Tag Archive: dumping

  1. EP INTA Vice-Chair Kathleen Van Brempt Visits Ellio: LEV Manufacturers Confront Inadequate EU Regulation and Anti-Dumping Measures

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    Just before the end of last year, Belgian Member of the European Parliament Kathleen Van Brempt paid an extensive visit to Ellio, a Belgian member of LEVA-EU. Kathleen Van Brempt is part of the S&D Group, serves as Vice-Chair of the Committee on International Trade, and is a substitute member of the Committee on Transport and Tourism. Ellio is a Belgian manufacturer of speed pedelecs, which are assembled at the custom-work company Bewel in Tessenderlo (B). A number of other LEVA-EU members from Belgium, the Netherlands, and France also took part in the visit.

    The two main topics of discussion during this visit were the inadequate technical regulations for LEVs in general and for speed pedelecs in particular, and the trade defence measures against China relating to electric bicycles.

    Despite a preparatory meeting between LEVA-EU and Kathleen Van Brempt, she listened with great attention—and in particular with considerable astonishment—to the accounts from Ellio and the other participants regarding inadequate technical regulations for light electric vehicles in the EU, as well as the damage caused, in particular, by the anti-dumping duties on bicycle components from China to European assemblers of electric bicycles. Several participants in the meeting are currently involved in legal proceedings in which they face exceptionally heavy fines and possibly even prison sentences.

    Ellio is not involved in any legal proceedings but likewise experiences systematic problems with Belgian customs when (attempting) to import bicycle components for use in their speed pedelecs. The highly complex administration resulting from their end-use authorisation regularly leads to fines—not because they have violated anti-dumping legislation, but purely because they have not applied the extremely complex administrative rules correctly. The situation is so burdensome for the company that they recently decided simply to pay the 48.5% anti-dumping duty on the import of front forks from China.

    This meeting took place while Kathleen Van Brempt was awaiting a response from the European Commission to her parliamentary question on the trade defence measures against China in our sector. That question consisted of three parts:

    • How the Commission intends to resolve the legal uncertainty and disproportionate burdens faced by small and medium-sized enterprises in the LEV sector?
    • How it justifies extending anti-dumping duties on bicycle components from China despite the sector’s reliance on Chinese supply chains?
    • How it plans to align its trade defence measures with the EU’s industrial strategy to enhance competitiveness, innovation, and LEV production?

    In his uninformative response, Maroš Šefčovič, Commissioner for Trade, claims that everything is properly arranged and running smoothly. According to him, the anti-circumvention measures on bicycle parts from China were introduced to tackle circumvention practices by Chinese exporters, and everything possible has been done to protect European assemblers through the exemption scheme and the end-use authorisation.

    “The measures on bicycles (both conventional and electric) have proven efficient and allowed the EU industry to prosper,” according to the Commissioner. It is particularly shocking to read this response, which completely disregards the financial and personal suffering that dozens of companies in Europe have been enduring for years. From the testimonies that Ms Van Brempt heard directly from the affected entrepreneurs, it was clear that the measures are anything but efficient and have certainly not allowed this part of the industry to prosper.

    Below you will find a brief summary of the testimony given by Tomas Keppens, Co-Founder and CTO of Ellio, during the meeting with Ms Van Brempt.

    Stakeholders who wish to provide testimony on challenges related to the import of bicycle components from China for the assembly of electric cycles, or on issues concerning type approval for speed pedelecs, are invited to contact LEVA-EU at annick@leva-eu.com. Contributions are welcome irrespective of LEVA-EU membership status.

    The stories about anti-dumping duties on bicycle components from China and about inadequate technical regulations will undoubtedly continue this year. We will keep you informed.

    The Key Regulatory and Administrative Challenges Faced by Ellio

    Ellio is a Belgian innovator in the speed pedelec segment, developing intuitive, high-performance drivetrains designed. Their speed pedelecs are developed, and assembled in Belgium, including through social employment initiatives. Ellio’s ambition is to lower the threshold for consumers to step into “fast” cycling as a valuable and credible mobility alternative.

    Despite operating in what should be a favourable environment, Ellio encounters quite a number of structural regulatory and administrative obstacles that disproportionately affect innovative European SMEs.

    Belgium as a Testbed for New Mobility – In Theory

    Belgium, and Flanders in particular, is often cited as an ideal testing ground for speed pedelecs. This is due to three enabling pillars:

    • A suitable regulatory framework for the use of speed pedelec
    • Improving cycling infrastructur
    • Strong fiscal and financial incentives for sustainable mobility

      However, for SME manufacturers such as Ellio, policy design and implementation often also create barriers rather than support, especially in the domains of customs, anti-dumping measures, and vehicle type approval.

