If I was stopped for doing 85mph on a 70mph motorway but my speedo was reading 69mph I don't think I'd have much of a case.

 

Or another example, if somebody changes diff ratios or tyre sizes on their car their speedo will read incorrectly but it's still their responsibility to make sure that they don't exceed speed limits.

activating a dongle is the same as twisting the spoke magnet until it starts reading wrongly, except that the dongle has a set error percentage of 50%.

If you have a wrong speedo, it's like after you activated the dongle. If you don't activate your dongle, you are not speeding.

The situation is similar to someone going to a demonstration with a flag pole, it's legal until you poke the pole into somebody's face.

Edited May 22, 20196 yr by Woosh

activating a dongle is the same as twisting the spoke magnet until it starts reading wrongly, except that the dongle has a set error percentage of 50%.

If you have a wrong speedo, it's like after you activated the dongle. If you don't activate your dongle, you are not speeding.

The situation is similar to someone going to a demonstration with a flag pole, it's legal until you poke the pole into somebody's face.

You've missed my point entirely and what a flag pole has to do with ebikes is beyond me.

Just tell us the secret way to change speed limit on the bosch's, the secret will be safe on here.

The last time I told someone on the forum how to derestrict his bike, I told him that I would have to kill him if he let the secret out. Unfortunately he let it out, may he rest in peace. I can tell you the secret but I'd have to kill you first because I can't run the risk of this one getting out. All the guys that make dongles would have their lives and jobs put at risk. Think of their children.

problem is what software version did the bike have and what display and if nothing else is required to remove the speed limit bosch would soon patch it so would no longer work.

 

you can either prove it and let others try it or you cant simple as that.

If I was stopped for doing 85mph on a 70mph motorway but my speedo was reading 69mph I don't think I'd have much of a case.

Your point is valid as far as breaking the speed limit is concerned. When the police check the speed of cars, they use an independent device, like their own calibrated speedometer, VASCAR, Radar gun or whatever. They would use that evidence in a prosecution and wouldn't even be interested to see what speed your speedometer displays. None of those devices are going to prove non-compliance on an electric bike when the rider is pedalling and he's adjusted the speedometer ratio, like OP has. They can get the speed, but how will they know if the motor was running or not? They'd have to ride the bike themselves while observing the speed displayed on the bike and compare that with an independent device. That's just not going to happen. All they can really do is a static test to see that the power cuts off when the display shows 25 km/h, but I doubt that they'd even do that.

 

Of course, there might be a policeman that happens to be an electric bike hobbyist, who reads the forum and knows everything that we do. I can spot a derestricted bike a mile off, but how many policemen have this capability?

You really are a chump,

OK , so now you've resorted to name calling. I can see the model of debate you're using, which follows this diagram exactly. We can see the next step. I think you've been on the Brexit thread too long, where people spout this sort of rubbish at each other all day long as if it's going to change the world.

I am not sure about this, as it has never been tested in a Court case.

Let's say I make a bike that will still work if the spoke magnet is twisted away.

Is it illegal? As far as I know, EN15194 testing has never mentioned a spoke magnet test that it cannot be removed nor twisted away.

So the spoke magnet is your on/off speed limit button.

There must be at least 10+ million EPACS in use, lots of them use a similar spoke magnet to measure the speed.

 

A magnet moved away from the designed and supplied condition is a modification, no matter what the cause. It's not a "button" available to the rider as supplied.

 

Therefore it is legal to ride the bike with the magnet in the correct position.

 

The paragraph below part copied from my post above defines the status for all pedelecs, the requirement for throttle type approval proving my case beyond any doubt:

 

"There is a direct comparison with the throttle issue. The type approval exemption does not allow the possibility of motor power without pedalling, so defeating that with a throttle loses the pedelec exemption. Ergo, if the bike is supplied with a rider control throttle already fitted, even if not used, it is not an exempt pedelec, hence it needing type approval. Equally if fitted with rider control capable of raising the assist limit to defeat that exemption condition, it loses pedelec exemption, whether used or not. "

.

Edited May 22, 20196 yr by flecc

OK , so now you've resorted to name calling. I can see the model of debate you're using, which follows this model exactly. We can see the next step. I think you've been on the Brexit thread too long, where people spout this sort of rubbish at each other all day long as if it's going to change the world.

[ATTACH=full]30541[/ATTACH]

 

None of the above, my case is proven by the post you complain of, but you just wanted to ignore that.

 

See the last paragraph of this post

.

