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ETRA: Safety Concerns for New E-Bike Type Approval

Laws & Regulations

BRUSSELS, Belgium – The European Parliament is about to vote the review of the type-approval. In a dramatic appeal to all MEP’s, ETRA urges them not to vote article 2.2(g) of the compromise text. According to ETRA, this article is an open invitation for electric bicycle manufacturers to circumvent the type-approval procedure. ETRA issues a stark warning that article 2.2(g) will produce serious safety risks.

ETRA: Safety Concerns for New E-Bike Type Approval
Will e-mountainbikes be excluded from the new type-approval?

The European Parliament and Council have reached a compromise on the Proposal for Regulation on the approval and market surveillance of two- or three-wheel vehicles and quadricycles. This compromise still needs to be formally debated and voted in a Plenary session. That is scheduled for Monday 19 and Tuesday 20 November.

New regulation not for MTB?
In the run-up to the Plenary session, ETRA has made a dramatic appeal to all Members of the European Parliament not to vote article 2.2(g) of the proposal. That article stipulates that the Regulation does not apply to vehicles primarily intended for off-road use and designed to travel on unpaved surfaces.

According to ETRA, this article is a permit for manufacturers of electric bicycles to circumvent type-approval and to put vehicles on the market with optimum functional danger levels rather than safety levels. ETRA also calls the article a permit for manufacturers to put vehicles on the market for irresponsible consumers who are only interested in speed and power output.

No criteria available
ETRA Secretary General Annick Roetynck further explains: “Manufacturers can very easily declare their electric bicycles vehicles primarily intended for off-road use and designed to travel on unpaved surfaces, since there are no criteria whatsoever set for labeling a vehicle as such.” Designed to travel on unpaved surfaces has in this context no meaning whatsoever because even if they are designed for that purpose, there is no rule against use on public roads. For comparison, many a mountain bikes are used on public roads though it is primarily intended for off-road use and designed to travel on unpaved surfaces.

Annick Roetynck continues: “If a manufacturer labels his electric bicycle as a vehicle primarily intended for off road use and designed to travel on unpaved surfaces then the vehicle is out of the type-approval and there are no other technical rules applying. There is only the General Product Safety Directive which obliges the manufacturer to put a safe product on the market. Furthermore, the owner of the above vehicle will be allowed to use the vehicle without any other obligations, i.e. helmet, insurance, driving licence, age limit, … There is no speed limit by construction set for his vehicle, nor a motor output limit.”

Motorcycles re-included
ETRA is unequivocal about article 2.2(g): absolutely inconsistent, dangerous and irresponsible. Warnings for this same article were issued by the motorcycle community. As a result, enduro, trial and heavy duty quads were explicitly re-included in the compromise text. ETRA has been warning Commission, Council and Parliament about the fact that this article will be abused to avoid the type-approval procedure for electric bicycles since 2009 and has proposed an amendment to overcome the problem, but that was eventually totally ignored.

According to ETRA it is very likely that manufacturers of electric bicycles will use the way out of type-approval offered to them by article 2.2(g) because type-approval is an extremely complicated, expensive and inappropriate regulation since it is designed for conventional mopeds and motorcycles, not for electric bicycles.

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