Comments Off on Commission Workshop on LEV-Legislation: registration to close on 8 September
On 14 September 2022, the European Commission will hold a workshop on the technical requirements on road safety for so-called Personal Mobility Devices (PMD). The term PMD covers all electric cycles, including cargocycles and speed pedelecs, e-scooters, self-balancing vehicles, electric skateboards, etc. LEVA-EU calls on the whole LEV-sector to participate in the workshop and have a say about current and future LEV-legislation.
This workshop is a one-off opportunity to make it clear to the European Commission that the current legislation is not adapted to light electric vehicles (LEVs) and therefore hinders their market development and uptake. LEVA-EU therefore warmly appeals to all companies, manufacturers, importers, distributors, as well as user groups involved, to seize this opportunity to testify that PMDs are currently severely hampered by a lack of proper legislation and to demand harmonised and accurate European legislation for these vehicles. The workshop will take place both physically in Brussels and online. Registration closes on 8 September, 12:00 CEST: https://bit.ly/3APEupl.
The current 250 W limit applied to EPACs is too low for the heavier pedal assisted cargo bikes that are now growing in popularity.
The L1e-A subcategory (electric cycles up to 25 km/h but more than 250W) has failed to attract manufacturers and consumers.
The business model of many PMD manufacturers is incompatible with the type-approval system.
On the question of traffic rules, there is support for the development of an EU harmonised approach.
TRL concluded that technical regulation outside the Machinery Directive and Regulation 168/2013, tailored to the needs of the PMD industry was the best way forward . The system could include a variety of assessment methods, ranging from self-certification to independent testing. TRL concluded further: “In our view this new system for the regulation and approval of PMDs would provide the flexibility necessary to support innovation in this rapidly evolving sector, while maintaining technical standards and road safety.”
Following this study, LEVA-EU submitted to the Commission a very extensive Position Paper on how EU rules and regulations for Personal Mobility Devices (PMDs) could be easily formulated into a simple but accurate legal framework, specifically for PMDs. The Commission responded: “We will carefully review and provide a detailed reply to your position paper.” That detailed reply never came. When we contacted the Commission to enquire after their response, we were told that at that time car emission issues had priority. On that occasion it was announced that there would be a workshop in the second half of 2022.
LEVA-EU is, to say the least, very surprised by the content of that workshop. The TRL study explicitly covered All PMDs and also clearly stated that the legislation for ALL PMDs needs to be revised. The September workshop, however, seems to focus one-sidedly on e-scooters. There is no mention in the programme of any planning for a review of the legislation. The Netherlands, France and Germany are each allowed to explain their national rules for e-scooters which, in our opinion, are in direct conflict with European legislation. And before the Commission enters into discussion with the participants, only one e-scooter manufacturer is allowed to comment on technical aspects and regulatory compliance. You read it correctly: ONE.
In the framework of the energy crisis as well as the Green Deal, the Fit for 55 Package, the New Urban Mobility Framework, the European Climate Pact and many more EU policies, it can no longer be justified that LEVs are neglected to this extent. We need solutions NOW.
LEVA-EU therefore calls upon all LEV-stakeholders to attend the Commission’s Workshop of 14 September 2022, either live in Brussels or online. Do not miss this unique opportunity to have your say on how your EPAC, Electric Cargo Cycle, Speed Pedelec, E-Scooter, Self-Balancing Vehicle Business needs its own accurate legal framework without any futher delay. Register before 8 September, 12 CET, here: https://ec.europa.eu/eusurvey/runner/63d8a542-d4b1-17e4-4159-fad262171bff
Comments Off on Like LEVA-EU, JRC advocates new, separate battery category for Light Electric Vehicles
JRC has completed its study for the European Commission on alternative collection targets for Light Means of Transport (LMT) batteries. JRC concludes that the best way forward is to introduce a new separate category for LMT batteries. That is exactly the solution, which LEVA-EU has been advocating since the Commission has published the new battery Regulation proposal. The JRC report is therefore a major boost for LEVA-EU’s lobby campaign towards the European Parliament and Council.
In its original proposal, the European Commission suggested to include batteries for so-called Light Means of Transport (LMT) in the portable battery category. The proposal defined LMT-batteries as sealed, up to 5 kg and for use in vehicles with a seat and a motor of no more than 750 Watts. All other batteries, such as those in electric scooters, mobility scooters, e-mopeds, e-motorcycles and other electric vehicles in the L-category would be categorized as electric vehicle batteries.
