Author Archives: Annick Roetynck

About Annick Roetynck

Annick is the Manager of LEVA-EU, with decades of experience in two-wheeled and light electric mobility.

• Institute of Transport Research of the German Aerospace Center invites you to participate in a study

  21/11/2022 12:08 Comments Off on Institute of Transport Research of the German Aerospace Center invites you to participate in a study

  We are looking for participants who own a light electric vehicle (LEV, class L5e, L6e or L7e) and would like to tell us more about the use and their experiences with their LEV.

  The research project is investigating what requirements and needs owners have for LEV design. This includes several questions, such as:

  • What do owners like and dislike about using LEVs?
  • From their perspective, what works well and what doesn’t work well?
  • What should be improved and what should be maintained?

  To answer these questions, we are looking for YOU – LEV owners.

  If you are interested in participating, please visit our project website and write an email to the given mail address: DATAMOST: Use patterns of LEVs – DLR Moving Lab 

  (Please note that the language of the study is German.)

  We look forward to your participation!

  The LEV Study Team

• Whilst EU Commission claims no anti-dumping on parts for e-bikes, EU e-bike assemblers paying millions of duties, fines and guarantees.

  18/11/2022 16:34 Comments Off on Whilst EU Commission claims no anti-dumping on parts for e-bikes, EU e-bike assemblers paying millions of duties, fines and guarantees.

  LEVA-EU was officially informed by the European Commission that there are no anti-dumping duties on parts imported from China for the assembly of electric cycles. Despite this official confirmation, customs services all over Europe are attacking assemblers of electric cycles, slamming them with duties, fines, guarantees and sometimes even threats of criminal court cases. Spoiler alert: this is a complicated story.

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  In a letter to LEVA-EU earlier this year, the Director-General of DG Trade wrote: “(…), as the bicycle parts for the assembly of electrical bicycles are legally not subject to the extended anti-dumping or countervailing measures, the assembly operations of electrical bicycles remain outside the scope of the Exemption Regulation (which logically can only exempt measures which are covered by the antidumping/countervailing measures in the first place).”

  Despite the Director-General’s words, e-bike assemblers up and down the continent are paying 48.5% extended anti-dumping duties on essential bicycle parts, such as frames, forks, wheels, etc, for the assembly of electric bikes. This even involves wheels with motors and frames built for the integration of mid-motors. A child knows that those are not essential bicycle parts but parts for e-bikes only.

  What’s worse, some of those e-bike assemblers are fined and/or threatened with a criminal court case. And if they manage to get the administration in order at all, they still end up paying extended guarantees to ensure that they will only use those wheels with motors and frames for mid-motors in the assembly of e-bikes and not conventional bikes.

  Discrimination

  Customs authorities all around Europe are currently attacking companies that assemble e-bikes only, companies that assemble both bikes and e-bikes are in the clear. That is due to the fact that the two types of companies are subject to different rules.

  A bike + e-bike assembler must obtain an exemption from the EU Commission. This exemption was implemented with the extension of duties to essential bicycle components in 1997. With the introduction of anti-dumping duties on electric bicycles from China in 2018, some companies moved their assembly to Europe. In some cases, companies had an exemption for essential bicycle components for conventional bicycles, which they also used to import bicycle components for electric bicycles. However, there was uncertainty as to the legality of this procedure.

  In an attempt to provide legal certainty, the European Commission published Regulation 2020/1296. With that Regulation, the Commission certified that companies in the EU, that assemble both conventional and electric bicycles, were allowed to use their exemption, originally awarded for assembly of conventional bicycles, for the duty-free import of essential bicycle components for the assembly of electric bicycles.

  Obstacle for start-ups

  However, this Regulation did not grant companies, that assemble electric bicycles only, the same exemption for essential bicycle components imported for the assembly of electric bicycles. Instead, these companies must obtain exemption from 48.5% anti-circumvention duties through end-use authorisation, which is granted by national customs authorities. These are often not properly informed on specific legislation for e-bikes and as a result many companies fail to obtain end-use authorization. What is utterly unfair is that until a company gets the authorization, they must pay 48.5% on those very components of which the Commission states that they are legally not subject to the duties! Furthermore, the conditions for end-use authorization include extensive guarantees and sometimes very complex business administration requirements. All this is a huge obstacle to starting a new business, which ultimately is detrimental to competition and to growing the market.