"There is a direct comparison with the throttle issue. The type approval exemption does not allow the possibility of motor power without pedalling, so defeating that with a throttle loses the pedelec exemption. Ergo, if the bike is supplied with a rider control throttle already fitted, even if not used, it is not an exempt pedelec, hence it needing type approval. Equally if fitted with rider control capable of raising the assist limit to defeat that exemption condition, it loses pedelec exemption, whether used or not. "

as vfr pointed out, that's your interpretation though.

Extrapolating from your posts, any bike that can be unlocked is illegal.

One could argue that installing a software update involves unlocking the LCD, so any bike with LCD that can be unlocked or have its software updated is potentially illegal.

I checked and rechecked regularly the EU's own publications, including the link I gave in a previous post in this thread, which I thought is the clearest explanation of what the rules are, what tests the bike must pass, what labels must be on the bike and what additional information must be in the user manual.

 

There are many bikes with dual settings sold all over Europe. The GreyP is an example in point.

As far as I can see, locking the LCD with a password is what many suppliers do. Component-wise, it's the same bike as one supplied unlocked or one that was previously locked now unlocked.

Find me a bike that cannot be unlocked then I will be convinced.

Edited May 22, 20196 yr by Woosh

Gtech

BionX

Actually he threw it at the van not at Tommy Robinson.

problem is they can set the laws but if the police will not enforce it because you have to remember will it be in the public interest to prosecute and if the cps thinks there is any chance they will not win the case it will be dropped and no action taken bar say a caution or small fine.

 

and as 1 of the biggest haibike dealers in the uk sell and fit dongles and honors the warranty he sure as hell dont give a dam lol.

as vfr pointed out, that's your interpretation though.

 

Not so, it is demonstrably the DfT's interpretation as their ruling on throttles shows. If a pedelec as supplied can defeat any of the three basic conditions for type approval exemption by the use of the supplied rider controls, it is technically not legal to use it. That is why the throttle defeat, whether used or not, removes the exemption. The same applies to as supplied rider available assist speed alteration controls.

 

Extrapolating from your posts, any bike that can be unlocked is illegal.

One could argue that installing a software update involves unlocking the LCD, so any bike with LCD that can be unlocked or have its software updated is potentially illegal.

 

Not if modification is involved. Unlocking the LCD is a modification of the bike as supplied, so the bike remains a pedelec if that isn't done to change the legal conditions. Software updates from the manufacturer conforming to the type approval requirements are of course legal, since the rider cannot use them to alter the exemption conditions and the bike remains compliant.

 

There are many bikes with dual settings sold all over Europe. The GreyP is an example in point.

 

There are many illegal e-bikes sold throughout Europe, and have been since 1999 at least. That it happens doesn't constitute legality of course.

 

As far as I can see, locking the LCD with a password is what many suppliers do. Component-wise, it's the same bike as one supplied unlocked or one that was previously locked now unlocked.

 

It's not just about components, the type approval regulations concern the bike as supplied. If access to the controls to alter the speed is locked from the rider by the supplier using a password, it is compliant. If the rider subsequently finds and uses the password to unlock that to give access to control illegality, the bike as supplied has been modified and loses the exemption. If the rider is able to relock it to supplied condition and hasn't introduce an illegal condition, the bike returns to compliance.

.

Edited May 22, 20196 yr by flecc

problem is they can set the laws but if the police will not enforce it because you have to remember will it be in the public interest to prosecute and if the cps thinks there is any chance they will not win the case it will be dropped and no action taken bar say a caution or small fine.

 

and as 1 of the biggest haibike dealers in the uk sell and fit dongles and honors the warranty he sure as hell dont give a dam lol.

 

Agreed, and as I've often made clear, I don't care what others do to their pedelecs, it's none of my business.

 

And I'm not too bothered by what conditions the legislators set, it's their business not mine.

 

But as a matter of principle everyone should know what the law is and what it's intended to do. In that context all the ducking and diving in efforts to convince the law isn't what it is and convince that law defeat controls are legal are not acceptable since they only confuse.

 

The DfT ruling on having a fitted throttle that can defeat a pedelec exemption condition was definitive. It clearly applies to any rider control available without modification that can defeat either of the other two fundamental exemption conditions.

 

Such machines are technically not compliant pedelecs.

.

https://autovistagroup.com/news-and-insights/bosch-fights-further-diesel-manipulation-allegations-germany-and-us

 

pmsl

Not if modification is involved. Unlocking the LCD is a modification of the bike as supplied, so the bike remains a pedelec if that isn't done to change the legal conditions. Software updates from the manufacturer conforming to the type approval requirements are of course legal, since the rider cannot use them to alter the exemption conditions and the bike remains compliant.

