Bad EEA report for transport

The European Environment Agency Briefing “Transport and Environment Reporting Mechanism (TERM)” gives the annual progress assessment based on a series of indicators which track the progress of the transport sector in meeting related policy targets and objectives. Issues covered in the briefing include emissions, air pollution, noise and renewable energy and the impact of transport on ecosystems and biodiversity. The report for 2016 is not good and is yet another proof that policy has to acknowledge light electric vehicles as a key factor in solving the problems.

Key findings:

Provisional data shows that in 2016, greenhouse gas emissions in the transport sector (including international aviation but excluding maritime shipping) across the EU-28 were 25 % higher than in 1990, confirming an upward trend in emissions since 2014.
The average carbon dioxide (CO2) emissions of new passenger vans and cars in 2016 were below the respective target paths for 2020 and 2021, although considerable reductions still need to be made in the coming years for manufacturers to meet future targets.
While sales of new diesel passenger cars have decreased in recent years, the share of diesel used in road transport (including for freight transport by heavy-duty vehicles) has continued to rise, amounting to more than 66 % of total fuel sales in road transport in 2015, compared with 51 % in 2000.
Oil consumption by the transport sector will need to fall by more than two-thirds to meet the objective of reducing consumption by 70 % by 2050 compared with 2008 levels.
The share of renewable energy in transport in the EU rose from 6.7 % in 2015 to 7.1 % in 2016, lower than the 10 % target set for 2020. Three Member States (Austria, Finland and Sweden) have already reached the 10 % goal.
Transport is the main source of environmental noise in Europe and contributes to pressure on ecosystem and biodiversity habitats. It also continues to be a significant source of harmful air pollution, especially through emissions of nitrogen dioxide and particulate matter.

The Collective of European Importers of Electric Bicycles regrets new EU anti-dumping legislation comes late

The Collective welcomes the approval by the European Council of the new anti-dumping legislation but sincerely regrets that these new rules, aimed at amending the EU breach of WTO rules, have come too late. It has not prevented EBMA from filing a complaint against imports of electric bikes from China based on the “old” unlawful rules. What’s worse, it has not prevented the European Commission from accepting the complaint and initiating a proceeding, which is just as well based on these unlawful rules.

The new legislation no longer allows the use of an analogue country, eliminates the distinction between market and non-market economies and reverses the burden of proof. The Commission will have to prove the existence of market distortions allowing for the application of the alternative method, i.e. the use of a constructed value.

Similar economic development

In other words, it will be up to the Commission to prove the existence of a “significant market distortion” between a product’s sale price and its production cost. On that basis, it will be allowed to set a price for the product by referring for example to the price of the good in a country with a similar level of economic development or to relevant undistorted international costs and prices.

Completely contrary to all the above, the Commission has provisionally chosen, in accord with EBMA, Switzerland as the most suitable analogue country. To the Collective, this comparison appears neither appropriate, nor convincing to prove China is dumping electric bicycles in Europe through undercutting and underselling.

In their submission to the European Commission, the Collective had already argued that the importers found it unacceptable that this complaint had been accepted and was being treated, not only in accordance with European legislation in breach of WTO rules, but also along lines which go diametrically against the spirit and the objectives of the new rules aimed at amending this breach of WTO-rules.

Totally unrealistic

Using Switzerland as an analogue country, is no less than comparing apples and oranges. Average monthly wages in China in 2016 were € 730, in Switzerland € 5,730. EBMA states explicitly that the case focusses mainly on EPACs, but chooses an analogue country with the relatively highest sales of speed EPACs in the world. In 2016, 22% of all electric bicycles sold in Switzerland were speed EPACs. The much more stringent technical rules for these vehicles than for EPACs are only one element in much higher price levels than for 25 km/h EPACs. But supplying the lower end of the market does not automatically mean dumping. EBMA ignores this world of difference between Chinese and Swiss EPAC production, which allows for the calculation of triple digit dumping margins (from 193% to 430%) based on normal values of in between € 1,782 and € 2,544. This is totally unrealistic.

The new Regulation will apply to all decisions on the initiation of proceedings, and to all proceedings, including original investigations and review investigations, initiated on or after the date on which this Regulation enters into force. The Regulation will enter into force the day after its publication in the Official Journal. That date is announced to be the 20th December, precisely two months after publication of the initiation of the proceeding.

Collective of European Importers calls on European Commission to terminate case against Chinese e-bikes

Gent, Belgium 21 importers from 7 EU member states have joined forces for their defence in the anti-dumping proceeding on electric bikes from China. On 26 November, the Collective of European Importers of Electric Bicycles has sent preliminary comments to the European Commission to counterargue the EBMA-complaint and to request to be considered an interested party in the proceeding. The Collective finds the evidence presented in the complaint for dumping, injury and causal link very feeble and unconvincing.

