The European Commission has finally decided to appoint TRL to carry out the long awaited research into the type-approval requirement of a maximum assistance factor for speed pedelecs. LEVA-EU is welcoming this research and committed to giving TRL full support. Any company or research institute with relevant information is invited to contact TRL.
Speed pedelecs, i.e. electric bicycles with pedal assistance up to 45 km/h, must comply with the European, technical rules laid down in the Type-Approval for category L1e-B “mopeds”. These rules consist of hundreds of pages of text and are therefore extremely complicated. Furthermore, the rules have originally been written for mopeds and are therefore not accurate for speed pedelecs or for any other electric bicycles for that matter.
Thanks to ETRA, the European trade association for bicycles dealers, which ceased to exist in 2013, some parts of the text have been adapted to better accommodate electric bicycles in the Type-Approval. However one specific paragraph was introduced in the texts, which throughout the years has continued to cause controversy. Certain parties thought this paragraph was necessary to make a clear distinction between bicycles and mopeds.
As a result, the Commission introduced the following paragraph: “Cycles designed to pedal of vehicle category L1e-B shall have a mass in running order of ≤ 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.”
ETRA fiercely opposed that paragraph mainly because of the maximum assistance factor requirement. ETRA argued that there was no evidence what so ever to show that this maximum assistance factor was necessary to ensure the safety of speed pedelecs. The requirement was nothing but an unnecessary design limitation that hampers the technological and market development of electric bicycles in the Type-Approval. As a compromise, the Commission introduced in the texts the promise to have the maximum assistance factor four examined, based on scientific data and statistics on vehicles placed on the market. The Commission stated that this examination could potentially result in the review of factor four. That research has now been assigned to the British Transport Research Laboratory (TRL).
In the meantime however, the Belgian University KU Leuven also became involved in the matter of type-approval for electric bicycles. Professor Jan Cappelle and his PhD student Bram Rotthier found that the maximum assistance factor is not a legal obligation for speed pedelecs. The “cycles designed to pedal” as described above are not a separate type-approval category. Type-approval legislation does not hold any legal obligations for electric bicycles in L1e-B to comply with maximum assistance factor four. It only holds a legal obligation to test the auxiliary propulsion power on its maximum assistance. Strangely enough, this obligation to test for maximum assistance factor also applies to all vehicles in L1e-A, even though the requirement itself does not. LEVA-EU has asked the Commision repeatedly to eliminate this unneccessary test, which is a waste of companies’ money, but the Commission continues to refuse. They state that the test holds valuable information for the end-user. To date, we have not yet found the first end-user who knows what maximum assistance factor means.
If a speed pedelec complies with maximum assistance factor four, then the requirement for vehicle structure integrity is that the vehicle must be designed and constructed to conform with all prescriptions regarding strength and construction of front forks and frames as stipulated in standard ISO 4210:2014. This combined with the limitation of the weight to 35 kg, is the only practical consequence of the designation “cycles designed to pedal”. If the speed pedelec has an assistance factor higher than four, then it does not need to be tested according to ISO 4210:2014. Incidentally, the reference to this ISO standard itself has now become inaccurate since in 2017 a completely revised EN 15194 has been published. The ISO standard refers to conventional city bikes, the revised EN 15194 has specific requirements for electric bicycle frames and forks.
LEVA-EU has taken over the battle for accurate technical rules for electric bicycles from ETRA. LEVA-EU considers adequate technical rules the single most important condition to enable this sector to fully tap on the potential of electric bicycles and LEVs in general. LEVA-EU therefore very much welcomes the fact that the Commission’s promise of further research on factor 4 has now come to fruition. Obviously, LEVA-EU is giving TRL its full cooperation. It is however essential for TRL to hear as many testimonies as possible from companies involved in the speed pedelec business. So TRL has launched the following appeal:
For speed pedelec companies as well as speed pedelec component companies to provide TRL with information on
- design philosophy of speed pedelecs e.g. the choice of assistance factor, powertrain configuration and control methodology
- current usage profiles e.g. types of journeys undertaken, rider’s age and gender, whether journeys are conducted on cycle paths or highways
- any issues encountered while riding e.g. collisions or incidents, interactions with other road users;
- perceptions of the effects of assistance factor on safety e.g. issues with controllability or stability encountered while riding.
TRL also wishes to hear from anybody who has any research in the area of assistance factor and safety.
If you have any relevant information on the above mentioned issues, please contact:
Dr Ianto Guy – TRL Vehicle Safety and Technology Consultant
Email firstname.lastname@example.org – tel. +44 1344 770 084 – mobile +44 7436 270343