OK, let's look at this argument further.

Lets say that the password for Bafang LCD is 0512. You navigate through the on screen menu, the LCD asks you for the password. You enter the password, you are in the setting screen.

On the Tongsheng LCD, you have 10 seconds after power up to hold down two buttons for 3 seconds then press the i button 4 times to get to the same settings screen.

What's the fundamental difference? Why one is legal (Bafang) and the other not?

The same way works with other LCDs, your software connects to the UART and sends the password to get to the settings menu.

It's just the degree of complexity of the password.

Once cracked, the user can change the password or remove it altogether.

My point is, the act of changing the settings breaks the law, not the complexity of the sequence of key presses.

Edited May 22, 20196 yr by Woosh

Find me a bike that cannot be unlocked then I will be convinced.

A current Bosch equipped ebike.

A current Bosch equipped ebike.

this thread shows you a simple method to derestrict it.

there is no fundamental difference because of the methods, between a modification by software or hardware.

If Bosch were threatened with heavy fines for not making tampering impossible, they'd put a 3-axis or 6-axis gyro chip inside the controller.

this thread shows you a simple method to derestrict it.

there is no fundamental difference because of the methods, between a modification by software or hardware.

If Bosch were threatened with heavy fines for not making tampering impossible, they'd put a 3-axis or 6-axis gyro chip inside the controller.

I must have missed the simple method to derestrict Bosch bikes, what is it?

 

VFR said he'd seen a Bosch bike that somebody said was derestricted but he doesn't know what's involved. I suspect 3rd party hardware hidden behind the motor case, these are readily available from Germany.

Lets say that the password for Bafang LCD is 0512.

 

My point is, the act of changing the settings breaks the law, not the complexity of the sequence of key presses.

 

The password is the difference, it is an addition to the machine to get access to possible illegality and therefore a modification. So without the password the bike complies. It baffles me why you are not understanding this difference.

 

Of course changing the settings break the law, but what has the complexity to do with anything. The question is only whether the change is available to the rider without a modification. Sequences of button presses are irrelevant , even cheap cycle computers have those, showing that they are rider controls.

 

Illegality is the norm in this business, the great majority of all supposed pedelecs supplied since 1999 in this country alone have been illegal as supplied. As someone in this business you surely know that.

 

From 1999 it was the illegal 250 watts rating. Then from November 2003 not having to pedal to get power was added to that illegality. As those two were being corrected between 2013 and 2015, a new ruling on Off Road buttons confirmed another post 2003 illegality for many machines as I've been showing.

 

And now, not for the first time, the DfT itself is extensively breaking the law in respect of its ruling on having throttles. They attempt to circumvent the law with SVA to L1e-A, but say they will consider the bikes are still EAPCs without bureaucracy.

 

But the law says that is absolutely not true, the throttle equipped L1e-A bikes as motor vehicles should be registered, number plated and third party insured and the rider should wear a m/c approved helmet. So it's turning a blind eye, but still illegal and why they cannot be used legally beyond that blind eye across the channel.

 

These are all technical breaches which will never trouble anyone, but they have all existed and some still do.

.

The password is the difference, it is an addition to the machine to get access to possible illegality and therefore a modification. So without the password the bike complies. It baffles me why you are not understanding this difference.

the password is difficult to crack without inside knowledge (eg from support people), same with the special key sequences. There is an easy defeat: buy a new LCD, the password comes with the LCD.

Your argument passes a blanket of blame on suppliers who do not try harder to stop people messing with speed reading or changing the speed limiter. My point is, there is no law to say that you have to stop customers messing up their bike. I made it quite clear on my website: don't change the settings, your warranty will be voided if you do. Don't take me wrong, I am at the opposite end of vfr on derestriction.

if the law is clear cut on this, suppliers would have fitted gyro or GPS chip to their controllers.

There is an easy defeat: buy a new LCD, the password comes with the LCD.

 

Which of course breaches the exemption.

 

I'm not trying to place any blame onto suppliers, just observing the technical breaches of pedelec law that have long existed and still do.

 

This all started with my correctly answering someone's academic question, an answer which the DfT's definition I've quoted confirms was correct.

 

There was no necessity for it to have been challenged nor any grounds for that to happen, as the total absence of any posted opposing legal evidence from my challenger shows.

 

Both the fact and the spirit of the law are absolutely clear and why you are able to definitively support that legality in your customer guidance.

.