      Customs: Legal Certainty at High Administrative Cost

      Ellio is importing certain bicycle components from China. For this import, it has obtained an end-use authorisation. Nevertheless, the company experiences a high level of scrutiny from Belgian customs authorities. While oversight is understandable, enforcement is often perceived as focusing strictly on the letter of the law rather than risk-based compliance.

      • Even when there is no indication of fraud, minor human errors trigger inspections and fines.
      • The solution proposed by the customs to facilitate smoother operations, i.e a request for a Binding Tariff Information (BTI) decision, would have offered legal certainty but came with significant downsides:
        • Lengthy procedures
        • Extremely time-consuming discussions with very rigid and therefore unworkable interpretations by the customs, for instance on what constitutes a “brake set”
        • Disproportionate cost and effort for SMEs

      In practice, this creates a situation where regulatory complexity fuels dependency on external consultants, effectively shifting resources away from innovation.

      Anti-Dumping Rules: Disproportionate Burden on SMEs

      Anti-dumping measures on bicycle components imported from China further compound administrative pressure:

      • Use of the special end-use authorisation regime requires extensive documentation and is highly error-prone.
      • Certain components, such as braking systems, have proven unworkable under this regime and are no longer sourced by Ellio that way.
      • Other components, such as suspension forks, are imported with the payment of 48.5% in anti-dumping duties, increasing costs without clear policy justification in the context of European assembly and innovation.

      Type Approval: A Framework Designed for PTW Not Bicycles

      One of the most significant challenges lies in vehicle type approval for L1e-B speed pedelecs.

      Structural mismatch with the bicycle industry

      The current system reflects mopeds and motorcycles, i.e. Powered Twowheelers (PTW) logic rather than cycling reality:

      • In PTW manufacturing, OEMs hold deep in-house regulatory expertise and tightly control suppliers.
      • In the bicycle sector, critical system knowledge resides with suppliers (e.g. drivetrain manufacturers), not OEMs.
      • Training and system certification are provided by suppliers, not by bike manufacturers themselves.

      For SMEs with small production runs, the cost of full vehicle type approval cannot be amortised in the same way as in the automotive sector and PTW sector which has much bigger series and higher prices.

      Excessive variants and administrative overhead

      Unlike PTWs, bicycles have no fixed “bodywork” which results in one size fits all. Rider position varies through:

      • Frame size
      • Handlebar configuration
      • Saddle height

      This leads to a multiplication of types/variants, each carrying very considerable administrative overhead and additional cost, despite differences having no meaningful impact on safety. Paradoxically, some mandatory requirements (e.g. adjustable saddles) exclude certain innovative configurations altogether.

      Safety and Consumer Protection Gaps

      Ironically, compliance with existing legislation does not always guarantee adequate consumer protection:

      • Type-approval legislation for speed pedelecs require testing of frames and forks according to a conventional bicycle safety standard ISO 4210:2014, which is repealed and only partially addresses critical elements such as fork strength.
      • The resulting safety requirements int type-approval are totally inadequate for speed pedelecs, creating a regulatory blind spot.

      At the same time, the few type-approval services in the EU that offer approval of speed pedelecs, face capacity constraints, leading to long approval timelines, uncertainty for manufacturers and ensuing additional costs.

      The 4:1 Assistance Rule: Technically Unrealistic

      The requirement that rider input must correspond to a fixed 4:1 assistance ratio is particularly problematic:

      • Maintaining 45 km/h under this rule is only feasible for trained riders, in ideal conditions, with a sporty riding posture.
      • Everyday use cases—upright posture, hills, headwind, commuting without excessive physical strain—are effectively excluded.

      In PTW terms, this would be equivalent to limiting a vehicle’s maximum speed based on the driver’s physical strength and seat position—an approach that would be unthinkable.

      Despite the Commission’s explicit confirmation that this factor four is not a legal requirement but an option, all approval service in the EU apply it is a legal requirement.

      Conclusion

      Ellio’s experience illustrates a broader systemic issue: regulatory frameworks built for large-scale PTW production do not translate well to innovative, small-series European light electric vehicle manufacturers. Addressing these mismatches is essential if Europe wants to remain competitive in sustainable, human-centred and light electric mobility innovation.