The Collective consists of a group of European importers, some of which have been on the market for a long time. They all share the intention and efforts to develop solid, successful and growing businesses. They have chosen to achieve this by developing long-term relationships with among others Chinese suppliers. In the comments sent to the European Commission, they voice their great concerns about the future of their businesses and the impact on European citizens, should the EU decide to impose anti-dumping duties on electric bicycle imports from China.

Comparing apples and oranges

The Collective opens its comments with the conclusion that the proceeding is based on European legislation, which is in breach of WTO-rules. The EU should have changed its legislation before the end of last year but failed to do so. Consequently, the EU is now using rules for this proceeding, which go against WTO regulations. Under the new legislation for instance, the use of analogue country will no longer be allowed. However, in this proceeding, the principle of analogue country is still applied. What’s worse, the European Commission goes along with EBMA’s suggestion to choose Switzerland as analogue country.

This is no less than comparing apples and oranges. Average monthly wages in China in 2016 were € 730, in Switzerland € 5,730. EBMA states explicitly that the case focusses mainly on EPACs, but chooses an analogue country with the relatively highest sales of speed EPACs in the world. In 2016, 22% of all electric bicycles sold in Switzerland were speed EPACs. The much more stringent technical rules for these vehicles than for EPACs are only one element in much higher price levels than for 25 km/h EPACs. But supplying the lower end of the market does not automatically mean dumping. EBMA ignores this world of difference between Chinese and Swiss EPAC production, which allows for the calculation of triple digit dumping margins (from 193% to 430%) based on normal values of in between € 1,782 and € 2,544. This is totally unrealistic.

Polluted statistics

As for the import/export data used in the complaint, something very peculiar is going on. EBMA rejects Eurostat import figures because they are “polluted”. According to EBMA, these figures include other products than electric bicycles, such as hoverboards and conventional bicycles sent to Europe under the CN code for electric bicycles. This allows for avoiding import duties and circumventing anti-dumping duties. The Collective fails to understand why EBMA, although aware of these illegal trade practices for more than 3 years, has taken no action whatsoever against them.

Instead a dumping complaint is built on export statistics provided by the custom services of a country that is being extensively accused of causing injury to the European industry, not only by dumping but also by subsidization. As the Chinese export statistics are listed “confidential” it is impossible to check out the data.

The injury evidence presented is just as debatable. In the considered period, electric bike consumption in the EU increased by 55%. Growing demand resulted in sales for both the EU producers and importers to go up. Sales by EU producers supporting the complaint increased by 45% in the period considered. Furthermore, employment in EU industry also improved: with 9% in 2015 and with almost 12% in 2016. Where to find proof of injury among all these positive results?

Competition to shrink

The reason why the Collective submits an extensive counter-argumentation is because the group believes that it is exactly potential anti-dumping duties that cause a threat of injury, more specifically injury to the European electric bike market and therefore to the European citizens

The Collective has the strong impression that this complaint is based on the ultimate objective to create a hidden non-tariff trade barrier, rather than tackling a real illicit trade practice. The EBMA represents companies, which to a large extent are active in mid- and high-range electric bicycles. There is a however also a considerable market for lower-range products. The Collective believes that the complaint is aimed at preventing non-EU producers to supply this market. Furthermore, should anti-dumping duties be imposed, this will ensure that Chinese producers are also prevented from being active in the mid- and high-range market. Because of the anti-dumping duties, Chinese producers will no longer be able to supply European importers with a competitive product in any of these ranges.

Achieving these two objectives, i.e. preventing Chinese supply for the low end as well as developing mid- and high range products, will result in shrinking competition, which in turn will bring about a reduction of choice and higher prices for European consumers.

Anti-circumvention case in the making

The complaint holds 19 references to Bosch and 17 to Bafang. Whilst extensive references are made to Bosch to make the case for dumping, Bafang is accused at length of among other things subsidization without any evidence being produced. Apart from the fact that subsidization allegations do not belong in an anti-dumping complaint, this argument strengthens the Collective’s impression that this complaint is an anti-circumvention complaint in the making.

The Collective warns that should anti-dumping duties be followed by anti-circumvention measures, then the whole European electric bicycles business, including the European producers of electric bicycles will sustain very considerable damage. The production of components for electric bicycles in Europe is by no means at a level to supply the demand that would result from anti-circumvention measures. The consequences of such shortage would be incalculable. Reduction of competition may well further deteriorate into the creation of monopolies.

Call to terminate

The Collective holds a deep belief in the potential contribution of electric bicycles and other light electric vehicles to sustainable mobility, as well as to the improvement of public health, combatting climate change, greening the economy, creating jobs, in short improving overall quality of life.

However, if the consumer is confronted with a lack of choice, because of trade restrictive measures, which are reducing competition, it is very likely that this consumer will turn away from electric bicycles and will rather continue using unsustainable means of transport to the detriment of our society as a whole.

In conclusion, the Collective is convinced that the complainant does not provide satisfying evidence for dumping, injury and causal link. Since the potential imposition of anti-dumping duties will seriously harm the electric bicycle sector in the EU as well as EU citizens and society, the Collective calls upon the Commission to terminate the proceeding without any further measures.

