Just picked up on this thread. The whole legal / illegal issue is not a problem until it is! Say you are on your illegal ebike and involved in an accident which proves to have been your fault, victim is maimed for life and awarded substantial damages - which could run to millions. Your bike is illegal so the insurance is invalid so you lose you home and any other assets and become bankrupt. This is the reality, although an extreme example, of life - why muck around???

Me - I am happy to trundle around at an average 12mph on a legal bike and enjoy the scenery!

I recon this is what Neptune has in mind ....

 

[ATTACH]4470[/ATTACH]

 

 

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Hehe imagine what riding that!..the film Easier Rider springs to mine! It would be fun to build an electric bike that resembles one of those choppers =)

Incidentally, my order was opened and inspected by Border Agency! It had a big sign on it saying "Home Office Border Agency inspected". Heh. First time I've ever had anything checked by Customs. So now they know I have an illegal motor and my address *hides*

 

Hi Morphix,

 

The reason your package was inspected would have been for the following reason as stated on their website,

"The UK Border Agency is responsible for ensuring that they are free from illegal items such as drugs and firearms, and that the correct tax and/or duty is paid on them."

They are unlikely to have checked the legality of the motor, they were probably more interested in the value of the goods.

 

Don't be surprised if you get a bill from the parcel delivery company for VAT and import duty, as they collect it on behalf of HMRC.

 

Our airfreight imports normally come by TNT and we get a bill from them a couple of weeks after delivery.

 

We had a shipment of bespoke kits earlier this year destined for a trade customer who wanted them in a hurry, so they came by FedEx airfreight and went straight to the customer.

 

I got the invoice from FedEx for 6% import duty and 20% VAT as expected, however the shipper had incorrectly described the goods and the wrong commodity code was applied, HMRC subsequently added Anti Dumping Duty of 48.5%

 

It has taken months to sort this one out.

 

On another container shipment, which was X-rayed by HMRC, the freight handling company stuck the decimal point one number to the right, on the invoice and we got a bill for 10 times the amount it should have been, when I pointed this error out to company they thought it was highly amusing:eek:

 

It just shows that you have to be very careful with documentation and check everything twice.

Just picked up on this thread. The whole legal / illegal issue is not a problem until it is! Say you are on your illegal ebike and involved in an accident which proves to have been your fault, victim is maimed for life and awarded substantial damages - which could run to millions. Your bike is illegal so the insurance is invalid so you lose you home and any other assets and become bankrupt. This is the reality, although an extreme example, of life - why muck around???

Me - I am happy to trundle around at an average 12mph on a legal bike and enjoy the scenery!

 

Ya hopefully as flecc said the controller will limit that motor down to 250W...and if it's too "lively" I can always use my speedict to cap it anyway and keep things safe.. I certainly wouldn't intentionally break the law or put others in danger.. I'm just a bit disappointed BMS sold me 350W when I asked for 250W.. I think others should watch out for this..but maybe the 250W controller will sort it.. I will report back in due course anyway once Catsnapper has done my wheel.

Hi Morphix,

 

The reason your package was inspected would have been for the following reason as stated on their website,

"The UK Border Agency is responsible for ensuring that they are free from illegal items such as drugs and firearms, and that the correct tax and/or duty is paid on them."

They are unlikely to have checked the legality of the motor, they were probably more interested in the value of the goods.

 

Don't be surprised if you get a bill from the parcel delivery company for VAT and import duty, as they collect it on behalf of HMRC.

 

Our airfreight imports normally come by TNT and we get a bill from them a couple of weeks after delivery.

 

We had a shipment of bespoke kits earlier this year destined for a trade customer who wanted them in a hurry, so they came by FedEx airfreight and went straight to the customer.

 

I got the invoice from FedEx for 6% import duty and 20% VAT as expected, however the shipper had incorrectly described the goods and the wrong commodity code was applied, HMRC subsequently added Anti Dumping Duty of 48.5%

 

It has taken months to sort this one out.

 

On another container shipment, which was X-rayed by HMRC, the freight handling company stuck the decimal point one number to the right, on the invoice and we got a bill for 10 times the amount it should have been, when I pointed this error out to company they thought it was highly amusing:eek:

 

It just shows that you have to be very careful with documentation and check everything twice.

 

Oh I'm well familiar with the routine I import regular for my business, but it's very rare for anything to be inspected, for me anyway. Normally they trust couriers to do it and put the items on the system for VAT+Duty collection.