    1. LEVA-EU: Driving the Future of Light Electric Mobility in Europe

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      Over the past year—and indeed over many years—LEVA-EU and its members have worked together to fundamentally strengthen the position of light electric vehicles (LEVs) in Europe. Through focused advocacy, deep technical expertise, and sustained engagement with EU institutions and standardisation bodies, LEVA-EU has ensured that the voice of the LEV industry is heard where it matters most.

      As the only European association fully dedicated to light electric vehicles in all their diversity, LEVA-EU plays a critical role in protecting the sector’s interests, shaping regulatory frameworks, and creating the conditions for innovation and fair competition. Our achievements to date, and our ambitious plans for the years ahead, demonstrate both the impact of our work and the value of being part of a strong, united industry platform.

      Our Strategic Priorities for 2026

      Looking ahead to 2026, LEVA-EU is further strengthening its capacity to support members and defend the future of the LEV sector.

      From 1 January 2026, we will welcome two new colleagues, Laurent Guérisse and Luca Destro, who will focus specifically on member recruitment and enhanced membership services. This expansion marks the next step in the continued growth of the LEVA-EU team, allowing us to deliver even more targeted support while intensifying our advocacy at both EU and national level.

      A central priority for 2026 will be the firm opposition to regulatory initiatives that threaten the viability of light electric vehicles. Proposals such as peak power limits, restrictive support ratios, or arbitrary methods for measuring maximum continuous rated power risk stifling innovation, distorting markets, and undermining the competitiveness of European LEV manufacturers—particularly in segments such as electric cargo cycles and advanced electric bicycles. LEVA-EU will continue to challenge these approaches with clear technical arguments and evidence-based policy input.

      In parallel, we are advocating for the inclusion of L5, L6 and L7 light electric vehicles in policy measures currently aimed exclusively at electric cars. These vehicles are a vital part of the sustainable mobility ecosystem and must be recognised as such in incentive schemes and deployment strategies.

      LEVA-EU will also maintain pressure on the European Commission to move towards a dedicated LEV Regulation—one that reflects the technical realities and market diversity of the sector—and to establish a dedicated consultation platform for LEV stakeholders. This is essential to ensure that future legislation is developed with, rather than about, the industry.

      Additional priorities for 2026 include:

      • Further development of our internal Battery Working Group to support members on battery safety, compliance, and waste management.
      • Continued opposition to anti-dumping duties on components imported from China for the assembly of electric bicycles in Europe.
      • Ongoing monitoring and advocacy to keep EU and national policies aligned with the interests of the LEV sector.
      • Comprehensive legislative intelligence and hands-on guidance for our 65+ members to ensure regulatory compliance across Europe.

      Delivering Tangible Results for the LEV Industry

      LEVA-EU’s credibility is built on results. In recent years, our work has delivered concrete outcomes that benefit the entire sector.

      Embedding Light Electric Mobility in EU Urban Policy

      Within the European Commission’s Expert Group on Urban Mobility, LEVA-EU successfully secured the formal recognition of “light electric mobility” alongside walking and cycling in the Group’s Recommendations for Urban Mobility Policy. Crucially, these recommendations now explicitly call on the European Commission for harmonised technical legislation and dedicated standards for LEVs, developed in close consultation with the sector itself.

      Progress Towards a Dedicated LEV Regulatory Framework

      LEVA-EU has consistently pushed back against inappropriate legislative frameworks, working to exclude light electric vehicles from both the Machinery Directive/Regulation and Regulation (EU) 168/2013. At the same time, we continue to press the Commission to propose a dedicated LEV Regulation tailored to the specific characteristics of these vehicles.

      Shaping Standards That Reflect Market Reality

      Our association has played a decisive role in standardisation:

      • Contributing extensively to the EN 17860 standards for electric cargo cycles and trailers, now fully published.
      • Ensuring that Series Hybrid (SH) systems are properly addressed through close collaboration with members.
      • Actively participating in the systematic review of EN 15194 for EPACs, with continued advocacy for the inclusion of SH systems.
      • Representing LEV interests within CENELEC TC21X and successfully advocating within IEC TC125 for the creation of a joint Working Group.
      • Supporting the international revision of EN 50604-1+A1 to better align battery safety requirements with LEV applications.
      • Participating in CEN TC354-WG4 for the review of EN 17826.

      Building Awareness and Capacity on Standardisation

      Through close cooperation with Small Business Standards (SBS), LEVA-EU continuously informs members—particularly SMEs—about standardisation developments and their implications. Our regularly updated Briefing on Standardisation for Light Electric Vehicles has become a key reference point for the industry.