Hugely problematic proposal
LEVA-EU immediately pointed out to the Commission that this definition would create huge problems for light, electric vehicles (LEVs). The main issue is the fact that the electric vehicle battery category is subject to information and sustainability requirements, which are simply not feasible for LEV-manufacturers. Another issue was the requirement for a seat, pushing all e-scooters into the electric vehicle battery category. Also, the limit of 750 Watts was meaningless because the meaning of Watts remained unspecified.
On top of these issues, the Commission was also confronted with questions from the Member States on the effect of the proposal on LMT. The Commission acknowledged the issues and asked the Joint Research Centre (JRC) for research into how to set a collection target for LMT batteries. JRC is the Commission’s science and knowledge service, which employs scientists to carry out research in order to provide independent scientific advice and support to EU policy.
Unknown and uninteded consequence
In its research and through consultation with stakeholders, among which LEVA-EU, JRC easily established that the definition of LMT batteries as proposed by the Commission was flawed. The definition was found to be “troublesome in its reference to motors ‘of less than 750 watts’. It is found to be problematic in referencing to ‘on which travellers are seated’ with a significant amount of smaller LMT products without a seat. Both types of parameters effectively discriminate between products with comparable battery characteristics.”
However, there were deeper issues with the Commission’s proposal to classify LMT-batteries as portable batteries. The proposal holds collection targets for portable batteries based on the so-called Put on Market (PoM) parameter. The JRC-study was exactly meant to determine whether that method and the targets set for portable batteries could be simply extended to LMT-batteries or whether alternative collection methods and targets for LMT-batteries were needed. In its research on collection targets for LMT batteries, JRC stumbled upon an “unknown and unintended consequence of the originally proposed target basis”. JRC’s conclusion on the proposed PoM-method and resulting targets for LMT-batteries was: “(…) due to increasing sales of rechargeable and LMT batteries, plus potentially more durable primary batteries as well, there will be a growing discrepancy between the placed on the market (POM) volumes and the waste volume becoming available later. This means that the currently proposed POM based collection target, based on 3 preceding years of sales, will not be ‘steadily ambitious’, but relatively more challenging for the years 2025 and 2030 when the newer target levels are respectively set at 65% and 70%. Reversely, in later years it will become less challenging.”
Growing discrepancy
The following example illustrates JRC’s findings. According to some prognoses, European electric bike sales could reach 17 million in 2030. In that year, the PoM collection rate will go to 70% based on the 3 preceding years. Hypothetical sales of 13.25 million in 2027, 14.5 million in 2028 and 15.75 million in 2029 would result in 10.15 million e-bike batteries targeted for collection in 2030. Let’s assume an average lifetime for e-bike batteries of 6 years. That means that the batteries becoming available for collection will effectively be put on the market in 2024. Sales in 2020 were estimated at 4.5 million. It is therefore totally unlikely that in 2024 sufficient sales will be achieved to reach a collection target of 10.15 million batteries in 2030. Even if sales reach 10 million in 2024, it is impossible for 100% of those batteries to make it to the collection points.
To overcome this problem, JRC proposes what it calls a “future-proof solution”. That includes the creation of a separate LMT battery category, next to industrial, automotive, electric vehicle and portable battery categories. Secondly, the basis for the collection target for this new category should be changed from Put on Market (PoM) to Available for Collection (AfC).
All batteries from non-type-approved light, electric vehicles as well as from L1 to L7 vehicles would come under the new category. This proposal is almost fully in line with what LEVA-EU has asked for from the start. Nevertheless, JRC proposes to include all LEV-batteries but only up to 25 kg. It is unclear how JRC has determined this 25 kg limit, which would still send heavier L-category vehicle batteries, for instance on motorcycles, tricycles or quadrimobiles into the electric vehicle battery category.
