European Commission Confirmed Categorization Speed E-Bikes
BRUSSELS, Belgium – The European Commission has used this year’s transition period for the new e-bike type-approval procedure to shed light on a number of unclear issues. One major issue was the categorization of different types of speed e-bikes.
On 1st January 2016, the new type-approval procedure based on Regulation 168/2013 has become effective. This procedure applies to all types of electric bicycles, except those on which you must pedal for the motor to assist up to 25 km/h with a maximum continuous rated power of 250W.
Until 31st December 2016 however, manufacturers still have a choice between the ‘old’ procedure based on Directive 2002/24 or the new one. On 1st January 2017 the new procedure becomes the only valid one. For that procedure the categorization of different types of e-bikes was still unclear. That’s settled now.
For the categorization the main question was whether there was a difference depending on the type of propulsion. On some electric bicycles, the motor only assists on condition that the rider pedals. On other types, the motor can propel the vehicle by itself without the rider having to pedal. And there are also types which offer a combination of these two options.
Electric bicycles either come under category L1e-A, ‘powered cycles’, or L1e-B, ‘two-wheel mopeds’. For L1e-A, the motor has to be cut off at a speed of 25 km/h and the maximum continuous motor power should not exceed 1 kW. The L1e-B category is subject to a maximum design vehicle speed of 45 km/h and a maximum continuous rated power of 4 kW.
With that, the Commission has now confirmed that all types of electric bicycles up to 25 km/h and 1 kW fall under L1e-A. This means that the bicycle may be equipped with a motor, which only assists provided you pedal, or with a motor that propels the bike by itself or with a combination or a choice of these systems.
There was a very strong opposition to this interpretation. Several stakeholders argued that only electric bicycles, of which the motor assists provided that the rider pedals, should have been categorized as L1e-A vehicles. They believed that bicycles that can work on the motor only should have been referred to category L1e-B.
Easier or more difficult type-approval
This was partly a philosophical discussion, partly an argumentation inspired by commercial motives. A number of type-approval requirements in L1e-A have been adapted to vehicles, which technically are much more related to bicycles then to mopeds.
This was interpreted by some stakeholders as allowing for an ‘easier’ type-approval, granting electric bicycles an advantage over for instance conventional mopeds, which would be subject to a more ‘difficult’ type-approval.
This does not hold good, the different requirements have been developed in order to better adapt the type-approval procedure to electric bicycles. The introduction of specific tests for frame and fork is a good example of an adapted requirement which has not exactly made type-approval easier for electric bicycles.
One of the member states, which was very much in favour of the interpretation to categorize all types of 25 km/h – 1 kW electric bicycles as L1e-A, was the UK, since historically the overall majority of electric bikes there have been equipped with a throttle. So far, the UK has been considering them as conventional bicycles. Therefore, in the past years, the UK has consistently argued against their categorization as L1e-B. Still as of 1st January 2017, they will have to be type-approved as L1e-A.
Category L1e-B also allows for all available systems on condition that the motor cuts out at 45 km/h and the maximum continuous rated power does not exceed 4 kW. The main question still open for this category was: “What about electric bicycles that do not meet the factor 4 requirement?”
In 2013, COLIBI and COLIPED had submitted to the European Commission a proposal to create a separate category for so-called speed pedelecs in the type-approval. However, the proposal came too late. By then the vehicle categories had been defined in the framework Regulation 168/2013, which had been approved by European Parliament and Council. No new categories could be introduced anymore.
The only solution was to have a mention of so-called speed pedelecs in one of the Regulations, in which the Commission sets out the technical details for the type-approval. Consequently, Regulation 3/2014 on vehicle safety requirements has the following: “Cycles designed to pedal of vehicle category L1e-B shall have 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.”
This gave rise to the question as to how to categorize electric bicycles that do not comply with factor 4, either because their motor power is higher than 4 times the pedal power or because they do not have a system in which the motor only assists when the rider pedals.
The Commission has now definitely confirmed that these types of electric bicycles also come under L1e-B. Because of the specific wording however, they are not subject to the EN 14764 test on frames and forks. The assumption is that the technical services will still use this test to check compliance with the rather vague structural integrity requirements in place for L1e-B vehicles in general.
As stated before, electric bicycles in the type-approval are subject to a number of requirements, which have been adapted or specifically introduced with a view to making the procedure better tuned to the types of vehicles. In this framework, electric bicycles are subject to specific tests for measuring speed, maximum continuous rated power, switch-off distance and maximum assistance factor.
Until now, this specific electric bicycle chapter also had a test for peak power and maximum motor power. This however was an editorial mistake since there are no requirements nor limit values for peak power and maximum motor power.
AVERE has argued for a very long time against these tests. Type-approval is a very complicated and expensive procedure, so there is certainly no need for unnecessary additional administrative burden and the expensive that goes with it. After all this time, the Commission has recently confirmed that they will delete the two unnecessary tests from the legislation.
With that however, the Commission has refused to rectify one other anomaly. Although factor 4 is a requirement that only concerns vehicles in L1e-B, vehicles in L1e-A have to go through the test on factor 4.
Supported by the UK, AVERE also insisted on the removal of this test for L1e-A. The Commission argued that such a test provides the consumer with information on the type of propulsion on his bicycle. In AVERE’s opinion, this argument is not really valid since full details on the propulsion system have to be provided in the legally required manual and instructions.
Finally, the Commission has officially confirmed that in 2017 they will order research into factor 4 as announced in a preamble of Regulation 3/2014: “The limitation to ‘four’ of the ratio of auxiliary propulsion power and actual pedal power for cycles designed to pedal set out in Annex XIX should be subject to further scientific research and assessment. Upon availability of scientific data and statistics on vehicles placed on the market, the ratio ‘four’ referred to above may be revisited in a future revision of this Regulation.”
By then, there should also be more clarity about the accuracy of the type-approval procedure in ensuring the technical safety of electric bicycles and other light electric vehicles.