On behalf of its members active in the e-bike sector and across the broader European Light Electric Vehicles (LEV) industry, LEVA-EU expresses its strong opposition to the position put forward by the German Bicycle Industry Association (ZIV) on 7 April 2025, titled “E-bikes – Active Mobility as Success Factor.”

ZIV’s proposal is based on the incorrect assumption that EPACs (Electrically Power Assisted Cycles) owe their market success to an alleged legal equivalence with bicycles. On this flawed basis, ZIV seeks to impose additional technical restrictions on EPACs, including limits on motor power, assistance ratios, and vehicle weight. Specifically, ZIV proposes to divide EPACs into two categories governed by separate legal frameworks:

EPACs that would remain excluded from L-category type approval under Regulation 168/2013, provided they meet all of the following criteria:
– Assistance limited to 25 km/h
– Maximum continuous rated power < 250W
– Peak power < 750W
– Assistance factor < 4
– Weight < 250 kg for single-track carrier cycles
– Weight < 300 kg for multi-track carrier cycles

All other EPACs exceeding any of the above thresholds would become subject to the L-category vehicle type approval under Regulation 168/2013. This includes:
Electrically assisted (mountain) cycles with assistance factor > 4 and/or peak power > 750W
Electrically assisted carrier cycles exceeding 250 kg (single-track) or 300 kg (multi-track)

LEVA-EU strongly opposes this proposal, as it would create a deeply unfair regulatory divide. EPACs that remain excluded from type approval would continue to enjoy a favourable legal and technical status under the Machinery Directive. In contrast, EPACs falling outside ZIV’s narrow definition would be forced into the L-category type-approval system, which is overly complex, prohibitively expensive, and technically unsuitable for these vehicles. This would effectively eliminate their development and market viability.

ZIV claims that the legal status of EPACs is under threat and must be safeguarded through stricter definitions. This claim is entirely unfounded. The current legal framework—based on Article 2.2(h) of Regulation 168/2013 and the Machinery Directive—has provided a clear, stable, and effective basis for the development and market placement of EPACs.
Harmonised European standards such as EN 15194, EN 17404, and EN 17860 ensure technical compliance and safety. There is no indication from the European Commission that this framework is inadequate or that EPACs are at risk of reclassification. The assertion of legal uncertainty is therefore misleading and does not justify the proposed restrictions.

It is also important to consider the underlying motivations behind ZIV’s proposal. ZIV represents major manufacturers of traditional bicycles and pedelecs, many of whom rely on specific drivetrain technologies that dominate the current 25 km/h – 250W market. The proposal appears designed to protect these incumbents by preserving the legal status of their products while restricting the growth of more powerful or innovative LEVs. This approach risks stifling competition, innovation, and the development of new vehicle types that serve broader mobility needs, including logistics, accessibility, and sport.

LEVA-EU firmly states that EPACs are Light Electric Vehicles, not bicycles, as defined by the Vienna Convention on Road Traffic. Bicycles are vehicles with at least two wheels, propelled solely by muscular energy, typically via pedals or hand-cranks. EPACs, by contrast, are electrically assisted and fall outside this definition. Their development and legal status should not be dictated by the bicycle industry.

Technical legislation such as Regulation 168/2013 and the Machinery Directive is intended to ensure that vehicles placed on the market are technically safe. These frameworks are not meant to prescribe vehicle characteristics, regulate user effort, or define mobility behaviour. The suggestion that EPACs risk being classified as motor vehicles unless assistance ratios and weight limits are imposed is legally baseless.

The ZIV proposal would:
– Severely hinder the development of EPACs for logistics, accessibility, and sport
– Discriminate against elderly, disabled, and physically weaker users
– Undermine the EU’s climate and mobility goals by reducing modal shift potential and innovation
– Misrepresent the purpose of technical legislation, which is not to define active mobility or enforce physical effort

The real legislative priority should be the creation of a dedicated LEV regulatory framework, developed in close consultation with the LEV industry. Such a framework should ensure fair, inclusive, and technically justified rules for all types of Light Electric Vehicles. In its current form, the ZIV position promotes a narrow industrial agenda that conflicts with broader EU goals for competitiveness, sustainability, and inclusive mobility.

LEVA-EU has produced a detailed fact-checking paper on ZIV’s position, available for download here.
The LEVA-EU position paper on a dedicated LEV regulatory framework is here.

Please contact LEVA-EU Managing Director, Annick Roetynck, annick@leva-eu.com, or Policy Director, Harold Tor-Daenens, harold@leva-eu.com.