LEVA-EU has issued a petition urging the Dutch Minister, Barry Madlener, and Secretary of State, Chris Jansen, responsible for Infrastructure and Water Management to withdraw the Dutch LEV Framework. The petition argues that the current draft contradicts established EU legislation, undermines the principles of the European Single Market, and ignores years of expert-driven standardisation work and key stakeholder engagement.

---

Sign the petition here: https://form.jotform.com/243504659084360

---

Over the past years, the Dutch government has prepared a comprehensive regulatory technical framework intended to govern various LEVs—including electric cargocycles, e-scooters, and self-balancing vehicles. While acknowledging the importance of road safety, LEVA-EU asserts that the framework, as it stands, will stifle innovation and restrict the availability of sustainable transport options, hindering the transition to cleaner mobility.

The planned technical requirements in the LEV framework are largely derived from the homologation legislation for L-category vehicles. However, the vehicles in the LEV framework are excluded from the L-category on the basis of Article 2.2 of Regulation 168/2013, precisely because the technical requirements are not suitable for these vehicles. By now making the rules for the L-category applicable via the LEV framework to vehicles that are excluded from the L-category by the EU, the Netherlands is going against European legislation. This also goes against the principle of the single market and therefore unnecessarily creates an illegal obstacle for manufacturers in the Netherlands and abroad to put vehicles on the Dutch market.

The current plans completely ignore the existing harmonised EU legislation. In all Member States, including the Netherlands, the vehicles excluded from Regulation 168/2013 following Article 2.2, are subject to the Machinery Directive/Regulation, the EMC and RoHS Directive and the Battery Regulation. Vehicles that do not meet the safety requirements of this legislation can simply be removed from the market. This is currently happening in the Netherlands, for example, with the so-called “fat bikes”, legally electric bicycles with pedal assistance up to 25 km/h and 250W, excluded from Regulation 168/2013 on the basis of Article 2.2(h) and therefore subject to the Machinery, EMC and RoHS Directives. Several thousands of these fat bikes have been recently seized, based on the fact that they don’t comply with the stated legislation.

In addition, this harmonised legislation has been supplemented with European technical standards that specify detailed technical requirements and tests for the vehicles concerned. For electric scooters and self-balancing vehicles, this is EN 17128, which is currently being revised. For electric cargo bikes, a series of 7 standards has just been completed, under the title EN 17860, by CEN TC333-WG9. Dozens of experts from the European sector have worked intensively on these standards for four years under the leadership of a secretariat that was provided by the Dutch standardisation institute NEN. Moreover, the convenor of this working group is also Dutch! The fact that this work has been completely ignored in the development of the LEV framework is downright incomprehensible and disrespectful.

Many other countries, including neighbouring Belgium, allow the vehicles in question on public roads without further technical requirements. These countries accept the Machine, EMC and RoHS directives as the applicable harmonised legislation and strictly limit themselves to the mere conditions of use. In these countries, there are no structural safety problems with the vehicles in question. Incidentally, the Netherlands does the same for electric bicycles (2 wheels) with pedal assistance up to 25 km/h and 250W. There are no additional Dutch technical requirements for these vehicles, while there are millions of them on the road. As indicated, the current Dutch government has chosen the right path by tackling the problems with fat bikes on the basis of the Machine, EMC and RoHS directives. LEVA-EU urges that the same sensible approach be taken for electric scooters, self-balancing vehicles with and without steering and electric cargo bikes.

Finally, LEVA-EU also asks for the Minister and Secretary of State to take note of the recent recommendations of the Expert Group on Urban Mobility, which have been endorsed by the Commission. These recommendations state: “The Commission must develop harmonized technical legislation and mandate related standards, specifically for light electric vehicles in close consultation with the light electric vehicle sector.” A purely Dutch initiative to develop technical legislation for just a few LEV-types is not in line with this recommendation. Instead, LEVA-EU argues, the Netherlands should work with the Commission to realise this harmonised technical legislation in close consultation with the LEV sector.

LEVA-EU also emphasises that in the development of the Dutch LEV framework, the real stakeholders have been systematically ignored. The trade association hopes that by responding to the petition, the two politicians will also rectify this important shortcoming and accept to have an in-depth consultation with the sector and the relevant companies involved.

Key Requests of the Petition:

• Immediate Withdrawal of the Proposed LEV Framework: Abandon the current measures that conflict with EU law and harm market harmonization.
• Adherence to Existing EU Directives and Standards: Align Dutch policy with established European standards and directives, which already provide clear, unified safety requirements.
• Close Collaboration with the EU and LEV Sector: Work jointly with the European Commission and industry experts to develop consistent, long-term regulations.
• Inclusive Stakeholder Consultation: Engage in comprehensive dialogue with sector representatives to foster policies that encourage innovation, ensure safety, and bolster sustainability.

Conclusion:
LEVA-EU calls on the Dutch Minister and Secretary of State for Infrastructure and Water Management to reconsider the current approach, comply with EU legislation and best practices, and pursue an inclusive, future-oriented path. By doing so, LEVA-EU argues, the Netherlands can uphold its reputation as a leader in sustainable, forward-thinking mobility solutions.

Petitioners’ Requests:

• Immediate Withdrawal: Stop enforcement of the current LEV Framework proposal that contradicts EU law and lacks stakeholder input.
• Alignment with EU Directives and Standards: Follow existing EU rules and recognized European standards that are already proven and effective.
• Collaboration at EU Level: Work closely with the European Commission and industry stakeholders to develop harmonized, future-proof LEV legislation.
• Inclusive Consultation: Engage in thorough dialogue with sector experts to ensure that the Dutch LEV policy remains safe, innovative, and sustainable.

Any company, organisation or individual that wishes to support the call for the withdrawal of the LEV-Framework is invited to sign the petition below: