The European Commission has drafted an Implementing Regulation that sets out how EU Member States must collect and submit urban mobility data for each designated urban node under Regulation (EU) 2024/1679. This data covers three major areas:

• Sustainability (e.g., mobility trends, mode shares),
• Safety (e.g., accident data by road-user type), and
• Accessibility (e.g., availability of parking infrastructure).

In the framework of the public consultation on this draft legislation, LEVA-EU has submitted feedback to the Commission. The core message of this feedback is that the draft legislation fails to correctly recognise and categorise Light Electric Vehicles (LEVs)—and that this omission will lead to poor-quality, inconsistent, and incomplete mobility data across the EU.

LEVs still “invisible” in EU legislation

LEVA-EU highlights a long-standing structural problem: light electric vehicles are scattered across multiple legislative frameworks never designed with them in mind. As a result, LEVs remain largely invisible in EU mobility policy. Attempts to introduce terms, such as “micromobility“, “light means of transport” or “personal mobility devices”, have only added confusion, resulting in unclear or contradictory classifications. This problem, LEVA-EU notes, is repeated in the draft implementing regulation and its Annex. Various vehicle types are mixed or misnamed, others left out entirely—undermining the goal of generating high-quality, harmonised data across the EU.

EGUM has already set the direction

In its feedback, LEVA-EU stresses that the Commission’s own Expert Group on Urban Mobility has already recognised the need to consistently reference light electric mobility, alongside walking and cycling, in its 2024 recommendations for the mid-term review of the Road Safety Policy Framework 2021–2030. These recommendations call for better counting methods and harmonised data frameworks capturing LEV use and user behaviour.

To fix inconsistencies and ensure reliable data, LEVA-EU proposes a simple and unified approach: define LEVs according to their legal status under Regulation (EU) 168/2013 and the Machinery Directive. This would clearly include EPACs, e-scooters, self-balancing vehicles, powered cycles, speed pedelecs, e-mopeds, electric motorcycles, tricycles, quadricycles, and micro-cars.

The organisation recommends introducing this definition directly into the regulation through a new Article 2(17): “Light Electric Vehicles’ means all electric vehicles for on-road use and subject to Regulation 168/2013 and all electric vehicles for on-road use subject to Directive 2006/42/EC until 31 December 2026 and Regulation 2023/1230 as of 1 January 2027.”

Key amendments proposed by LEVA-EU

To enable accurate and harmonised mobility data, LEVA-EU proposes the following changes:

1. Updated indicators for Sustainability

• Add “using light electric vehicles” as a distinct category in trip-counting indicators (SU.2), ensuring LEV usage is measured separately from walking and cycling.
• Clarify whether micro-cars (L7 vehicles) are included in the stock of registered passenger cars (SU.3).

2. Revised Safety Indicators

• Replace vague or outdated categories with a clear list of LEV types: micro-cars, tricycles, e-motorcycles, e-mopeds, speed pedelecs, powered cycles, speed pedelecs, EPACs, e-scooters, self-balancing vehicles, … This ensures road safety data reflects the full diversity of modern mobility.

3. Parking and Infrastructure Definitions
Amend definitions to include LEVs—such as modifying “secure bike parking facility” to “secure bike and light electric vehicle parking facility.”

4. Accident Data Collection
The current draft uses a single term, “road vehicle,” to cover everything from bicycles to trucks. LEVA-EU finds this unacceptable and calls for clearer distinctions between heavy and light vehicles to avoid misleading accident statistics.

Urgent Need for an Update to CARE Database Terminology

LEVA-EU concludes by stressing that the EU’s CARE accident database urgently needs a terminology update aligned with the organisation’s proposals. LEVA-EU stands ready to assist the Commission in implementing these improvements.