  Harrowing case

  The most harrowing case reported to us was a company applying for end-use authorization in August 2018, having their request denied in June 2020: 698 days after the application. They entered a new application and while that procedure was ongoing, another customs department raided the company and accused them of circumventing the anti-dumping duties on e-bikes from China. All that time, the company had been paying 48.5% extended duties on bike components for the assembly of e-bikes. Once again, those are the very components that, according to the Commission, are legally not subject to these extended duties. Finally, the company was informed that all that time, the customs had been treating the application as a request for authorization to import less then 300 components a month, not for the assembly of e-bikes. And so, they were back to square one.

  Logic?

  When the Commission extended the exemption to components for e-bikes through Regulation 2020/1296, LEVA-EU pointed out that this created a discrimination between bike + e-bike assemblers on the one hand and e-bike assemblers only on the other hand. Following a meeting with the Commission, LEVA-EU submitted a detailed proposal with amendments for Regulation 2020/1296. The objective was to also apply the exemption procedure instead of the end-use authorization to e-bike assemblers. The Commission never responded to this proposal, not until that famous letter from the Director-General, which we still do not fully comprehend. “The operations of electric bicycles remain outside the scope of the Exemption Regulation”, so electric bicycle assemblers cannot be included in the exemption scheme.

  However, the “operations of electric bicycles” are clearly in the scope of the Exemption Regulation if carried out by assemblers who also build conventional bicycles!? Frankly, the logic completely escapes us. We also believe it is not a coincidence that the article which grants exemption for assembly of bicycles and electric bicycles does not explicitly mentions “assembly of electric bicycles”. It stipulates “assembly of other products”. If it would have stated “assembly of electric bicycles”, then the Director-General’s claim would have become totally unsustainable.

  Inaccurate nomenclature

  In the meantime, LEVA-EU has discovered that one of the root causes of the problem is the nomenclature. This determines how to categorize a product for import into the EU. While electric cycles, as completed vehicles, are categorized together with motorcycles and mopeds, there is no separate categorization for electric cycle components. They all fall under the same category of non-motorized cycle components. That is how customs manage to categorise wheels with motors as conventional bicycle wheels and how companies end up paying the 48.5% extended duties for essential bicycle parts, despite the fact that it is a bicycle part legally not subject to extended duties, worse, it’s not a bicycle part full stop.

  LEVA-EU continues to negotiate with the Commission on this enormous and extremely unfair legal aberration. One of the potential measures to alleviate the pressure on the affected companies is to introduce suspension of payment of duties as soon as a company requests end-use authorization. This would at least remove one aspect of the discrimination between bike + ebike companies and e-bike companies only. When the Commission receives a properly documented request for exemption, payment of the duties is suspended relatively quickly. With end-use authorization, companies continue to pay for parts legally not subject to extended duties until they obtain the authorization, if ever they obtain the authorization. And of course, refund of the wrongly paid duties is out of the question.

  Obstruction fight against climate change

  The DLR-report, LEV4Climate, commissioned by LEVA-EU shows that light, electric vehicles including electric cycles offer the potential for saving up to 44% GHG emissions. With the current EU dumping legislation on bicycles, parts and e-bikes there will never be enough supply to meet the demand necessary for achieving that potential.

  Companies who have been or currently are being investigated by the customs are invited to contact LEVA-EU Manager, Annick Roetynck, tel. +32 475 500 588, annick@leva-eu.com. We are making an inventory of all customs actions, to build a case against these legal aberrations.

  Photo by Tingey Injury Law Firm on Unsplash

• Join LEVA-EU now for Membership till end 2023

  14/11/2022 11:45 Comments Off on Join LEVA-EU now for Membership till end 2023

  LEVA-EU Membership is usually valid for one year from the date that you confirm your affiliation. However, the LEVA-EU board has decided to apply 1 November as a cut-off date for next year’s membership. If you join between 1 November and 31 December 2022, your membership will run until 31 December of the next year.

