Just before the end of last year, Belgian Member of the European Parliament Kathleen Van Brempt paid an extensive visit to Ellio, a Belgian member of LEVA-EU. Kathleen Van Brempt is part of the S&D Group, serves as Vice-Chair of the Committee on International Trade, and is a substitute member of the Committee on Transport and Tourism. Ellio is a Belgian manufacturer of speed pedelecs, which are assembled at the custom-work company Bewel in Tessenderlo (B). A number of other LEVA-EU members from Belgium, the Netherlands, and France also took part in the visit.

---

The two main topics of discussion during this visit were the inadequate technical regulations for LEVs in general and for speed pedelecs in particular, and the trade defence measures against China relating to electric bicycles.

Despite a preparatory meeting between LEVA-EU and Kathleen Van Brempt, she listened with great attention—and in particular with considerable astonishment—to the accounts from Ellio and the other participants regarding inadequate technical regulations for light electric vehicles in the EU, as well as the damage caused, in particular, by the anti-dumping duties on bicycle components from China to European assemblers of electric bicycles. Several participants in the meeting are currently involved in legal proceedings in which they face exceptionally heavy fines and possibly even prison sentences.

Ellio is not involved in any legal proceedings but likewise experiences systematic problems with Belgian customs when (attempting) to import bicycle components for use in their speed pedelecs. The highly complex administration resulting from their end-use authorisation regularly leads to fines—not because they have violated anti-dumping legislation, but purely because they have not applied the extremely complex administrative rules correctly. The situation is so burdensome for the company that they recently decided simply to pay the 48.5% anti-dumping duty on the import of front forks from China.

This meeting took place while Kathleen Van Brempt was awaiting a response from the European Commission to her parliamentary question on the trade defence measures against China in our sector. That question consisted of three parts:

• How the Commission intends to resolve the legal uncertainty and disproportionate burdens faced by small and medium-sized enterprises in the LEV sector?
• How it justifies extending anti-dumping duties on bicycle components from China despite the sector’s reliance on Chinese supply chains?
• How it plans to align its trade defence measures with the EU’s industrial strategy to enhance competitiveness, innovation, and LEV production?

In his uninformative response, Maroš Šefčovič, Commissioner for Trade, claims that everything is properly arranged and running smoothly. According to him, the anti-circumvention measures on bicycle parts from China were introduced to tackle circumvention practices by Chinese exporters, and everything possible has been done to protect European assemblers through the exemption scheme and the end-use authorisation.

“The measures on bicycles (both conventional and electric) have proven efficient and allowed the EU industry to prosper,” according to the Commissioner. It is particularly shocking to read this response, which completely disregards the financial and personal suffering that dozens of companies in Europe have been enduring for years. From the testimonies that Ms Van Brempt heard directly from the affected entrepreneurs, it was clear that the measures are anything but efficient and have certainly not allowed this part of the industry to prosper.

Below you will find a brief summary of the testimony given by Tomas Keppens, Co-Founder and CTO of Ellio, during the meeting with Ms Van Brempt.

Stakeholders who wish to provide testimony on challenges related to the import of bicycle components from China for the assembly of electric cycles, or on issues concerning type approval for speed pedelecs, are invited to contact LEVA-EU at annick@leva-eu.com. Contributions are welcome irrespective of LEVA-EU membership status.

The stories about anti-dumping duties on bicycle components from China and about inadequate technical regulations will undoubtedly continue this year. We will keep you informed.

---

The Key Regulatory and Administrative Challenges Faced by Ellio

Ellio is a Belgian innovator in the speed pedelec segment, developing intuitive, high-performance drivetrains designed. Their speed pedelecs are developed, and assembled in Belgium, including through social employment initiatives. Ellio’s ambition is to lower the threshold for consumers to step into “fast” cycling as a valuable and credible mobility alternative.

Despite operating in what should be a favourable environment, Ellio encounters quite a number of structural regulatory and administrative obstacles that disproportionately affect innovative European SMEs.

Belgium as a Testbed for New Mobility – In Theory

Belgium, and Flanders in particular, is often cited as an ideal testing ground for speed pedelecs. This is due to three enabling pillars:

• A suitable regulatory framework for the use of speed pedelec
• Improving cycling infrastructur
• Strong fiscal and financial incentives for sustainable mobility

However, for SME manufacturers such as Ellio, policy design and implementation often also create barriers rather than support, especially in the domains of customs, anti-dumping measures, and vehicle type approval.