      Influencing Battery and Waste Legislation

      LEVA-EU is actively involved in the European Commission’s Waste Expert Group, contributing directly to the Implementing Acts under the new Battery Regulation. To translate these complex requirements into practical guidance, we have also established a dedicated internal working group focused on battery compliance and EN 50604-related challenges.

      Defending Fair Trade Conditions

      LEVA-EU has been at the forefront of engagement in EU anti-dumping and anti-circumvention cases affecting bicycle components from China and therefore also assembly of electric cycles in the EU. We have supported companies unfairly targeted by measures that fail to reflect the realities of the LEV supply chain, clearly communicating to EU institutions the structural lack of alternative component sourcing and the impracticality of certain origin and assembly requirements. Our ongoing advocacy seeks trade defence measures that protect European industry without causing unjustified disruption to the market.

      Standing Firm Against Restrictive National Frameworks

      At national level, LEVA-EU has actively opposed initiatives such as the proposed Dutch LEV framework, continuing to petition for its withdrawal due to its disproportionate and damaging impact on the sector.

      Why Membership Matters

      LEVA-EU’s work is made possible by its members. By joining and supporting the association, companies ensure that the LEV industry speaks with one strong, informed, and credible voice in Brussels and beyond. Membership means direct access to regulatory intelligence, technical expertise, and representation at the highest policy and standardisation levels—resources that no individual company could realistically replicate alone.

      As the LEV sector continues to grow in strategic importance for Europe’s mobility transition, the need for effective, professional representation has never been greater. LEVA-EU stands ready to meet that challenge—together with its members.

      Join us in shaping the future of light electric mobility in Europe.

      For more details on LEVA-EU membership, contact Laurent Guérisse, laurent@leva-eu.com, or if your company is in Italy, contact Luca Destra, luca@leva-eu.com.

    2. UK Revokes Trade Defence Measures on Chinese E-Bikes

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      The UK Secretary of State for Business and Trade has followed the recommendations of the Trade Remedies Authority (TRA) to revoke the anti-dumping and countervailing duties on electric bicycles from China. Despite finding that dumping and injury to UK industry would likely recur if duties were removed, the TRA ruled that continuing the measure does not meet the UK’s Economic Interest Test (EIT).

      Key Findings:

      • Dumping Likely to Continue: The TRA determined that Chinese e-bike manufacturers have significant production capacity and could resume exporting e-bikes to the UK at unfairly low prices if duties were lifted.
      • Potential Harm to UK Industry: The review found that without trade protections, UK producers—primarily Brompton—could suffer from reduced sales and profitability due to increased price competition from Chinese imports. TRA therefore proposed to maintain the trade defence measures on electric folding bikes only.
      • Economic Interest Test Not Met: Despite the risk of injury to UK manufacturers, the TRA found that the overall economic impact of maintaining the duty—such as higher costs for businesses and consumers—outweighed the benefits of protecting domestic producers.

      Economic Interest Test (EIT): Why It Was Not Met

      The Economic Interest Test (EIT) is a requirement under UK trade remedies law, assessing whether continuing an anti-dumping measure serves the overall economic interest of the UK. It considers the impact on:

      1. UK Producers – Would they suffer significant harm if the measure were removed?
      2. UK Importers and Retailers – Would they face additional costs or restrictions?
      3. Consumers – Would they pay higher prices due to duties?
      4. The Wider UK Economy – Would the measure benefit or hinder economic growth?

      The TRA concluded that:

      • The economic harm to UK businesses and consumers was disproportionate to the benefits of protecting UK producers.
      • Retailers and importers strongly opposed the duties, arguing that they raised costs and restricted supply.
      • Consumers would benefit from lower prices if duties were removed, boosting the UK e-bike market and supporting sustainable transport goals.
      • The UK e-bike industry lacks sufficient domestic production to justify long-term protection, as over 90% of e-bikes are imported.
      • While the UK producer Brompton represents a major share of domestic production, its focus on high-end folding e-bikes meant that broader protection for all e-bikes was not justified.

      On overall welfare costs, TRA concluded: “Overall, extending the existing measure is very likely to lead to a significant overall welfare loss of between £1.7m to £79.0m per year. The average impact across all scenarios is £31.1m per year. The highest benefits for UK producers occur in the scenarios with the highest costs to importers/retailers and consumers, and there are no scenarios in which extending the measure would have a positive impact.“

      TRA also estimated that extending the duties could result in 18,000 fewer e-bikes being purchased per year. This would have a negative impact on switching to walking and cycling for shorter journeys and therefore also on efforts to reduce greenhouse gas emissions.

