Legislation and e-bike conversions

[Pedaleg]

Newbie, first post, here goes:

My situation: retired, getting a motorhome soon to to travel around UK and Europe. Looking to buy a couple of folding electric assist bikes to throw in the boot. I've looked at and tried a lot of the available models but have come across the changing legislation and stories of heavy fines in Spain for e-bike riders who do not have certificates of conformance with European Directive EN15194.

Here's the thing, I'm attracted by some e-bike conversions (C H White @ Sons in Malmesbury do some brilliant looking kit conversions). However, I can't figure out how these would meet the EU requirements. The bike manufacturer cannot provide a certificate because they do not provide the electrical equipment and the retailer cannot provide a certificate because they are not the manufacturers of the bike or electrical equipment. I note also that e-bikes are required to have permanent labels showing compliance with the legislation. How does a kit conversion, particularly a home built one achieve this?

My options appear to be:

Buy a manual folder
Buy only a manufacturer's e-bike (I.e. Avoid conversions altogether)
Do not use in Spain (rolling the dice in the UK and other countries).
Go for it and risk the penalties (not an option for me)

Other issues:

Some conversion kits have full power throttles. Does disconnecting the throttle make them legal?

One conversion kit I've seen can be programmed to be more powerful than legislation allows but can be programmed to be compliant. How does the legislation cope with this?

Any thoughts from more experienced/knowledgable e-bikers would be appreciated.

(Apologies for any incorrect/imprecise terminology)

Thanks

 

[derf]

Newbie, first post, here goes:

My situation: retired, getting a motorhome soon to to travel around UK and Europe. Looking to buy a couple of folding electric assist bikes to throw in the boot. I've looked at and tried a lot of the available models but have come across the changing legislation and stories of heavy fines in Spain for e-bike riders who do not have certificates of conformance with European Directive EN15194.

Here's the thing, I'm attracted by some e-bike conversions (C H White @ Sons in Malmesbury do some brilliant looking kit conversions). However, I can't figure out how these would meet the EU requirements. The bike manufacturer cannot provide a certificate because they do not provide the electrical equipment and the retailer cannot provide a certificate because they are not the manufacturers of the bike or electrical equipment. I note also that e-bikes are required to have permanent labels showing compliance with the legislation. How does a kit conversion, particularly a home built one achieve this?

My options appear to be:

Buy a manual folder
Buy only a manufacturer's e-bike (I.e. Avoid conversions altogether)
Do not use in Spain (rolling the dice in the UK and other countries).
Go for it and risk the penalties (not an option for me)

Other issues:

Some conversion kits have full power throttles. Does disconnecting the throttle make them legal?

One conversion kit I've seen can be programmed to be more powerful than legislation allows but can be programmed to be compliant. How does the legislation cope with this?

Any thoughts from more experienced/knowledgable e-bikers would be appreciated.

(Apologies for any incorrect/imprecise terminology)

Thanks

FWIW I'd go fo it - the nano system wont support a bromptoin much beyond the legal limit (and certainly not beyond 17.8mph) so that's fine, it's had some reliability issues (rollers slipping), but I gather the internals can be cheaply swapped. if I had to start all over an assisted Brompton would cover many bases, except that a top speed of around 15mph might be restrictive for longer journeys

 

[Pedaleg]

FWIW I'd go fo it - the nano system wont support a bromptoin much beyond the legal limit (and certainly not beyond 17.8mph) so that's fine, it's had some reliability issues (rollers slipping), but I gather the internals can be cheaply swapped. if I had to start all over an assisted Brompton would cover many bases, except that a top speed of around 15mph might be restrictive for longer journeys

As leisure only users, 15mph is not an issue. I simply want to avoid my collar being felt for enjoying the benefits of an e-bike.

 

[trex]

what's wrong with ready made electric folders?

 

[flecc]

There is no official way to get approval for any home build/kit conversion e-bike. The tests laid down in EN15194 are only suitable for complete e-bikes so a certificate cannot be issued for a motor or kit.

In most EU countries it's sufficient for the conversion to meet with the legal usage requirements on declared power and speed, and one can add a label to conform to the requirements. But in the case of a country insisting on a EN15194 certificate, clearly kits etc are effectively banned.