  Read up on why you should become a member of LEVA-EU here. You will find full details on what we do under “What We Do” in the top menu of the homepage..

  To apply for membership, simply complete and send the online form here or contact LEVA-EU Manager Annick Roetynck for more details or an introductory meeting: annick@leva-eu.com

  We hope we will have the pleasure of welcoming you as a LEVA-EU Member soon!

  The LEVA-EU Team,
  Annick, Bram, Eddie, Dennis, Willow and Bruno

  Photo by Mick Haupt on Unsplash

• LEVA-EU Session on E-Cargocycle Regulations at ICBF/WOE

  31/10/2022 11:41 Comments Off on LEVA-EU Session on E-Cargocycle Regulations at ICBF/WOE

  On Thursday 27 October, LEVA-EU hosted a special session at the International Cargo Bike Festival (ICBF). The session was fully dedicated to curent legislation and rules governing electric cargocycles.

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  Break-out room 1 was completely packed with very interested participants who asked a lot of questions. LEVA-EU Manager, Annick Roetynck, opened the session with an overview of the general EU legislative framework for e-cargocycles. Joost Witsenburg, (NEN) presented an overview of the ongoing standaridization work for (e)cargocycles in working group 9 of CEN TC 333, of which he is the secretary. Next, LEVA-EU Technical Director, Bram Rotthier presented the DLR study on the emission saving potential of light, electric vehicles, including electric e-cargocycles. Finally, Annick Roetynck concluded the session with an update on the legal status of Series Hybrid systems.

  The presentations may be obtained free of charge by sending an email to annick@leva-eu.com.

  

  The International Cargo Bike Festival, including the LEVA-EU session were part of the World of eMobility (WOE), which was announced as a meeting place for alle stakeholders in the eMobility industry. According to Nieuwsfiets.nu, the World of E-Mobility deserves a chance. Compared to last year, the mobility fair has made some serious progress and organiser Rick van Rijthoven has managed to get a nice delegation from the e-(cargo)cycle and light electric vehicle (LEV) industry on board.

  The automotive sector and the LEV industry have been growing closer in recent years, especially since the electrification of vehicles is gaining momentum. Van Rijthoven is adequately responding to this development with the set-up of World of E-Mobility. A year ago, the business fair took a false start, partly caused by Corona. Attendance was low and shortly before the fair, a number of exhibitors dropped out. In the run-up to the second edition, the organiser promoted the event relentlessly, especially through LinkedIn. He rigged up a broad programme of lectures and presentations and integrated the International Cargo Bike Festival into his fair. The efforts resulted in an event that grew both in size and number of exhibitors.

  Among LEV-exhibitors at World of E-Mobility positivity prevailed and they felt that Van Rijthoven’s initiative deserves a chance. The fair offered a wide variety of electric vehicles, ranging from e-cycles to agricultural vehicles and everything in between. That wide range of offerings meant that visitors were also from very diverse backgrounds. The fair has widely varying starting points and, as a result, exhibitors also got visitors to their stands who were less relevant to them. On the other hand, they could come into contact with interesting visitors they would never have met otherwise. “It is a fair that cannot be compared to any other and so it takes some getting used to. We will now take stock of the results for our company, which will determine whether we will come back next year. Of course, this fair has room for improvement, but it is a new initiative that deserves a serious chance,” said one of the exhibitors from the e-cycle industry, therewith expressing the opinion of many other participants.

• New Expert Group on Urban Mobility including LEVA-EU begins work

  24/10/2022 11:57 Comments Off on New Expert Group on Urban Mobility including LEVA-EU begins work

  To implement the new 2021 EU Urban Mobility Framework, a reinforced platform for dialogue and co-creation of actions was announced. The goal is stronger engagement by Member States and improved dialogue with cities, regions and stakeholders on all urban mobility issues. LEVA-EU is one of the 127 selected participants in the Group.

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  Following a call for applications over the summer, EU Commission DG MOVE received more than 150 applications from organisations as well as cities and regions to become members of the reformed Commission Expert Group on Urban Mobility (E03863). LEVA-EU is one of the 25 organisations selected as expert for the new Group. In addition, Member States have nominated their representatives at Ministry level.