---

Customs: Legal Certainty at High Administrative Cost

Ellio is importing certain bicycle components from China. For this import, it has obtained an end-use authorisation. Nevertheless, the company experiences a high level of scrutiny from Belgian customs authorities. While oversight is understandable, enforcement is often perceived as focusing strictly on the letter of the law rather than risk-based compliance.

• Even when there is no indication of fraud, minor human errors trigger inspections and fines.
• The solution proposed by the customs to facilitate smoother operations, i.e a request for a Binding Tariff Information (BTI) decision, would have offered legal certainty but came with significant downsides:
  • Lengthy procedures
  • Extremely time-consuming discussions with very rigid and therefore unworkable interpretations by the customs, for instance on what constitutes a “brake set”
  • Disproportionate cost and effort for SMEs

In practice, this creates a situation where regulatory complexity fuels dependency on external consultants, effectively shifting resources away from innovation.

---

Anti-Dumping Rules: Disproportionate Burden on SMEs

Anti-dumping measures on bicycle components imported from China further compound administrative pressure:

• Use of the special end-use authorisation regime requires extensive documentation and is highly error-prone.
• Certain components, such as braking systems, have proven unworkable under this regime and are no longer sourced by Ellio that way.
• Other components, such as suspension forks, are imported with the payment of 48.5% in anti-dumping duties, increasing costs without clear policy justification in the context of European assembly and innovation.

---

Type Approval: A Framework Designed for PTW Not Bicycles

One of the most significant challenges lies in vehicle type approval for L1e-B speed pedelecs.

Structural mismatch with the bicycle industry

The current system reflects mopeds and motorcycles, i.e. Powered Twowheelers (PTW) logic rather than cycling reality:

• In PTW manufacturing, OEMs hold deep in-house regulatory expertise and tightly control suppliers.
• In the bicycle sector, critical system knowledge resides with suppliers (e.g. drivetrain manufacturers), not OEMs.
• Training and system certification are provided by suppliers, not by bike manufacturers themselves.

For SMEs with small production runs, the cost of full vehicle type approval cannot be amortised in the same way as in the automotive sector and PTW sector which has much bigger series and higher prices.

Excessive variants and administrative overhead

Unlike PTWs, bicycles have no fixed “bodywork” which results in one size fits all. Rider position varies through:

• Frame size
• Handlebar configuration
• Saddle height

This leads to a multiplication of types/variants, each carrying very considerable administrative overhead and additional cost, despite differences having no meaningful impact on safety. Paradoxically, some mandatory requirements (e.g. adjustable saddles) exclude certain innovative configurations altogether.

---

Safety and Consumer Protection Gaps

Ironically, compliance with existing legislation does not always guarantee adequate consumer protection:

• Type-approval legislation for speed pedelecs require testing of frames and forks according to a conventional bicycle safety standard ISO 4210:2014, which is repealed and only partially addresses critical elements such as fork strength.
• The resulting safety requirements int type-approval are totally inadequate for speed pedelecs, creating a regulatory blind spot.

At the same time, the few type-approval services in the EU that offer approval of speed pedelecs, face capacity constraints, leading to long approval timelines, uncertainty for manufacturers and ensuing additional costs.

---

The 4:1 Assistance Rule: Technically Unrealistic

The requirement that rider input must correspond to a fixed 4:1 assistance ratio is particularly problematic:

• Maintaining 45 km/h under this rule is only feasible for trained riders, in ideal conditions, with a sporty riding posture.
• Everyday use cases—upright posture, hills, headwind, commuting without excessive physical strain—are effectively excluded.

In PTW terms, this would be equivalent to limiting a vehicle’s maximum speed based on the driver’s physical strength and seat position—an approach that would be unthinkable.

Despite the Commission’s explicit confirmation that this factor four is not a legal requirement but an option, all approval service in the EU apply it is a legal requirement.

---

Conclusion

Ellio’s experience illustrates a broader systemic issue: regulatory frameworks built for large-scale PTW production do not translate well to innovative, small-series European light electric vehicle manufacturers. Addressing these mismatches is essential if Europe wants to remain competitive in sustainable, human-centred and light electric mobility innovation.