I'm not trying to place any blame onto suppliers, just observing the technical breaches of pedelec law that have long existed and still do.

but yes you do. If a supplier forces those who want to derestrict their bike to buy a dongle then that's alright. If customers can derestrict their bikes without buying a dongle then it's that supplier's fault.

about technical breaches:

 

if the specifications of EN15194 include measures to stop tampering with the speed measurement, the dongles will disappear.

 

There is a white paper at present, but not yet approved by the Commission.

 

RVFSR – Annex XVIII Maximum continuous rated and/or vehicle speed limitation by design L1e-A & B Specific anti-tampering requirements for electric motors in the Regulation

 

RVFSR – Annex XIX Vehicle structure integrity L1e-A & B Requirements in the Regulation + vehicles L1e-A and cycles designed to pedal in L1e-B must conform with ISO 4210:2014. Definition of cycles designed to pedal in Annex XIX: pedelecs up to 45 km/h + factor 4

 

 

D. TYPE-APPROVAL FACTOR FOUR L1e-A “powered cycles” are defined as cycles designed to pedal, equipped with an auxiliary propulsion with the primary aim to aid pedalling. The propulsion should be limited to a speed of 25 km/h and its maximum continuous rated power should not exceed 1000 W. L1e-A includes two-, three- and four-wheel vehicles, i.e. also electric cargo bikes with more than two wheels. L1e-B “mopeds” are defined as vehicles with a maximum design speed of more than 25 km/h and up to 45 km/h with a maximum continuous rated power of 4000 W. This category only includes two-wheel vehicles. Following this categorisation, a pedelec 25 km/h with 750 W for instance will come under L1e-A, an e-bike 25 km/h with 500W as well, whilst a pedelec 45 km/h with 1000 W will come under L1e-B. A vehicle that combines pedal assistance with open throttle up to maximum 25 km/h will come under L1e-A. Electric cycles with a speed limit above 25 km/h and with three wheels belong to category L2e – “three-wheel moped”, whilst vehicles with four wheels belong to category L6e – “light quadricycle”. But since the requirements in these categories have not been adapted to electric cycles, it is virtually impossible for these electric cycles with three or four wheels to pass type-approval. As for pedelecs 45 km/h, manufacturers may decide to limit their vehicles with the so-called “factor four”. This means that the auxiliary propulsion power added to the driver’s pedal power is less than or equal to four times the actual pedal power. In that case, their vehicles become so-called “cycles designed to pedal of vehicle category L1e-B”. In the Regulation on Vehicle Functional Safety Requirements these are defined as: “cycles with a mass in running order ≤ 35 kg and shall be fitted with pedals enabling the vehicle to be propelled solely by the rider’s muscular leg power. The vehicle shall feature adjustable rider positioning in order to enhance the ergonomic posture of the rider for pedalling. The auxiliary propulsion power shall be added to the driver’s pedal power and shall be less than or equal to four times the actual pedal power.” These “cycles designed to pedal” are not a separate type-approval category. Type-approval legislation does not hold a legal obligation to comply with factor four, it only holds a legal obligation to test the auxiliary propulsion power. This obligation also applies to all vehicles in L1e-A. If, however, the pedelec 45 km/h complies with factor four, then the requirement for vehicle structure integrity is that the pedelec must be designed and constructed to conform with all prescriptions regarding strength and construction of front forks and frames as stipulated in standard ISO 4210:2014. This, combined with the limitation of the weight to 35 kg, is the only practical consequence of the designation “cycles designed to pedal”. L1e-A vehicles must in any Rules & Regulations on Electric Cycles in European Union 10 case conform with the frame and fork requirements in ISO O 4210. Pedelecs 45km/h that do not comply with factor four are subject to more general requirements in the field of vehicle structure integrity. The legislative text stipulates: “Vehicles shall be so designed and constructed as to be sufficiently robust to withstand their intended use over their normal lifetime, taking into account regular and scheduled maintenance and specific equipment adjustments clearly and unambiguously set out in the instruction manual provided with the vehicle. The vehicle manufacturer shall provide a signed statement to this effect.” Moreover: “Vehicle assembly and construction in the assembly plant(s), in particular the processes relating to the vehicle frame, chassis and/or body and the drivetrain, shall be covered by a quality assurance system to ensure that essential mechanical connections such as welds and threaded connections, as well as other relevant material characteristics, are checked and verified as appropriate.” The assumption is that an electric cycle not complying with factor four, but which has passed the ISO 4210 tests, meets the more general requirements above. However, it should be noted that ISO 4210 does not apply to delivery and recumbent cycles. The Commission has confirmed that, probably in 2017, factor four will be examined based on scientific data and statistics on vehicles placed on the market. This examination may result in the review of factor four in a future revision of the Regulation.