 

Heh I know what you mean about the mistakes.. I used to use TNT for all my airfreight (they're a f'kin nightmare of a company to deal with, I swear they just make up numbers and quotes). They've consistently overcharged me on freight, VAT and duty on numerous occasions and subsequently had to credit me back. I also stopped their £15 a time "deferral fee" racket by informing them I wanted to pay HMRC directly (which is every consumers and businesses right). I don't deal with TNT anymore or use airfreight.. I just sea freight its much cheaper and easier for me to consolidate all my shipments to one location by road freight and buy container space on ships.

Edited November 22, 201213 yr by morphix

They are unlikely to have checked the legality of the motor, they were probably more interested in the value of the goods.

 

The thing is though, posession of a 350w motor, or a 500w motor or even a 5000w motor isn't illegal.

Ya hopefully as flecc said the controller will limit that motor down to 250W...and if it's too "lively" I can always use my speedict to cap it anyway and keep things safe.. I certainly wouldn't intentionally break the law or put others in danger.. I'm just a bit disappointed BMS sold me 350W when I asked for 250W.. I think others should watch out for this..but maybe the 250W controller will sort it.. I will report back in due course anyway once Catsnapper has done my wheel.

There's only one power version of the Q100. They either say "250w - 350w" or "350w" on the label, so they didn't send you the wrong one. As has been said many times before, the label on the motor has no sensible meaning.

There's only one power version of the Q100. They either say "250w - 350w" or "350w" on the label, so they didn't send you the wrong one. As has been said many times before, the label on the motor has no sensible meaning.

 

Which is the power rating then eh? It can't be both 250W and 350W..why are they quoting a range on their website? I've seen sellers offering 250W OR 350W but never one motor that does both.

The thing is though, posession of a 350w motor, or a 500w motor or even a 5000w motor isn't illegal.

 

Exactly. This is my concern. People are placing an order in good faith expecting to get kit which is UK road legal, and it appears that's not what is being sent. Of course, you can remove the sticker etc, and use a 250W controller.. but if you did get pulled by the cops for any reason and they discovered it's a 350W motor you could be screwed?

It's all to do with continuous output of the complete bike, if the output is limited by the controller then it's no matter what the motor 'could' be capable of under a different configuration.

 

I think, lol

 

 

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It's all to do with continuous output of the complete bike, if the output is limited by the controller then it's no matter what the motor 'could' be capable of under a different configuration.

 

I think, lol

 

 

Sent from my iPhone using Tapatalk

 

That makes total sense to me. It's basically having an assistance restrictor in place and provided that this configuration is in place at the relevant time the bike is in use on the road, can't see how the bike could be successfully argued to be illegal on challenge if continuous output is 250W or less.

That makes total sense to me. It's basically having an assistance restrictor in place and provided that this configuration is in place at the relevant time the bike is in use on the road, can't see how the bike could be successfully argued to be illegal on challenge if continuous output is 250W or less.

 

Yeah I guess so, unless the controller in question is higher power than the BMS Battery let on.. this is the thing really, because the industry is unregulated and you're dealing with companies in China... how can consumers really be responsible eh. Unless we do what the law asks and present our bikes for testing to that DfT place. We only have the word of the manufacturers in China our kit is legal unless you have the technology and means to test it yourself at home.

 

Do UK-based e-bike manufacturers like Whisper get their bikes approved/checked in UK? Is there some argument then here, that going down the self-build route is more risky and/or places a burden of responsibility to establish legality and road safety on us?

Edited November 23, 201213 yr by morphix

In God and the devine rating plate we trust

 

 

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Do UK-based e-bike manufacturers like Whisper get their bikes approved/checked in UK? Is there some argument then here, that going down the self-build route is more risky and/or places a burden of responsibility to establish legality and road safety on us?

 

They use EU approved labs to test the bikes for EN15194 compliance. Self build is inherently legally more risky, but unlikely to cause problems if the self build complies with the law.

They use EU approved labs to test the bikes for EN15194 compliance. Self build is inherently legally more risky, but unlikely to cause problems if the self build complies with the law.

 

My Mezzo has an ENxxxx sticker on it Presume that means it's passed all the UK safety standards and quality assurance levels. Having a proper branded serial numbered bike makes it a lot easier on my insurance, but I'm not sure where I stand with regards to the electric side of it and if that is covered..I need to give L&G a ring and find out next week..I expect they will say only bike is covered..nothing aftersale addon.

The thing is though, posession of a 350w motor, or a 500w motor or even a 5000w motor isn't illegal.

 

Hi Amigafan,

 

That's kind of what I meant and agree electric motors are not illegal;)

They use EU approved labs to test the bikes for EN15194 compliance. Self build is inherently legally more risky, but unlikely to cause problems if the self build complies with the law.

 

My understanding is that EN15194 requires that the motor must be rated at no more than 250w by the manufacturer, so as long as the manufacturer provides a letter or certificate to this effect, there's no need to test. The only thing to test regarding performance would be the 25kph speed.