 

Greenhouse gas emissions across EU drop slightly in 2016 despite transport growth

Source: EEA

Greenhouse gas emissions across the European Union decreased modestly in 2016, according to estimates published in the latest climate ‘trends and projections’ assessments released today by the European Environment Agency (EEA). The estimates confirm that the EU remains on track to meet its emission reduction target set for 2020, but more work is needed to meet longer-term goals.

According to preliminary estimates, emissions for 2016 in the EU decreased by 0.7% from 2015. The slight drop corresponds to a 23% decrease in emissions between 1990 and 2016. The decrease in 2016 was mainly due to a rising share of renewable energy and a switch from coal to gas in the EU’s fuel mix for power generation, despite an increase in energy consumption and growth in emissions in the residential and transport sectors.

A higher demand for heating (because of weather conditions) and a higher transport demand in 2016 help explain the increase. Emissions from these sectors are now 11% below 2005 levels.

The full articles and report are here.

 

LEVA-EU L6-L7 meeting preceding LEVS in Rotterdam: don’t forget to register

 

On Tuesday 21 November,  the day preceding the Light Electric Vehicle Summit, which takes place in Rotterdam on 22 and 23 November, LEVA-EU is organizing a meeting specifically for L6-L7 companies. The meeting will take place in the LEVS-venue Engels in Rotterdam from 1 o’clock till 3.15 p.m. This meeting will be followed by the second International Energy Agency workshop on small vehicles from 3.30 till 6 p.m in the same meeting room.

All companies operating in the field of L6-L7 or planning to start operating are welcome to attend the LEVA-EU meeting.  They are invited to state their interest or confirm attendance at this meeting by completing the following form: https://goo.gl/forms/52JLbKhG4VGO1vWi1

Interested companies should also note that if they intend to attend LEVS and they have not yet registered, they can enjoy a 10% discount by using our promocode LEVAEU on the LEVS registration webpage: http://levs.mobi/page/registration-form/.

The light electric vehicles association in Europe, LEVA-EU has been established earlier this year . The objective of our association is to promote LEVs and to grow the LEV-market in Europe.

We are convinced that LEVs offer a huge potential for making transport more sustainable and much more efficient.

So far, no association in Europe was working specifically for the benefit of LEVs. LEVA-EU is now filling this important gap and is the only association in Europe to work exclusively for light electric vehicles.

The scope of LEVA-EU is all L-category vehicles including L6, light quadricycles, and L7, heavy quadricycles for on-road use.

LEVA-EU is convinced that the potential of these vehicles as a means of making mobility more sustainable is seriously underused and undervalued. Therefore, LEVA-EU is seeking to bring together the major players in this sector. The objective being to offer these players a platform to get to know each other and to develop joint initiatives to grow the market.

Contact for further details: LEVA-EU manager, Annick Roetynck,
leva-eu@telenet.be,
tel. +32 9 233 60 05

EU Anti-Dumping Proceedings Electric Bicycles from China: Important Deadlines

On 20th October, the European Commission has published a notice of initiation of an anti-dumping proceeding concerning imports of electric bicycles originating in the People’s Republic of China, which you will find here: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017XC1020(01)

LEVA-EU believes it is important for all stakeholders, both EU producers and importers of electric bicycles, to be informed on the procedure and the relating deadlines. That is why we have listed below the essential deadlines for all interested parties to make themselves known to the Commission.

  • By 4 November: contact the Commission as an EU producer if you consider you should be included in the EU producers’ sample
  • By 4 November: all European importers buying the product under investigation from Chinese suppliers, but not related to those Chinese companies, should make themselves known to the Commission by completing Annex II of the Notice. The definition of “(un)related” is in footnote 1 of page 22 of the Notice.
  • By 4 November: all producers exporting from China or representatives acting on their behalf, should make themselves known to the Commission and provide the information requested in Annex I of the Notice, which includes a declaration to claim an individual dumping margin should the Commission impose anti-dumping duties.
  • By 4 November: comments on the choice of Switzerland as an analogue country or arguments for another analogue country to be sent to the Commission.
  • By 4 November: deadline for requests to be heard on issues pertaining to the initial stage of the investigation
  • By 10 November: deadline for interested parties wishing to submit any relevant information regarding the selection of the sample other than the information requested through Annex I from exporting producers
  • By 10 November: deadline for interested parties wishing to submit any relevant information regarding the selection of the sample other than the information requested through Annex II from unrelated importers
  • By 10 November: deadline for interested parties wishing to submit any relevant information regarding the selection of the sample of EU producers.

For any further details on this issue, please contact LEVA-EU Manager, Annick Roetynck, email leva-eu@telenet.be, tel. +32 9 233 60 05.

LEVA-EU on electric range test for electric bikes: may be relevant, but no legal obligation required

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