Benefits
JRC quotes several benefits in creating a separate LMT battery category. First of all, it would allow the inclusion of heavier batteries, “that would otherwise not fit in the collection infrastructure for portable batteries.” Secondly, JRC states that 70% of AfC by 2025 and 75% by 2030 will be a much more realistic target for LMT waste batteries. Changing to AfC will require a revision clause in the Commission’s proposal to adapt the common methodology parameters and potentially also the target level specifically for the new category. LEVA-EU believes that the AfC calculation methodology must be adapted to the lifespan of the various vehicles in the category. The lifespan of an e-scooter for instance is different from the lifespan of an electric bike. It will also require specific consideration for batteries which are not returned through this collection infrastructure. There will undoubtedly be some hoarding to be taken into account, as well as batteries which will be treated for re-use for instance. Furthermore, all vehicles excluded from the L-category are subject to the WEEE-Directive. It is quite likely that some batteries will not be removed from end-of-life vehicles.
Another benefit of JRC’s proposal is that the creation of a separate LMT battery category will allow for faster introduction of more collection points and will improve the handling and the safety attention for end-of-life batteries. And last but not least, JRC points out that the creation of a separate LMT category offers an additional possibility to adapt other than collection requirements, such as sustainability, safety and information requirements, “to the distinctive character of LMT batteries.” In doing so, JRC agrees with LEVA-EU’s request not to simply subject LEV batteries to the particularly extensive and strict requirements for electric vehicle batteries. Instead, the EU institutions should consult with the LEV-sector as to appropriate and adequate requirements. Ideally, the Commission should order new research into such requirements.
Confusion in Parliament
In the meantime, even before this JRC report was published, 3 parliamentary committees had started working on the original Commission proposal. Normally, only 1 parliamentary committee is responsible for a file. In this case, the work was entrusted to IMCO, ITRE and ENVI while TRAN was allowed to issue an opinion. Since, the IMCO and TRAN Rapporteurs and the ITRE committee have effectively proposed amendments. As a result, a particularly confusing situation has now arisen for LMT batteries, with diverging amendments for the same articles in the proposal. LEVA-EU will resume lobbying after the summer break to try to align all relevant parliamentary committees with JRC’s recommendations for LMT batteries.
Comments Off on Commission’s Battery Proposal is existential threat for LEV-market
LEVA-EU’s in-depth analysis of the Commission’s proposal for a new Battery Regulation shows no less than an existential threat to the EU market for light, electric vehicles. LEVA-EU has made proposals to the Commission for essential amendments.
The Commission has published a proposal for a new Battery Regulation in December last year. The proposal is aimed at improving the sustainability and safety of batteries throughout their entire life. Long-term sustainable batteries are key for the goals of the European Green Deal and contribute to the zero-pollution ambition set in it.
The Commission explicitly acknowledges the issues of batteries for light electric vehicles. They propose to categorise these batteries as portable batteries. However, the conditions set out for this categorisation are such that certain light, electric vehicles (LEV) will be prevented from coming on the market.
The idea is that sealed LEV-batteries of less than 5 kg will be considered portable batteries, but only on condition that they are used in wheeled vehicles with a seating position, with a motor of less than 750 W to be powered by the motor alone or by a combination of motor and human power.
This would mean, among other things, that one and the same battery becomes either portable or electric vehicle battery depending on the wattage of the motor. A speed pedelec in L1e-B with a 500W motor would have a portable battery. That exact same battery in a speed pedelec with a 750W motor becomes an electric vehicle battery. All batteries in e-scooters, e-monowheels, e-hoverboards and self-balancing vehicles, etc. will be electric vehicle batteries because they don’t have a seating position.
It is simply impossible for LEV-battery producers to comply with electric vehicle battery regulations. The requirements concerning carbon footprint declaration, technical documentation, registration, extended producer’s responsibility, electronic exchange of information, battery passport, collection targets, information on performance and durability and mandatory declarations of levels of recycled content, followed by mandatory levels of recycled content are simply unachievable. It is also very debatable whether these requirements are necessary and adequate for LEV-batteries.
Even if the manufacturer would be able to implement all this, it would have a huge impact on the price of the battery and therefore also on the vehicle. The battery already has an important share in the vehicle price. Further big increases will price the vehicles out of the market in favour of internal combustion engine (ICE) vehicles.
Another major issue is the fact that a lot of the responsibilities fall on the producer, who first puts the battery on the market in a member state. In a large majority of cases, that will be the vehicle producer or importer. Under electric vehicle battery rules, that producer will be charged with duties beyond his competence.
