EU Regulations for E-bikes & Pedelecs (Part 1)
The battery and the motor in an e-Bike result in a number of risks that do not exist in a conventional bicycle. In five chapters you can find information on the set of European rules and regulations that apply in all 27 member states regarding e-Bikes. Companies active in
All those who are considering manufacturing, importing, distributing, selling, renting, leasing, making available, promoting, electric bicycles must be aware of and observe these rules. This overview is aimed at providing all interested parties with the relevant information.
Electric bicycle is a term, which covers two different concepts of vehicles with an auxiliary electric motor:
- Cycles equipped with an auxiliary motor that cannot be exclusively propelled by that motor.
- Only when the cyclist pedals, does the motor assist. These vehicles are generally called pedelecs.
- Cycles equipped with an auxiliary electric motor that can be exclusively propelled by that motor.
- The cyclist is not necessarily required to pedal. These vehicles are generally called E-bikes.
Pedelecs and E-bikes are not always two-wheeled. There are also vehicles with 3 wheels. Legal definitions have the term “cycles” in order to cover all vehicles, irrespective of their number of wheels.
Article 1 (h) of Directive 2002/24/EC relating to the type-approval of two or three-wheel motor vehicles legislation stipulates that the Directive does not apply to: “cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of 0.25 kW, of which the output is progressively reduced and finally cut off as the vehicle reaches a speed of 25 km/h, or sooner, if the cyclist stops pedalling”. As a result of this exclusion, member states classify these vehicles as bicycles.
Pedelecs with a maximum continuous rated power of more than 0.25 kW and all E-bikes that can be exclusively propelled by the motor do fall within the scope of Directive 2002/24/EC. In this Directive they are classified as low-performance mopeds, i.e. vehicles with pedals, with an auxiliary engine of power not exceeding 1 kW and a maximum design speed not exceeding 25 km/h. As a result, they have to be type-approved but they are excluded from a number of type-approval requirements as listed in Annex I of Directive 2002/24/EC. The note to Annex I sums up the excluded requirements.
Pedelecs with a motor assisting beyond 25 km/h and E-bikes with a maximum design speed exceeding 25 km/h are classified as conventional mopeds (category L1e) and have to be type-approved accordingly.
The type-approval may only be carried out by an officially recognised approval authority. Type-approval in one member state is valid in all other 26 member states. The type-approval applies not only to the vehicle as a whole but also to all components and characteristics listed in Annex I of Directive 2002/24/EC. Consequently, a type-approved components may only be replaced by another type-approved components. A type-approved electric bike must be supplied with an official Certificate of Conformity. In all member states moped classification brings along compulsory wear of a helmet, insurance, driving license and an age limit. In some cases, it also involves a number plate.
Reviewing Directive 2002/24/EC
The European institutions are in the process of reviewing Directive 2002/24/EC. In that framework, the European Twowheel Retailers’ Association (ETRA) has submitted a proposal aimed at changing the legislation related to electric cycles. The full text of the proposal is available at: https://www.dropbox.com/s/mkb8fdhddm3l914/Comments%20and%20Amendments%20by%20ETRA%20-%20final%20version.pdf.
The overall objective of ETRA’s proposal is to achieve technical regulations which are developed specifically for electric bicycles rather than for mopeds and motorcycles. The reviewed type-approval legislation is expected to become effective in 2016.
Member states classify pedelecs excluded from Directive 2002/24/EC as bicycles. For this category of vehicles the European standard EN 15194 (EPAC – Electrically Power Assisted Cycles) has been implemented. The text of this standard should be available in any national language from the national standardisation institutes.
Most EU member states have not introduced a legal obligation to comply with EN 15194. In some member states however, such as UK and France, compliance with the standard is compulsory. Most member states allow for self-certification. This means that if a manufacturer has his own testing facilities and believes his pedelecs, after testing, comply with EN 15194, the manufacturer is allowed to certify his own products. In reality, many manufacturers have their pedelecs tested by professional testing organizations.
EN 15194 only concerns the electric part of the vehicle, whereas for the bicycle part EN 14764 applies. Consequently, the vehicle has to come with marking and instructions as listed in these standards.
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.
As for instructions
The vehicle must be provided with a set containing the following information:
a) preparation for riding — how to measure and adjust the saddle height and handlebar height to suit the rider, with an explanation of the insertion-depth warning marks on the seat-pillar and the handlebar-stem, and clear information on which levers operate the front brake and which lever operates the rear brake;
b) recommended tightening of fasteners related to handlebar, handlebar-stem, saddle and seat-pillar, and wheels;
c) the method for determining the correct adjustment of wheel quick-release mechanisms, such as, “the mechanism should emboss the fork ends when closed to the locked position”;
d) the correct assembly of any parts supplied unassembled;
e) the permissible total weight of the rider and luggage;
f) lubrication — where and how often to lubricate, and recommended lubricant;
g) the correct chain tension and how to adjust this;
h) adjustment of gears;
i) adjustment of brakes and recommendations for replacement of the friction components;
j) care of the wheel-rims and a clear explanation of any danger of rim-wear;
k) appropriate spares, i.e. tyres, tubes, brake friction components;
l) accessories — where these are offered as fitted, details should be included such as operation, maintenance required (if any) and relevant spares (e. g. light-bulbs);
m) safe riding — regular checks on brakes, tyres, steering, caution concerning possible increased braking distance in wet weather;
n) the type of use for which the bicycle has been designed (i. e. the type of terrain for which it is suitable) with a warning against the hazards of incorrect use;
o) an advisory note to draw attention to the rider concerning possible national legal requirements when the bicycle is to be ridden on public roads (e.g. lightning and reflectors);
p) the importance of using genuine replacement parts for safety-critical components;
q) Concept and description of electric assistance;
r) Recommendation for washing;
s) Control and tell tales;
t) Specific EPAC recommendations for use;
u) Specific EPAC warnings;
v) Recommendations about battery charging and charger use as well use as well as the importance of following the instruction contained on the label of the battery charger.
EN 14764 revision
The European Standardisation Committee (CEN) has announced that European standard EN 14764 will be revised. The reference of the new version of that standard following the revision cannot be published in the Official Journal of the European Union in the absence of a Commission mandate laying down specific safety requirements. The Commission has provided such a mandate by means of its Decision of 29 December 2011. In that Decision, the Commission has set specific safety requirements for bicycles with a view to mandating the CEN to develop European standards on the basis of those requirements. Once the reference to the revised standard is published in the Official Journal, any electric bicycle complying with the new EN 14764 standard will be presumed to be safe for its mechanical part under the General Product Safety Directive.