  Members were selected following a thorough evaluation process, and, as a result, the group will include representatives of:

  • Organisations (25 stakeholders – Type C members)
  • Cities and regions (25 authorities at regional or local level – Type D members)
  • Member States (27 authorities at national level – Type D members)

  The full list of members is available at the Register of Commission Expert Groups.

  The first Group meeting takes place on 25 October 2022.

  To implement the new 2021 EU Urban Mobility Framework(link is external), a reinforced platform for dialogue and co-creation of actions was announced. The goal is stronger engagement by Member States and improved dialogue with cities, regions and stakeholders on all urban mobility issues.

  Following a call for applications(link is external) over the summer, DG MOVE received more than 150 applications from organisations as well as cities and regions to become members of the reformed Commission Expert Group on Urban Mobility (E03863). In addition, Member States have nominated their representatives at Ministry level.

  Members were selected following a thorough evaluation process, and, as a result, the group will include representatives of:

  • Organisations (25 stakeholders – Type C members)
  • Cities and regions (25 authorities at regional or local level – Type D members)
  • Member States (27 authorities at national level – Type D members)

  The full list of members is available at the Register of Commission Expert Groups.(link is external)

  The first Group meeting will take place on 25 October 2022.

  Photo by Gaurav Jain on Unsplash

• SBS and SMEunited welcome agreement on amendment to Regulation on EU standardisation

  21/10/2022 12:22 Comments Off on SBS and SMEunited welcome agreement on amendment to Regulation on EU standardisation

  Brussels, 20 October – SBS and SMEunited welcome the agreement by the Council of the European Union and the European Parliament on a technical amendment to Regulation 1025/2012 on European standardisation. The amendment, approved in yesterday’s Coreper I meeting, is part of the package of measures outlined in the Standardisation Strategy published by the European Commission last February.

  SBS has supported the content of the amendment throughout the different stages of the discussion, expressing in its position paper on the subject that inclusiveness needs to be enhanced at all levels of standardisation, be it national, European or international. It is vital that a consultation of all stakeholders, including SMEs, is carried out at national level within the National Standardisation Bodies (NSBs) ahead of any decision concerning a standardisation request.

  In this sense, SBS and SMEunited particularly welcome the newly created Recital 4(a), which stresses the need to ensure the “essential” representation of the interests of SMEs and other societal actors both at national level and within the European Standardisation Organisations. The text offers an improvement over the Commission’s already positive proposal by further highlighting the need for an inclusive, balanced and transparent standardisation system that properly considers the interests of SMEs and all relevant stakeholders.

  Commenting on the agreement reached, SBS Secretary General Maitane Olabarria said: “The agreed text supports a stronger role of SMEs in European standardisation. Looking to the upcoming evaluation of Regulation 1025/2012, SBS renews the call for an effective implementation of its provisions, particularly concerning the participation and access of SMEs to standardisation at the national level.”

  SBS represents and defends small and medium-sized enterprises’ (SMEs) interests in the standardisation process at European and international levels. Moreover, it aims at raising the awareness of SMEs about the benefits of standards and at encouraging them to get involved in the standardisation process. With Eddie Eccleston, LEVA-EU has an SBS-standard working in CEN TC333.

• Electric mopeds and -motorcycles save EU market from decline

  17/10/2022 17:16 Comments Off on Electric mopeds and -motorcycles save EU market from decline

  Registrations of electric motorcycles in the 5 biggest European markets, which together hold around 80%, have more than doubled (+136.3%) in the first half of 2022. The biggest leap took place in Italy, from 2,572 in the first half of 2021 to 6,078. With that, Italy is now largest market for e-motorcycles. Italy overtook Spain, where growth was “only” 58.5% to a total of 4,118. France (+154.2%) and Germany (+149.2%) also outperformed Spain, taking second and third position with 4,815 and 4,142 registrations respectively. Electric motorcycles in these 5 markets, now have a share in total registrations of 3.9% versus 1.9% in the first half of 2021. That stands for a total of 20,905 vehicles, 106.7% more than the previous year.