If the Commission pursues the proposal for LEVS, it will kill off all LEV-production involving electric vehicle batteries for lack of availability. This concerns electric motorcycles, electric quadricycles, electric mopeds, e-scooters, e-monowheels, e-hoverboards, self-balancing vehicles, L1e-A powered cycles with electric vehicle batteries, speed pedelecs with electric vehicle batteries, e-cargocycles with electric vehicle batteries. The only surviving market will be for e-cycles with pedal assistance up to 25 km – 250W. As a result, the transition from ICE-vehicles to LEVs will be reversed, all R&D made unnecessary and innovation made impossible.
LEVA-EU does agree that efforts are needed to improve the sustainability, longevity and recyclability of Li-Ion batteries for LEVs. However, these efforts need to be well-founded, proportionate and aimed at promoting LEVs, not at pushing them out of the market. LEVA-proposes to solve the issue as follows.
In the new Regulation, a separate battery category should be created for all LEVs in the scope of Regulation 168/2013, as well as for all LEVs excluded from this Regulation through Article 2.2. The Commission also needs to enter into a long-term dialogue with the LEV-sector. This will benefit legislation that is specifically adapted to LEV-batteries. The Commission should provide for and organise the necessary studies to analyse the market of LEV-batteries. The study results in combination with the above-mentioned dialogue should allow for adequate and proportionate measures for LEV-batteries.
And finally, the Commission should officially acknowledge LEVs in all EU battery-related policies. LEV-battery stakeholders should be involved in all initiatives aimed at furthering sustainable battery development and production both in and outside the EU. There are currently many EU battery-initiatives, involving investments worth billions. These are however fully focused on batteries for cars, vans and busses. Last year, at least 10 million LEVs have been sold in the EU, compared to only half a million battery electric vehicles (BEV). It is high time for the Commission to recognise that LEVs have a major stake in the field of batteries.
Comments Off on LEVA-EU Position on Review for Zero Emission Tailpipe Vehicles
LEVA-EU has published a position paper in which the trade association has developed an exhaustive argumentation for the introduction of the concept of Zero Tailpipe Emission Vehicle (ZEV) in Regulation 168/2013. The ZEV-concept covers all light, electric vehicles and allows for much simpler, more accurate and future-proof rules. LEVA-EU has submitted the paper to TRL in the framework of their on-going study for the European Commission.
LEVA-EU defines a Zero Tailpipe Emission Vehicle as “a powered vehicle equipped with a motor that does not produce harmful tailpipe emissions”. Next, LEVA-EU proposes to add an article to Regulation 168/2013 stating “This Regulation does not apply to Zero Tailpipe Emission Vehicles with a maximum design speed not exceeding 50 km/h;” Furthermore, LEVA-EU proposes to exclude all Zero Tailpipe Emission Vehicles from the Machinery Directive. As a result, this simple legal intervention would exclude all types of electric cycles, e-scooters, monowheels, e-hoverboards, self-balancing vehicles and any other Zero Tailpipe Emission Vehicle not yet mentioned explicitly in law today, from the current legal framework, which is totally inappropriate and inaccurate.
Instead, LEVA-EU proposes to transfer ZEVs into a new horizontal Vehicle Regulation. This European law would specify essential safety requirements to be complemented with harmonised standards and possibly, for certain ZEV-categories, type-approval procedures. In any case, LEVA-EU believes that the form of the legislative framework needs to be decided in consultation with the ZEV-sector.
1/2mv²
LEVA-EU’s proposal for new legislation is based on kinetic energy, which equals 1/2mv². LEVA-EU believes that vehicles developing similar levels of kinetic energy must be subject to similar rules. It is unjustifiable to submit vehicles with the same kinetic energy to completely different rules as is the case today.
As an example, a pedal assisted bike 25 km/h – 250W develops exactly the same kinetic energy as that same vehicle with for instance 300W. And yet, the first is excluded from type-approval, comes under the Machinery Directive and has the same status as a conventional bicycle in all Member States. The 300W edition is an L1e-A, needs type-approval and does not have a clear status in most Member States. The first one is selling by the millions, the second one is virtually non-existing.