Exactly!

 

 

 

.

I don't think I've read a thread with more confusion over the legal aspects of UK ebikes.

 

If you want a 250W ebike then it has to comply with the EU standard, EN 15194:2009, and be certified against it with some form of Type Approveal issued by an EU state.

 

The exact wording of the power definition and maximum assisted speed from EN15194:2009 is:

 

" electrically power assisted cycles of a maximum continuous nominal power

of 0,25 kW, whose power is gradually reduced and finally stopped when the vehicle reaches

a speed of 25 km/h, or sooner, if the cyclist stops pedalling "

 

Note that EN15194, unlike the UK EAPC regulations (SI 1168, 1983) does NOT make it clear as to whether the power is the electrical power input, or the mechanical output power, nor does EN15194 make mention as to where the power should be measured (at the motor shaft, gear output shaft, bicycle tyre etc). The only clarification on power is the manufacturer (of the ebike, NOT the motor) making a statement as to what they consider to be the continuous rated power in these terms (note that I have emphasised "specified"):

" continuous rated power

continuous (or constant) output power specified by manufacturer, at which the motor reaches its thermal equilibrium at given ambient conditions

 

NOTE Thermal equilibrium: temperatures of motor parts do not vary more than 2K per hour. "

 

If you are the manufacturer of the ebike, you can (in fact must) specify what you consider to be the continuous output power. You may well choose to use a motor rated at a very much higher power and under-rate it for reliability, which is perfectly acceptable.

 

Given that at least one Acceptable Means of Compliance is the simple acceleration test:

" Maximum power measurement - Alternative method

D.1 Generalities

This Annex gives guidance on how to measure the power at the wheel.

The maximum power which the bicycle gives assistance may differ by ± 5% of the power indicated on the label described in Clause 5. During a production conformity check, the maximum speed may differ by ± 10% from the above-mentioned determined value. The test shall be performed without pedalling using only the electrical assistance system (the test bicycle shall be prepared accordingly).

 

D.2 Test conditions

a) The test may be performed either on a test track, a test bench or on a stand that keeps the motor driven wheel free of the ground.

b) The speed-measuring device should have the following characteristics:

- Accuracy: ± 2%

- Resolution: 0,1 km/h

c) The ambient temperature should be between 5 °C and 35 °C.

d) Maximum wind speed: 3 m/s.

e) The battery should be fully charged according to the manufacturer's instructions.

f) The test should be performed with mass of the test bicycle equal to 150 kg.

 

D.3 Test procedure

Any appropriate method for checking for this requirement is acceptable.

a) Pre-condition the EPAC by running it for 5 min at 80% of the maximum assistance speed as declared by the manufacturer.

b) Stop the bicycle.

c) Note the time between the action start and the EPAC to travel 20 meters.

d) Verify the speed value is equal or less than the maximum speed declared by the manufacturer after 20 metres (D).

e) Verify the maximum continuous rated power at wheel is: P = m x 2D²/T³ with the time T which is the noted value in c).

 

NOTE Considering that on a test track, the engine temperature is not stable, and the grip of the tyre on the road can be variable, the result of the measurement should be decreased by 1,10 to consider the measurement uncertainty. The measure is compared to the limit given in the scope of this European Standard. "

 

and as this does not measure power at the motor, motor shaft, electrical input power etc, but derives average power over a very short test run, then we can say with certainty that EN15194 does accept a form of output power measurement in terms of motive power delivered, rather than any other form of power measurement or rating provided by any manufacturer of any component.

 

In simple terms, unlike the UK EAPC regulations, EN15194 has, in effect, removed the absolute requirement for the motor to meet the 0.25kW stated limit, by allowing an Acceptable Means of Compliance that can be met with a motor of a much greater power. In pure legal terms, there is a perfect defence to a claim that your motor exceeds the 0.25kW limit IF you can show that your ebike meets EN15194 by means of passing the acceleration test. In practice, an ebike of more than double the legal power can pass this test, by the simple expedient of adjusting the throttle/pedelec response time.

 

As flecc has rightly said, many (I suspect most) "legal" ebikes deliver far more than 250W, with many delivering perhaps 2 or 3 times that power. For example, a 500W ebike can be perfectly legal as long as it passes the EN15194 acceleration test, only provides electrical assistance when the pedals are rotating, ceases to provide electrical assistance at speeds above 25 km/h and complies with the relevant aspects of the EMC Directive and also perhaps the Low Voltage Directive (only if any voltage within the ebike systems exceeds 60V DC).

