168, the EAPC Regulations) gives as definitions, quote:

"2. In these Regulations—
“continuous rated output” has the same meaning as in the 1971 British Standard;
“kerbside weight”, in relation to an electrically assisted pedal cycle, means the weight of the
cycle without any person on it and with no load other than the loose tools and equipment with
which it is normally equipped;
“nominal voltage” means the nominal voltage of the battery as defined in the 1971 British
Standard;
“the 1971 British Standard” means the specification for motors for battery operated vehicles
published by the British Standards Institution under the reference 1727: 1971 as amended by
Amendment Slip No. 1 published on 31st January 1973, Amendment Slip No. 2 published on
31st July 1974 and Amendment Slip No. 3 published on 31st March 1978;"


and this is what it actually says with regard to the requirements, quote:

"4. The requirements referred to in Regulation 3 above are that the vehicle shall:—
(a) have a kerbside weight not exceeding—
(i) in the case of a bicycle, other than a tandem bicycle, 40 kilograms, and
(ii) in the case of a tandem bicycle and a tricycle, 60 kilograms;
(b) be fitted with pedals by means of which it is capable of being propelled; and
(c) be fitted with no motor other than an electric motor which—
(i) has a continuous rated output which, when installed in the vehicle with the nominal
voltage supplied, does not exceed—
(A) in the case of a bicycle, other than a tandem bicycle, 0.2 kilowatts,
(B) in the case of a tandem bicycle and a tricycle, 0.25 kilowatts; and
(ii) cannot propel the vehicle when it is travelling at more than 15 miles per hour."


These parts of the law have to be read in conjunction with the parts of The Pedal Cycles (Construction and Use) Regulations 1983, in UK SI 1176, quote:

"Interpretation
3. - (1) In these Regulations:-
(a) a reference to the manufacturer of a vehicle means, in the case of a vehicle which has been so altered so as to become an electrically assisted pedal cycle, the person who made that alteration;"


This law also states:

"4. No Person shall ride, or cause or permit to be ridden, on a road a pedal cycle to which the Electrically Assisted Pedal Cycles Regulations 1983 apply unless it is fitted with -
(a) a plate securely fixed in a conspicuous and readily accessible position showing:-
(i) the name of the manufacturer of the vehicle,
(ii) the nominal voltage of the battery (as defined in the 1971 British Standard) of the vehicle, and
(iii) the continuous rated output (as defined in the 1971 British Standard) of the motor of the vehicle;"


From this you can see that before you fit the plate to the bike with the rating, you have to ascertain the motor power and battery voltage according to the BS, you can't do this afterwards as otherwise the information on the plate would be, in effect, made up, rather than measured, as required.
Looking at the dates of the statutes quoted they mostly were brought in before the UK became part of the EU.
Since we became subject to EU law, that takes preference over UK law, I believe all electrical goods sold in the EU have to be marked with a CE approval badge.
Certainly my own Storck motor is so marked and having had a quick look at other electrical goods in my house they all seem to be marked as CE approved to whatever that particular standard is.
I think the law requires the importer of goods from outside the EU to ensure the goods comply with regulations not the end user. Assuming the end user uses the electrical items for the use determined by the supplier.
 

Jeremy

Esteemed Pedelecer
Oct 25, 2007
1,010
3
Salisbury
Looking at the dates of the statutes quoted they mostly were brought in before the UK became part of the EU.
Since we became subject to EU law, that takes preference over UK law, I believe all electrical goods sold in the EU have to be marked with a CE approval badge.
Certainly my own Storck motor is so marked and having had a quick look at other electrical goods in my house they all seem to be marked as CE approved to whatever that particular standard is.
I think the law requires the importer of goods from outside the EU to ensure the goods comply with regulations not the end user. Assuming the end user uses the electrical items for the use determined by the supplier.
Yes and No. You're right, in general EU law does supersede UK law, but only after the parliament has passed the EU law into UK statute and rescinded the old UK statute. This has happened in some areas, but they haven't got around to doing it for ebike regulation. The UK law covering EAPCs is still on the Statute Book, and so is still applicable.