Very simple categorisation
Following on to this principle of kinetic energy, LEVA-EU proposes a very simple categorisation based on speed and weight only. There would be a distinction between vehicles with a maximum speed of 25 or 30 km/h and vehicles with a maximum speed of 45 or 50 km/h. LEVA-EU insists that the limits must be set in consultation with the ZEV-sector. There may well be an argument for 30 and 50 km/h because this is in line with speed limits used by road management authorities. It would make it easier for ZEVs to go with the flow of the traffic, whilst today through their design they have slightly lower speed limits of 25 and 45. These have never been decided upon any scientific or other research. They were just copied from conventional mopeds.
LEVA-EU proposes to split up the two speed categories in low-weight and higher-weight vehicles. Again, the limits should be set in consultation with the ZEV-sector. The low weight and low-speed vehicles would be regulated by the provisions of the new, horizontal Vehicle Regulation in combination with harmonized standards. LEVA-EU points out that there are already a number of standards available and others in preparation. For the 3 other categories, LEVA-EU leaves the option open of Vehicle Regulation plus harmonized standards or specific type-approval. Again, the decision needs to be made in consultation with the ZEV-sector.
Call for consultation
Throughout the position paper, LEVA-EU really stands up for a better representation of and consultation with the ZEV-sector. Today, the forum for preliminary discussions on the corrections, amending and review of L-category type-approval legislation is the Motorcycle (sic) Working Group. This forum is dominated by internal combustion engine moped and -motorcycle experts, both among the Member State representatives and the stakeholders. LEVA-EU is the only stakeholder to exclusively represent ZEV-companies.
In the Motorcycle Working Group a number of stakeholders are fighting to keep the technical rules as they are. That is proof in itself of the extent to which these rules prevent the development and marketing of ZEVs. With that, the organizations totally deny the fact that new types of ZEVs are needed to address new types of users, to convince even more people to trade unsustainable mobility for sustainable mobility by means of ZEVs. Electric bicycles with a throttle for instance have the right to exist, for instance for people who are physically incapable of pedalling all the time, as needed with pedal assist only. In the case of carriage of goods and people, the obstruction caused by current regulations and the need for new concepts/solutions is even bigger. Because the voice of the ZEV-sector is drowned out by the voice of parties who consider ZEVs an existential threat, from which they must protect their business, the Commission has not (yet) entered into an in-depth dialogue with the ZEV-sector. LEVA-EU calls on the Commission to no longer postpone that consultation.
Regulate speed differently
LEVA-EU also proposes some fundamental changes to the terms of use for ZEVs. For instance, speed limits by design must no longer be used to regulate traffic. Just as is the case for all other vehicles (except conventional mopeds), traffic speed must be regulated by local speed limitations decided by traffic management authorities.
Some member states don’t have dedicated speed limits on cycle paths/cycling infrastructure. LEVA-EU believes that member states must impose maximum speed limits specifically on cycle paths, which need to be used in a smart way. These limits should still allow to achieve and not to hinder the potential of the ZEVs. For instance, on a separate wide, good quality path with low traffic, the speed limit should allow non-low speed ZEVs such as speed pedelecs to use their full potential. All ZEVs should then be given the option to use cycle paths provided they keep to the maximum speed and whilst observing potential local rules on dimension limits. If they want to go faster, they must go on the road, provided the speed limit there does not exceed the ZEV speed limit by design. Another example: in cycling streets a speed limit of 30 km/h or even lower may be imposed, whilst all ZEVs both low and non-low speed are allowed on condition that they keep to that local speed limit.
European harmonisation
Regulating speed through local speed limits rather than through the design of the vehicle, just as is the case for all other vehicles, will improve the access to different types of ZEVs and therefore reduce the desire for increasing the vehicle’s speed limit by tampering. It will also simplify the policing of speed limitations for ZEVs.
All ZEVs up to 5O km/h should be subject to the same traffic rules as bicycles, for instance allowed to ride in two directions in one-way streets for motorised traffic, allowed to turn right at traffic lights, allowed to use waiting areas in front of motorised traffic at traffic lights, allowed to ride in front of motorised traffic in “cycling streets” etc. Obviously, those facilities should only be granted if feasible. In this respect, it may be necessary to consider dimension restrictions for certain use. With that however, it is important to strive for a European harmonized approach so as not to create a new bottleneck that hampers free circulation of goods in the single market.
