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EU Regulations for E-bikes & Pedelecs (Part 7) RoHS Directive

Laws & Regulations

BRUSSELS, Belgium – As a result of Directive 2002/95/EC, the electrical and electronic parts of a pedelec with assistance up to 25 km/h and a motor output up to 250W may not contain any lead, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE).

EU Regulations for E-bikes & Pedelecs (Part 7) RoHS Directive

In the meantime, a recast of the above Directive has been published, i.e. Directive 2011/65/EC, which the member states must apply no later than 3 January 2013. “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” were originally explicitly included in the scope of this new Directive.

All parts of the e-bike

As a result the Directive would apply not only to the electrical and electronic parts but to all parts of an electric bicycle. An impact assessment resulted in the following conclusion: “Overall, the inclusion of electric bicycles in the scope of RoHS II is expected to have very limited impacts, whether that is in environmental, economic or social terms. While the internal market could benefit from the inclusion, the electric bicycle manufacturers will face additional compliance costs and administrative burdens.”

Therefore it is expected that the European Commission will return to the first solution, i.e. making the RoHS Directive only applicable to the electrical and electronic parts of an electric bicycles. The manufacturer has to certify that his product complies with the RoHS Directive by means of a CE marking. This however, cannot be done unless the product also complies with the Machinery Directive and the EMC Directive.  In order to comply, he also has to draw up technical documentation, carry out an internal production control procedure and provide for a declaration of conformity.

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