When the new two and three wheeled type approval law comes into force from January 2016, having a kit e-bike approved as an L1e-A low powered moped might be a way round this EN15194 requirement, but it will bring some bureaucracy. How much depends on each country's requirements.
.

 

[Pedaleg]

what's wrong with ready made electric folders?

Nothing per se, but the conversions I've seen are smaller (folded) and lighter than most ready makes.

 

[Pedaleg]

Ready mades.....

 

[Pedaleg]

There is no official way to get approval for any home build/kit conversion e-bike. The tests laid down in EN15194 are only suitable for complete e-bikes so a certificate cannot be issued for a motor or kit.

In most EU countries it's sufficient for the conversion to meet with the legal usage requirements on declared power and speed, and one can add a label to conform to the requirements. But in the case of a country insisting on a EN15194 certificate, clearly kits etc are effectively banned.

When the new two and three wheeled type approval law comes into force from January 2016, having a kit e-bike approved as an L1e-A low powered moped might be a way round this EN15194 requirement, but it will bring some bureaucracy. How much depends on each country's requirements.
.

Would that mean that it could not be used on cycle paths, require a license etc?

 

[flecc]

Would that mean that it could not be used on cycle paths, require a license etc?

In most EU countries, yes as the law stands. Not in the UK though, since the DfT have said such an e-bike will still be regarded as an EAPC if it conforms to pedelec regulations in all respects other than the fully acting fitted throttle, which the type approval will permit.
.

 

[derf]

As leisure only users, 15mph is not an issue. I simply want to avoid my collar being felt for enjoying the benefits of an e-bike.

i may be wrong, but I think the chances of being collared by the police for humming sedately past on a nano Brompton is very, very, very, very slim (it's about the most opposite one can get from overpowered pedelec). I have had an ordinary Brompton for ten years and think you're right to imagine they're in a different league to other folding bikes.

 

[mike killay]

Exactly what do the Spanish Police expect you to produce?
I came across this when I Googled EN 15194,
As for marking:
a) the frame must be visibly and permanently marked with a serial number at a readily visible location;

b) the frame must be visibly and durably marked, with the name of the manufacturer or the manufacturer’s representative and the number of European Standard, i.e. EN 14764;

c) the vehicle must be durably marked with the following words: EPAC according to En 15194;

d) xx km/h, i.e. cut off speed;

e) xx W, i.e. electric motor maximum continuous rated power.

Would this do, or do they want paperwork?

 

[Pedaleg]

Exactly what do the Spanish Police expect you to produce?
I came across this when I Googled EN 15194,
As for marking:
a) the frame must be visibly and permanently marked with a serial number at a readily visible location;

b) the frame must be visibly and durably marked, with the name of the manufacturer or the manufacturer’s representative and the number of European Standard, i.e. EN 14764;

c) the vehicle must be durably marked with the following words: EPAC according to En 15194;

d) xx km/h, i.e. cut off speed;

e) xx W, i.e. electric motor maximum continuous rated power.

Would this do, or do they want paperwork?

I've read on other forums that Spanish police have insisted on riders having a certificate and one retailer told me that he had been inundated recently by Spanish based customers of his asking for retrospective manufacturers' certificates.

 

[Pedaleg]

i may be wrong, but I think the chances of being collared by the police for humming sedately past on a nano Brompton is very, very, very, very slim (it's about the most opposite one can get from overpowered pedelec). I have had an ordinary Brompton for ten years and think you're right to imagine they're in a different league to other folding bikes.

Does this mean I ride a manual bike but hum an e-bike?

 

[trex]

Nothing per se, but the conversions I've seen are smaller (folded) and lighter than most ready makes.

Smaller than this Woosh Gallego?
http://wooshbikes.co.uk/?gallego

 

[anotherkiwi]

Lucky me I am in the Basque Country not in Spain. I bought a "road legal" Spanish kit so I will just tell the Ertzaintza to contact the Spanish company in the extremely unlikely case that I get pulled over. I ride on the other side of the frontier at least twice a week and have never seen a policeman.

Today they pulled me over in my girlfriends car and checked that me and my sister had our seatbelts on correctly...