No more cycle paths
LEVA-EU also calls for renaming all infrastructure, now known as cycling infrastructure, such as cycle paths, cycle streets, cycle highways, cycle parking, etc. as ZEV infrastructure. Member states must not only rename the infrastructure, but they also need to redesign traffic signs, traffic pictograms, etc. to represent all ZEVs instead of bicycles only. This will improve cyclists’ and motorists’ perception of ZEVs. Today, cyclists often feel that the infrastructure is their exclusive territory and, when the infrastructure is scarce, they consider other ZEV-users as intruders. This results in irritation and in the worst case in conflicts. Motorists are not yet used to the fact that, today there are many more different light vehicles on the road than just bicycles. Renaming and resigning infrastructure may well contribute to raising their awareness of the changing traffic scene.
Member states must consult
Finally, the Commission must take an initiative aimed at organizing consultation between member states on terms of use for ZEVs. This will definitely contribute to raising awareness of member states on ZEVs as well as to exchanging best practice. That will in turn speed up the adaptation of traffic rules and road infrastructure to ZEVs and allow them to realize their full potential thus making a huge contribution to the objectives of the Green Deal.
LEVA-EU invites all ZEV-stakeholders to read the full position paper and to respond to it. You can find it here: https://bit.ly/36SrBwv
Let us know whether you agree with our proposals or whether you have ideas to further improve our proposals. Please send your reactions to LEVA-EU Manager Annick Roetyck, annick@leva-eu.com.
Overview of LEVA-EU’s proposal
Speed in the table below is the maximum speed at which the motor propels the vehicle with or without addition of muscular power
Maximum Weight
Maximum Speed
Technical Rules
Terms of use
Maximum limit to be determined in consultation with LEV-sector
25/30 km/h to be set in consultation with LEV-sector
Horizontal Vehicle Reg. + Harmonized standards
Identical to (e)-bikes – but no use of dedicated low-speed ZEV-infrastructure above specified width – no helmet obligation if more than 2 wheels and ROPS
Maximum limits above limit set in previous category to be determined in consultation with LEV-sector
25/30 km/h to be set in consultation with LEV-sector
Horizontal Vehicle Reg. + Harmonized standards or Specific Type-Approval for these vehicles
Identical to (e)-bikes but no use of dedicated low-speed ZEV-infrastructure above specified width – no helmet obligation if more than 2 wheels and ROPS
Maximum limit to be determined in consultation with LEV-sector
45/50 km/h to be set in consultation with LEV-sector
Horizontal Vehicle Reg. + Harmonized standards or Specific Type-Approval for these vehicles
Possibility of (e)bike helmet – use of LEV-dedicated infrastructure only up to maximum speed as decided by local traffic management authorities – specific theoretic driving licence exam – if practical exam than specific for and with vehicle concerned
Maximum limits above limit set in previous category limits to be determined in consultation with LEV-sector
45/50 km/h to be set in consultation with LEV-sector
Horizontal Vehicle Reg. + Harmonized standards or Specific Type-Approval for these vehicles
no helmet if ROPS – use of LEV-dedicated infrastructure only up to maximum speed as decided by local traffic management authorities and under specific width – specific theoretic driving licence exam – if practical exam than specific for and with vehicle concerned
Vehicle type and speed
Kinetic Energy in Kilojoules, assuming rider weight 70 kg
Human running without vehicle, 25 km/h
1.69 KJ
Very Lightweight Bicycle or Electric Vehicle, 10kg riding at 25km/h
1.93 KJ
L1e-A powered cycle 500W, 25kg, e.g. throttle up to 25 km/h, riding at 25km/h
2.29 KJ
Electrically assisted cycle 250W, 25 kg, assistance up to 25 km/h riding at 25km/h
2.29 KJ
Electrically assisted cycle, 25 kg, assistance up to 25 km/h, riding at 30 km/h
Comments Off on LEVA-EU wants future-proof Driving Licence Directive
The European Commission is currently reviewing the Driving Licence Directive. LEVA-EU is seizing the opportunity to call for the exclusion of all vehicles with a maximum speed of 30 km/h from the driving licence obligation. LEVA-EU also calls on the Commission to align the Driving Licence Directive with Regulation 168/2013 and to provide for accurate measures for electric vehicles.
The EU rules on driving licences have been progressively set up through three Directives. The first was introduced in December 1981, followed by the second Directive of July 1991. Directive 2006/126/EC on driving licences, also known as the 3rd Driving Licence Directive, was adopted in 2006 and became applicable in January 2013. It has been amended in nine instances.
