The recently released Kurz-Studie on Electrically Power Assisted cycles (EPACs), published by the Zentrum Nachhaltige Transformation (zNT Berlin), presents itself as an objective contribution to the mobility debate. A closer look, however, reveals that the study is biased towards preserving the current legal framework and fails to address some of the most urgent regulatory challenges facing Europe’s mobility transition.

From the outset, the study narrows its scope by equating EPACs almost exclusively with conventional two-wheeled bicycles (2wheels) limited to 25 km/h and 250 watts. Other important EPAC categories, such as cargo bikes or inclusive vehicles for people with disabilities, are barely mentioned. This narrow perspective sidelines precisely those vehicle types that could make the greatest contribution to sustainable urban logistics and inclusive mobility solutions.

Equally striking is the absence of any discussion of technical neutrality. Regulation 168/2013 has created a distorted situation in which vehicles with similar performance as EPACs are regulated differently depending on technical details such as throttle control or maximum continuous rated power. This breach of neutrality is one of the key barriers to fair regulation in the light electric vehicle sector, yet the study ignores it completely. As a result, the analysis paints a misleadingly positive picture of the existing framework, without acknowledging how many vehicles are effectively locked out of the market.

This lack of perspective is particularly apparent when considering innovation. While the study celebrates the success of the EPAC market under current rules, it does not mention the many vehicle types that have been stifled by the system. Heavy-duty cargo bikes, EPACs designed for (very) hilly terrain or adaptive solutions for mobility-impaired users are all subject to regulatory burdens that obstruct their market entry and uptake. A true assessment of the framework should weigh both the successes it has enabled and the opportunities it has prevented. Instead, the study only tells half the story.

The bias becomes even clearer in its treatment of industry positions. LEVA-EU’s proposals for reform, such as abolishing the arbitrary and senseless 250W limit or creating a new, fairer legislation for light electric vehicles, are described as risky, theoretical or destabilising. With that, the study ignores the fact that LEVA-EU’s proposals have been recommended by the Expert Group on Urban Mobility to the European Commission. By contrast, the proposals of the Zweirad-Industrie-Verband (ZIV) are framed as pragmatic and stabilising. This rhetorical imbalance conceals the fact that the ZIV’s suggestions—such as additional limits on weight, power and support ratios—would in practice push many EPACs into Regulation 168/2013.

This would result in type approval requirements, with the accompanying terms of use that are not adapted to the vehicles such as no access to bicycle traffic rules, helmet obligations, motor vehicle insurance obligations, etc. Such a shift would devastate large parts of the market. None of this is acknowledged in the study.

Finally, the study leans heavily on the results of a Civey user survey, which finds that most current EPAC owners are satisfied with their Electrically Power Assisted Bicycles and see little need for change. While this finding is unsurprising, it is also limited. Surveys of today’s users naturally reflect the bulk of the existing market, but they say nothing about the untapped demand for vehicle categories that are currently limited or excluded by Regulation 168/2013. Presenting these results as evidence for regulatory stagnation misses the wider picture.

Europe’s mobility transition cannot be achieved by freezing outdated definitions in law. A regulatory framework that is truly fair and future-proof must be based on technical neutrality, must enable innovation, and must ensure that the full diversity of EPACs and light electric vehicles can reach the market. This conclusion is also supported by the conclusions of the LEV4Climate study conducted by the German Aerospace Center (DLR) and commissioned by LEVA-EU. The study demonstrated that light electric vehicles have significant potential to reduce greenhouse gas emissions and replace car trips—potential that can only be realised if legislation allows a broad spectrum of LEVs onto the market rather than restricting them to narrow, outdated categories. Protecting the status quo may serve the interests of incumbent industry players, but it undermines the broader goals of sustainability, innovation and inclusivity.

Annick Roetynck, LEVA-EU Managing Director, concludes: “Europe’s mobility transition cannot succeed by freezing yesterday’s definitions in law. We need a regulatory framework that is fair, technically neutral, and future-proof—one that enables the full diversity of EPACs and LEVs to reach the market.”