  Registrations of electric mopeds, including speed pedelecs, in Belgium, France, Italy and Spain also grew, albeit not as strong as the motorcycles. In the first half of 2022, just under 44,000 vehicles were registered, a 24.2% improvement compared to the first half of 2021. The biggest market is the Netherlands with 15,330 vehilces (+16.3%), followed by France with 12,363 (+42.6%) and Belgium with 9,138 (+11.6%). The share of electric mopeds in total registrations thus climbed to 32.7 % compared to 26.6% in the previous year. Consequently, one in three newly registered mopeds is now electric.

  Registrations of both Internal Combustion Engine (ICE) and electric motorcycles dropped by 0.5% in the first half of this year, registration of ICE and E-mopeds wents up by 1%. This status-quo was only possible thanks to increasing registrations of electric vehicles. Their ICE counterparts have been in decline for quite a few years now. ICE-motorcycle registrations shrunk further this year with -2.6%, ICE-mopeds with -7.4%.

• Dutch Speed Pedelec fleet reaches 30,000

  15:08 Comments Off on Dutch Speed Pedelec fleet reaches 30,000

  The Dutch non-profit “Speedpedelec Evolutie” has once again analyzed the Dutch market for speedpedelecs. They are sharing the following information about sales and fleet, based on their data regarding registered speedpedelecs.

  Fleet

  

  The total speed pedelec fleet in The Netherlands has increased by 8% to 29,683 vehicles, consisting of
  58 brands and 203 models. Many models are available with different specifications, so there is plenty of choice. The data show a steady increase of the fleet from 23,793 at the end of 2020 to 27,538 end of last year.
  The Top 10 brands, with a total of 26,601 vehicles, increased their market share from 89 to 90%. No less than 48 brands account for the remaining 10% with a total of 3.082 vehicles.
  
  Last year, the Top 3 brands were the same as the year before: Stromer was market leader, with 34% and the first brand to exceed the 10.000 limit. STromer and number 2, Riese & Müller, hold just over half of the fleet. Third place was for the Dutch brand Sparta. Stromer, Riese & Müller and Sparta have a share of 64% in the Top 10 per model (19.032 vehicles). The remaining 36% (10.651 vehicles) consists of 193 models!
  Stromer’s ST1, ST2 and ST3 hold the 1st to 3rd place. However, it should be taken into account that both ST1 and ST2 consist of several models. For example the old ST2 has a chain and derailleur/sprockets,
  while the new model is driven with a belt and internal gears.
  Stromer has 4 models in the Top 10, Riese & Müller 3, Sparta 2 and Gazelle 1, but that is not their new model “No1”.
  Four new models have been introduced in the first half of 2022: the Y Muse 45 and N Rogue
  45 both by Klever, the Axis eRide Evo Speed Bike by Scott and finally the LEB 800 Speed, the premiere of the German Velo de Ville.

  Despite the new sales, the average age of the fleet increased to 3.9 years. Stromer, Sparta
  and Riese & Müller account for approximately 3,100 vehicles older than 5 years, while the remaining
  3,501 vehicles belong to 38 different brands! In total 43% (almost 13.000 vehicles) are older than 5 years. Almost 2.400 vehicles date from before 2015, with the oldest speed pedelec on Dutch roads being 13.2 years!

  The Speed Pedelec Evolutie data show that 69% of the fleet is still with their first owner, whilst 9,300 (31%) changed ownership. Also, 98% were purchased in The Netherlands, with only 700 speed pedelecs from abroad.

  Sales

  

  In the first half of 2022 sales have increased with 11%, compared to the same period in 2021. However, the result is still 7% lower than sales in the first half of 2020. The first 4 months of 2022 showed an average increase of 25% followed by a reduction of 6% in May and June. Speed Pedelec Evolutie predicts total sales in 2022 of 4,149, which would be a 5% increase compared to 2021.

  For more graphs and indicators please visit
  www.speedpedelec-evolutie.nl

• Estimating environmental damage from key resources required for EU low-carbon transition

  14:10 Comments Off on Estimating environmental damage from key resources required for EU low-carbon transition

  Transition to a low-carbon economy will create additional demand for many raw materials, production of which will have a range of environmental impacts.

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  This study assessed the environmental costs associated with meeting demand for key resources in the EU by 2050. The researchers estimate the total annual cost at €38.9 billion, with 48.5% arising from materials used for electric-vehicle batteries, including nickel, accounting for 24.9% of total cost.

  The transition to a low-carbon economy set out in the European Green Deal will alter demand for many raw materials. However, the environmental impacts of increased demand for key resources required to provide the necessary infrastructure have not been fully assessed. This study used existing data to explore the implications of rising demand by material, type of impact and affected country.

  The researchers identified anticipated consumption of key materials from the EU Foresight study, Critical raw materials for strategic technologies and sectors in the EU¹, and sourced those countries exporting them to the EU from the UN Comtrade database, incorporating production within the EU27 from the US Geological Survey. They considered a range of scenarios, focusing their analysis on a situation with moderate material demand, no recycling (due to current lack of available recycling processes) and a 0% discount rate. They assumed that all materials would continue to be sourced from different countries in the same proportions as they are currently. The researchers then assessed each material for impacts on climate change, water use, land use and abiotic resource depletion (using up finite supplies of materials). They transformed these levels of impact into monetary values to produce final estimates of the total annual cost of environmental damage by 2050.

  The researchers report that the estimated total cost of damage was €38.9 billion. However, they calculate this as only 3.7% of the current annual cost of EU carbon emissions, based on 3.6 billion tonnes of CO₂ (tCO₂) emitted in 2018 at a price of €290 per tCO₂². Nickel accounted for 24.9% of the estimated costs in 2050 (€9.7 billion), they say, with iron accounting for 14% and aluminium for 13.9%.

  They report that 45.8% of the damage costs are associated with materials for batteries used for electric mobility purposes, and a further 8.4% linked with batteries for renewable-energy infrastructure. Impacts on climate change accounted for 47.5% of total costs, according to the researchers, and abiotic resource depletion for 45%. They highlight the disparity between imported quantities of each material and its contribution to impact, with nickel making up only 12% of imported mass, and cobalt, for example, making up 2% of mass but contributing 10.94% of total environmental costs.

  The largest share of environmental costs is borne by China, say the researchers, at €8.2 billion or 21% of the total. They report that substantial costs are also carried by the USA (€4.5 billion) and India (€3.9 billion). However, they say that, as a proportion of national GDP, the greatest burden falls on Guinea and Gabon with environmental costs exceeding 1% of GDP from bauxite and manganese mining, respectively.

  The researchers highlight that as these environmental damage costs only represent 3.7% of costs from EU carbon emissions in 2018, they are likely to be outweighed by the benefits of the transition to a low-carbon economy. They argue that recycling could be a key component in reducing impacts from the production of raw materials and that provisions for public transport and cycling could limit demand for vehicle batteries. The study does not focus on this area, however, as recycling of these materials has not yet begun in earnest – the researchers say that recycling processes for many of the materials and products do not exist in industrial quantities (there are not many electric vehicles entering the demolition phase).

  The researchers acknowledge that there are many uncertainties concerning their calculations – such as future location changes in sourcing of materials, changes in technologies that could alter the demand for materials or the impacts of their production, and uncertainties in ascribing prices to impacts (for instance, estimates for the social cost of carbon range from €7.6 to €69 009.50 per tonne of CO₂ equivalent). They suggest, however, that their methodology could play an important role in incorporating these considerations into planning activities such as criticality assessments, integrated assessment models and material flow analyses.

  Footnotes:

  1. EC’s Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (2020) Critical raw materials for strategic technologies and sectors in the EU, A Foresight Study. Publications Office of the EU. Available from:  Critical raw materials for strategic technologies and sectors in the EU – Publications Office of the EU (europa.eu)[Accessed 27.6.22]
  2. Ricke, K., Drouet, L., Caldeira, K. and Tavoni, M. (2018) Country-level social cost of carbon. Nature Climate Change 8: 895–900.

  Photo by Markus Spiske on Unsplash