In fact, because the EU regulations have not been passed into UK law, a strict interpretation would be that they do not yet apply in the UK. This is superseded by the EU treaty that governs free trade, to which we are signatories, and which allows EU approved ebikes to be freely sold and used throughout the EU, including the UK, even though there is no specific UK law covering this.

With regard to responsibility for compliance, then for EU approved items that responsibility rests with the manufacturer or importer (if the goods are manufactured outside the EU). However, as the UK ebike statutes are still valid, the responsibility for compliance against their requirement rests with the manufacturer, which in the specific case of a pedal bike altered to become an EAPC is the person that does that alteration.

CE electrical safety marking is not required, as long as the ebike doesn't have a DC power source of greater than 75V and that no AC voltage within it is greater than 60V AC.
 
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Marctwo

Pedelecer
Dec 1, 2012
182
1
OK, I see where your coming from and where the misunderstanding is. The current and voltage going into the controller from the battery (which is the only reasonable place to make such a measurement) determines the input electrical power to the whole system, motor and controller. The law requires a definition of the mechanical output power from the motor only. The two are different, and highly load and temperature dependent.
The law requires the continuous rated output power. It doesn't specify how you get it, only the standard by which it's testing method is defined.

If I limit my motor to 200W and rate it accordingly, no test will find it to be illegal.

Even if I don't limit my motor but put 200W on the plate, it will only be illegal if it fails the test. If it passes the test then the rating I gave it will be found to be correct - even though it was a guess.

The whole point is that there is no legal requirement to test your motor. How you end up with a rating for your motor is up to you.
 

Jeremy

Esteemed Pedelecer
Oct 25, 2007
1,010
3
Salisbury
The law requires the continuous rated output power. It doesn't specify how you get it, only the standard by which it's testing method is defined.

If I limit my motor to 200W and rate it accordingly, no test will find it to be illegal.

Even if I don't limit my motor but put 200W on the plate, it will only be illegal if it fails the test. If it passes the test then the rating I gave it will be found to be correct - even though it was a guess.

The whole point is that there is no legal requirement to test your motor. How you end up with a rating for your motor is up to you.
Well, clearly there is a requirement to test the motor, as the law very clearly stipulates that you must rate it according to BS1727:1971, and that BS requires a test, so your last line is not true.

Certainly you could take the very conservative approach of limiting the motor electrical input power such that it never exceeded 200W. You could then be sure that the motor rated output power could never exceed 200W and therefore you would be compliant with the law.

The big downside of the latter approach is that the continuous output power that you would actually have from the motor would be a lot less than 200W, so performance would be much lower than is allowed.
 

Marctwo

Pedelecer
Dec 1, 2012
182
1
Well, clearly there is a requirement to test the motor, as the law very clearly stipulates that you must rate it according to BS1727:1971, and that BS requires a test, so your last line is not true.
I'll quote it again:
the continuous rated output (as defined in the 1971 British Standard) of the motor of the vehicle.
This doesn't mean it needs to be tested. Only that the method of determining this value is defined in the BS. This doesn't mean you have to use this method but this is the method that should be used to check for compliance.

Certainly you could take the very conservative approach of limiting the motor electrical input power such that it never exceeded 200W. You could then be sure that the motor rated output power could never exceed 200W and therefore you would be compliant with the law.

The big downside of the latter approach is that the continuous output power that you would actually have from the motor would be a lot less than 200W, so performance would be much lower than is allowed.
Why is it that when you spoke earlier about limiting power, you could have good results with 'blocking' and whatnot and still be legal. But when I mention it, it'll just be rubbish?
 

Jeremy

Esteemed Pedelecer
Oct 25, 2007
1,010
3
Salisbury
I'll quote it again:
This doesn't mean it needs to be tested. Only that the method of determining this value is defined in the BS. This doesn't mean you have to use this method but this is the method that should be used to check for compliance.
This is going to be my last response on this detail, because I strongly suspect that you're just trolling now.

The law says clearly that the continuous rated output power has to be as defined in the British Standard and must not exceed 200W. The British Standard says that the continuous rated power output has to be determined by a test method described within it. Therefore the law directly defines the need for the motor continuous rated power output to be defined by a test to the British Standard.

