At the beginning of 2022, the State Traffic Office of Spain (DGT) presented the technical requirements manual for the certification of PLEV, which will enable the regulation of the circulation of these vehicles in Spain. As of the 22^nd of January 2024 all PLEVs have to be certified in order to be authorized to circulate in Spain.

Regarding the manual’s entry into force, it became effective on 22 January 2022. However, a transitional regime was established with the following timelines:

• All PLEVs marketed until 22 January 2024 will be able to circulate until 22 January 2027 without the need to be certified.
• All PLEVs marketed from 22 January 2024 onwards must be certified.
• From 22 January 2027 onwards, only PLEVs complying with the requirements described in the manual will be allowed to circulate.

As specified in the manual, an electric scooter is a vehicle with one or more wheels, propelled exclusively by electric motors that, by design, can provide a maximum speed of between 6 and 25 km/h (4 – 16 mph). They can only be equipped with a single seat or saddle if they are provided with a self-balancing system.

Key Technical Requirements:

• Speed: PLEVs will be permitted to have a maximum speed of 25km/h, following which the engine will cease propulsion. Additionally, they must incorporate anti-tampering systems for both speed and power, along with a visible speed and battery level indicator.
• Braking System: All personal transport vehicles must feature two independent brakes capable of decelerating at a minimum of 3.5 m/s2. Vehicles with more than two wheels should also have a parking brake.
• Visibility: PLEVs are mandated to have front (white), side (white or yellow), and rear (red) reflectors. The brake light should be distinct or integrated with the rear light.
• Indicators and Safety Features: Front and rear indicators, rear-view mirrors, reversing assist, and an acoustic warning system are obligatory. Vehicles designed for goods or services must also include a reversing warning.
• Parking Stability: PLEVs with less than three wheels need a stabilization system such as a side kickstand or central stand for parking stability.
• Wheel Specifications: Minimum wheel diameter is set at 203.2 mm with a rough surface for better ground adherence. Slick tires are strictly prohibited.
• Secure Folding: PLEVs must feature a dual safety system to prevent accidental unfolding during transportation.
• Marking and Identification: Every PLEV should display a unique, legible, factory marking indicating maximum speed, serial number, certificate number, year of construction, make, and model. Additionally, there must be a designated space for carrying an identification or registration tag.
• Quality-Oriented Characteristics: The manual also includes directives on structural integrity, electromagnetic compatibility, humidity resistance, battery protection against high temperatures, non-slip surfaces, among others.

“Personal mobility vehicles are a reality in our cities and contribute positively to sustainability, but we must ensure that they do so in safe conditions. The Manual of technical characteristics will help reduce the number of accidents”, explains Jorge Ordás, deputy director general of Mobility and Technology Management of the DGT.

For their part, the PLEV user associations give a different opinion: “There is already a European standard; this standard is not necessary, it only puts barriers in the market and an expiration date for hundreds of thousands of vehicles”, says Antonio Gómez, spokesperson for the Spanish Federation of MP Vehicle User Associations (FEVEMP).

It must be taken into account that next to this national certification, PLEVs must also legally comply with the Machinery -, EMC – and RoHS Directives. Spain is yet another country believing that it should reinvent the wheel by imposing additional technical requirements on these vehicles. This creates a severe obstruction of the single market. With every country that introduces national rules, manufacturers are forced to adapt the vehicles for that country only.

Some countries are wise enough to refrain from national technical rules, Belgium and France being only two examples. In these countries there are no more problems with e-scooters than, for example, in Germany and now also Spain, which find it necessary to introduce a type-approval for these vehicles. The key question is therefore: cui bono? Next up is the Netherlands, where the damned LEV-framework has been on the political table for several years now. It is fairly clear who in the Netherlands will benefit form the framework. RDW, the Dutch type-approval authority, has the privilege to design the rules and to check them!

In the meantime, the Commission continues to delay adequate harmonized technical rules for e-scooters and other LEVs. Yet another study has now been commissioned, that will undoubtedly come to the same conclusion as the 2022-study: LEVs need their own legal framework. The big question remains when that will finally come. In the best case, the Commission may start working, following the study, within 1 to 1.5 years, then it will take about three years to pass the proposal through the co-decision procedure and so we are good for another 5 years of waiting!