The 3rd Directive aims at harmonising the rules on driving licences in order to improve road safety, to facilitate the freedom of movement for citizens moving inside the Union and to reduce the possibility of fraud.
Further harmonization
Firstly, it prescribes new rules for replacing the different driving licence formats circulating in the EU by a standard European credit card format characterized by stricter security protection features. All existing paper driving licences in circulation must be changed to the new format by 2033 at the latest.
The 3rd Directive also introduced harmonised validity periods for licences, further harmonization of categories, reinforcement of progressive access to categories (age, dimensions) and harmonised minimum requirements for driving examiners. Furthermore, it established an EU network for the exchange of driving licence information.
The Directive has never been evaluated since the start of its application. Moreover, Article 14 of the Directive calls for a review of its impact on road safety.
In view of the above, the Commission has started assessing how well the Directive has performed since its adoption and whether it continues to deliver in terms of effectiveness, efficiency, relevance, coherence and EU added value.
Joined up thinking
A public consultation has recently taken place in which LEVA-EU has submitted its position on the review. LEVA-EU acknowledges that road safety may be improved by optimizing the requirements of the Driving Licence Directive (DLD). However, the association believes that it is essential for such effort to be combined with freeing up space for light, electric vehicles (LEVs), considerably improving road infrastructure for LEVs, further improving technological safety solutions on cars, vans and trucks and an EU-wide introduction of a 30 km/h speed limit in urban areas.
In an appeal for joined up thinking, LEVA-EU also points out that this review must take into account the on-going review of Regulation 168/2013 for the benefit of LEVs as well as the Commission’s considerations on terms of use for LEVs. All review activities need to linked in order to make the Driving Licence Directive future-proof.
Exclusion 30 km/h
LEVA-EU further believes it is essential not to make any vehicles with a maximum motor speed of 30 km/h subject to driving licence requirements. The maximum speed limit in current type-approval and driving licence legislation of 25 km/h should be increased to 30 km/h. This limit has become widely introduced in urban areas. An alignment of the speed limit for the vehicles is necessary to allow them to go safely with the traffic flow.
Light electric vehicles with a maximum speed of 30 km/h can have a major contribution to making mobility sustainable, because they allow to swap polluting cars and vans for LEVS, especially over shorter distances. The introduction of a driving licence for these vehicles would have a dramatic impact on their accessibility and current ease of use. These vehicles are mostly used in areas with a 30 km/h speed limit. Where speed limits are higher, they very often are/or should be able to use separate lanes. As a result, these vehicles mainly operate in fairly safe traffic conditions, which justifies the exclusion from a driving licence. We believe that the 30 km/h speed limit, improved infrastructure, increased space and traffic codes which make motorized traffic subordinate to slow traffic modes in 30 km/h zones, will produce a much bigger safety dividend than a driving licence. Furthermore, sharing systems are becoming increasingly important and also require ease of accessibility and use. A driving licence would be a hindering factor here too without producing considerable safety benefits.
Provisions for electric vehicles
Since Regulation 16/8/2013 came about after the introduction of the current DLD, the two pieces of legislation are disjointed. It is essential to align them and to use for L-vehicles the same categories.
However, it should be taken into account that some categories may accommodate very different vehicles. The reviewed DLD should provide for those differences. One of the most telling examples is category L1e-B “mopeds”, which no longer stands exclusively for conventional mopeds but also for so-called speed pedelecs (with motor assistance up to max. 45 km/h) and potentially other electric bicycle-like vehicles. The Directive must ensure that if Member States impose tests for these vehicles, the tests are specifically designed for these vehicles. Their characteristics and behaviour are very different from conventional mopeds. Also, it is imperative that such tests are carried out with the vehicles concerned and not with conventional mopeds.
The Directive must be amended to include provisions for adapted tests with electric vehicles in the L-category. It is also important to take into account that the concept of “professional driver” is subject to major changes due to change/growth in deliveries and introduction of e-vehicles. Finally, the Directive must be amended to improve freedom of movement through mutual recognition of equivalence (B-AM, B-A1 and B-tricycle) between Member States with the same equivalence rules.
The Commission’s proposal for the review is announced for the fourth quarter of 2020.
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