 

When it comes to home made ebikes then things are less clear. You can choose to get your ebike certified and Type Approved against EN15194:2009, but as someone who used to be a head of Type Approval for UK electronic equipment I can tell you that this is a very expensive path to follow! The only other way to legally build an ebike here in the UK is to choose to show compliance with the UK specific EAPC regulations under SI 1168, 1983. You can do this by getting the Vehicle Inspectorate to agree that your ebike is compliant. Unlike EN15194 there are no agreed Acceptable Means of Compliance for SI 1168, so you are on your own when it comes to providing acceptable test evidence to the Vehicle Inspectorate. I doubt that anyone has ever done it, TBH, and this technically makes every DIY ebike in the UK illegal simply because they don't have any paperwork or verified rating plate to show they are legal.

 

If you do want to be legal under the UK EAPC regulations, then in terms of power you have to prove that the " continuous rated output of the motor must not exceed 200 watts ". Note very carefully that this is specific, it is the mechanical power output of the motor, not the electrical power input and not the power after any gear reduction system there may be. For example, if you had a geared hub motor, then you would have to take the hub apart and use a dynamometer to test the motor power output and ensure that it did not exceed 200W continuous (note: it is still perfectly acceptable for the motor to deliver hundreds of watts more than this for short periods!).

 

Hopefully this might put to rest all the BS about "legal" and "illegal" ebikes based on misquoted and misunderstood (in the main) comments about power that dominates this forum, and get some of the holier than thou types to stop and think, especially if they ride an ebike that has neither an EN 15194:2009 Type Approval Certificate or a Vehicle Inspectorate approved rating plate, making them illegal irrespective of the motor power......................

Edited November 23, 201213 yr by Jeremy

Just to make it clear, Jeremy is also a regular contributor on the Endless Sphere site and assists on all things technical on overpowering systems.

deleted due to double post.

Edited November 23, 201213 yr by neptune

Referring to section D.2 test conditions. In subsection a we are told that the bike can be tested on a test track, on a bench or test stand.Then, in sub section d we are told that the wind speed must not exceed 3 metres/second. Why? What possible effect could the wind have if the bike is tested on the stand or bench?

I suggest that sub section d be re written to read as follows.

 

WARNING. It is of the utmost, vital importance that the wind speed does not exceed 3 metres/second.

 

If it does, it doesn`t matter.

Edited November 23, 201213 yr by neptune

Jeremy, I'm not sure that your last paragraph is correct. Just because your bike hasn't been certified. doesn't automatically make it illegal. It would have to be tested to prove that it's illegal, and, as you rightly pointed out, the criteria are not very clear.

 

When a manufacturer rates a motor power, it's normally a minimum rating. They test and certify that the motor will be able to run at that rating without problems. It could actually run continuously at a much higher power. EN15194 allows for this by including the word "nominal", which means that the manufacturer can call the rating whatever they want below its actual maximum rating. The acceleration test can be chosen as a way of confirming compliance in the absence of other data. It isn't mandatory, and any bike would pass the test with the soft-start throttle algorithms that sensible people use on their higher powered bikes.

 

It's almost impossible to tie down an electric vehicle's power because it's too easy to change the current to the motor. You'd need to specify/test the motor at a fixed voltage, temperature and current, and then put a cap on the maximum current allowed, which is also very difficult to measure because it changes continuously through three phases. You could put a cap on battery current and voltage, but that would be unfair on the different manufacturers systems.

 

Finally, if you have a Q100 powered bike, and you wanted to prove that it wasn't over-powered, you would only need to get a chartered engineer to compare it's power to a BH Emotion Neo, which has certified compliance, and get a letter from him that the Neo has substantially more power in any sort of test, and that should be compelling evidence.

Just to make it clear, Jeremy is also a regular contributor on the Endless Sphere site and assists on all things technical on overpowering systems.

 

Also that d8veh and Jeremy have had several differences of opions on that other site.

Some interesting contributions on the legal side of things

 

So in a nutshell, it's ok to have a motor that is higher power than 250W fitted on a bike, if you declare its "nominal" power output to be 250W or less (the power at runs at most of the time under normal conditions)... and, it's actually the controller which determines that? So basically, your controller is what makes the bike comply with the legal guidelines given on speed and continuous output?

 

Obviously a motor under heavy load or stress may draw MORE power than 250W, for example when climbing a hill..but that doesn't make the bike illegal. There is a balance between a legal AND functional bike eh.. and common sense would seem to apply.

 

Perhaps in lay man's terms you can compare it to rating a washing machine, it runs at a normal spin speed and power output most of the time and so you say its power rating is X but when its doing a short faster spin cycle (to rinse out water) it can dramatically increase power usage and output...but that doesn't mean you rate it at the higher power output on the manufacturing spec, you use the nominal output figure.

Edited November 23, 201213 yr by morphix