L-category vehicles in type-approval are currently exempted from the electric range test if their maximum speed is less than 50 km/h. At the request of Spain, the European Commission is now considering whether to introduce a specific test for these vehicles after all. Stakeholders had to submit their comments before 15 October, which LEVA-EU in view of the electric bikes in type- approval, has done.
LEVA-EU has informed the Commission of the following position.
It may be relevant to have a harmonized test to provide customers with clear information on top of the information already provided through the electric consumption test. However, it is absolutely essential to take into account that there are a very large number of variables that have an influence on electric range and to inform the customer of this issue. Furthermore, it is essential for the harmonized test to be developed by the industry involved provided there is sufficient support within the industry for such a test.
According to LEVA-EU, there is no need for a legally binding test as part of the type-approval. The type-approval for electric bicycles as it stands today is extremely complicated and extremely expensive, to a point where it is not feasible for small companies. The introduction of a legally binding test will further increase the price of type-approval, thus exacerbating this issue and having a negative impact on competition. LEVA-EU concluded that it is possible to supply customers and users with objective and precise information by means of a voluntary, harmonized test.
In order to sound out the electric bike sector on this issue, LEVA-EU launched an Internet based survey, which at the time that LEVA-EU had to respond to the Commission, had been completed by 32 respondents.
47% of the respondents declared themselves in favour of a legally binding test for electric range, against 38% in favour of leaving it to the free initiative of the manufacturer, whilst 15% were proposing a different solution. Whereas among electric bike manufacturers and importers/distributors, the vote for a legally binding test as opposed to free initiative was 50/50, there was a much stronger vote for a legally binding test among component companies: 8 against 4.
The overall majority of respondents (87.5%) declared themselves familiar with type-approval requirements and procedures. However, only a minority of the respondents (47%) currently has electric bikes in type-approval. Of these, a small majority favoured free initiative over a legally binding test. Remarkably enough, in the group that had no electric bikes in type-approval, twice as many respondents favoured a legally binding test instead of free initiative.
Of all respondents, just under 44% are currently testing the range of their electric bikes. To the question “Do you find it necessary to provide customers and users with information on electric range?” a majority of more than 78% answered positively.
LEVA-EU draws the following conclusions from this survey. Electric range is an important issue, since a clear majority believes it is necessary to provide customers with relevant information. However, the survey does not show clear-cut support for one or another solution. Although 47% of the respondents speak out in favour of a legally binding test, the companies in favour of free initiative or another solution together represent 53%. In other words, opinions are divided. Although a majority of respondents state that they are familiar with type-approval requirements and procedures, LEVA-EU believes that this familiarity does not mean that the companies have an in-depth knowledge of type-approval. They may well require more essential information on very important aspects of a potential electric range test, such as the exact content of the test, the test requirements and especially the cost of the test to be able to judge thoroughly.
The survey is still only and companies active in the electric bike sector are encouraged to complete the survey, which only takes 5 minutes. The survey is here: https://goo.gl/forms/YMvqvwtRbggY0pmw2