QED.

Why is it that when you spoke earlier about limiting power, you could have good results with 'blocking' and whatnot and still be legal. But when I mention it, it'll just be rubbish?
I earlier gave a valid method of setting the motor continuous rated power by setting the controller to deliver a set continuous maximum current, provided that you were able to determine what that current needed to be in order to obtain a maximum continuous rated power of not more than 200W (and as said before you can't determine that without testing the motor under a known load).

I also said that, because the test method within the British Standard is a long term continuous power test, you could include an initial acceleration over-current, and hence over power, capability within the controller as long as it was time limited. Some controllers have this facility and it can be programmed by using a PC and connecting to the manufacturers controller programming port. The feature is referred to as the "block time" on the Xiechang controller programming software, and allows up to 10 seconds of over-current operation to be set before the controller preset current limit kicks in to reduce power to the maximum continuous setting. This momentary over-power condition during acceleration would have no effect on the outcome of the British Standard power measurement, because it measures continuous rated power AFTER the motor rpm and temperature has stabilised, so AFTER the block time period would have expired and the controller would have cut back to the preset current limit.

I never once used the word "rubbish", either to you or anyone else.
 

Marctwo

Pedelecer
Dec 1, 2012
182
1
This is going to be my last response on this detail, because I strongly suspect that you're just trolling now.
That's a heck of a thing to say just because I don't agree with your interpretation of the law. I have remained on topic, have shown no disrespect at all.

The law says clearly that the continuous rated output power has to be as defined in the British Standard and must not exceed 200W.
Yes.

The British Standard says that the continuous rated power output has to be determined by a test method described within it.
That's only relevant when the motor has to be tested to the BS.

Therefore the law directly defines the need for the motor continuous rated power output to be defined by a test to the British Standard.
No. The law requires that the rated power complies with a test to the BS. It doesn't require that it be tested for compliance.
 

Old_Dave

Esteemed Pedelecer
Sep 15, 2012
1,211
2
Dumfries & Galloway
Once upon a time there was a stick that to be grasped from one special end..

After examining the stick very very carefully some peeps wot know about sticks managed to work out which of the ends was the one to grasp and shared the knowledge freely with any one who was curious.

Other peeps couldn't work it out for themselves, even when paint was put on the stick to mark the end to grasp they would argue that the paint should go on the other end.

Anyway... With all the carry on about which end of the stick, the stick fairy got fed up with it all and slung the stick over a cliff. The stick fairy then walked away muttering "see if you can follow that"


Sent from my iPhone using Tapatalk
 
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Marctwo

Pedelecer
Dec 1, 2012
182
1
Once upon a time there was a stick that to be grasped from one special end..

After examining the stick very very carefully some peeps wot know about sticks managed to work out which of the ends was the one to grasp and shared the knowledge freely with any one who was curious.

Other peeps couldn't work it out for themselves, even when paint was put on the stick to mark the end to grasp they would argue that the paint should go on the other end.

Anyway... With all the carry on about which end of the stick, the stick fairy got fed up with it all and slung the stick over a cliff. The stick fairy then walked away muttering "see if you can follow that"


Sent from my iPhone using Tapatalk
Well the people could only reach one end of the stick... And most of the people hadn't even seen the other end of the stick. The ministry for sticks was apparantly not concerned about where they grabbed the stick so long as they grabbed it properly. So, naturally, the people grabbed the stick at the only end they could and all was well.

One day, a stick expert came along and told the people that the other end of the stick was painted. The people panicked, thinking that the guarians of the stick would eat them alive.

A traveler thought it was a bit silly that the right end of the stick should be out of reach and he didn't like to see the people panicked. So he set of in search of the other end of the stick. He searched and searched and eventually he found the other end of the stick and it had indeed been painted by a stick expert. But the paint was thin and worn and the traveler could make out lettering under the paint which read:
You're quite welcome to grab this stick at the other end so long as you grab it properly.
The traveler thought the people should know what he found but most of the people just thought he was a nutter to disagree with a stick expert.