      The EU doesn’t have an economic impact test in its trade defence legislation. It has the so-called community interest test, which focuses primarily on the interest of the so-called EU industry, whilst having little to no consideration for consumers and EU businesses harmed by the measures. As a result, trade defence measures are maintained if they protect EU producers, as happened with the recent renewal of the measures against e-bikes from China in Europe.

      The full impact of this decision on the UK market remains to be seen. However, one key concern may be that the UK has significantly fewer technical regulations to ensure the import of high-quality and safe products. For example, the UK has no counterpart for our Battery Regulation and the problem of fires caused by batteries seems to be more serious there than on the continent. While on the other hand, the EU does have laws to prevent illegal and unsafe imports, enforcement is inadequate. Strengthening enforcement would be a far more effective and efficient solution than relying on perpetual trade defence measures that ultimately harm European businesses.

      Another critical takeaway from this case is that EU trade defence measures are designed solely to protect the so-called “Community Industry“, making them inherently protectionist and self-sustaining. If Europe were to revise its community interest test following the UK example, the approach to trade defence would likely be much more balanced. Current EU trade remedies on conventional bikes, e-bikes, and especially bike components are totally not aligned with the broader interests of society, and this case highlights the need for a more holistic evaluation of their impact.

      In any case, since 7 February 2025 there are no more trade defence measures against e-bikes imported from China in the UK. An exception has been made for electric folding bikes, a concession mainly to Brompton. The measures for electric folding bikes are maintained. Importers of electric bikes that cannot be folded must enter the additional code 8100 on the import declaration.

      It will be interesting to see the outcome of the British review of the measures on bicycles and especially on essential bicycle components from China. It already seems very unlikely that these measures would pass the economic interest test.

    3. LEVA-EU Calls on European Union to Review Community Interest Test in EU Trade Defence Measures

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      LEVA-EU, the leading trade association advocating for the light electric vehicle (LEV) sector, is calling on the European Commission to review the Community interest test in EU trade defence measures, following the example of the UK’s economic interest test implemented post Brexit.

      This call comes as concerns persist that the Community interest test, in its current form, is overly focused on protecting EU producers, often neglecting the broader impact on importing and other businesses, retailers, and consumers—particularly regarding finished consumer products. These concerns were first recognised by the European Commission in its 2006 communication on trade defence instruments, which was meant to initiate a dialogue on the issue. Unfortunately, that dialogue did not lead to any meaningful reform. LEVA-EU believes it is now time to revive that discussion and reassess the role of the Community interest test in shaping EU trade policy.

      “The European Commission itself raised the need for a broader approach to trade defence measures almost 20 years ago,” said Annick Roetynck, Managing Director at LEVA-EU. “However, no concrete results followed, and the concerns identified in 2006 remain just as relevant today. The introduction of the economic interest test in the UK demonstrates how trade defence measures can be assessed in a more balanced and transparent way. The EU should take this as an opportunity to revisit and improve its own approach.”

      Under the current EU framework, trade defence measures such as anti-dumping and countervailing duties are primarily designed to safeguard domestic manufacturers against unfair competition. However, the Community interest test, which is meant to ensure that such measures also align with the broader interests of the EU economy, is often applied in a way that prioritises the interests of EU producers over those of the wider market.

      The UK’s economic interest test was applied in the review that resulted in the recent decision to revoke measures against e-bike imports from China. The Trade Remedies Authority concluded: “Overall, extending the existing measure is very likely to lead to a significant overall welfare loss of between £1.7m to £79.0m per year. The average impact across all scenarios is £31.1m per year. The highest benefits for UK producers occur in the scenarios with the highest costs to importers/retailers and consumers, and there are no scenarios in which extending the measure would have a positive impact.”

      This economic interest test provides a valuable example of how trade measures can be assessed with greater consideration for their impact on the entire supply chain, including importers, distributors, retailers, and consumers. The outcome of that assessment clearly shows that similar concerns should be addressed in the EU, particularly in relation to trade defence measures affecting bicycles, e-bikes, and especially essential bicycle components from China.

      Annick Roetynck continues: “We urge the European Commission to reassess the Community interest test in light of the UK’s approach and to restart the discussion it initiated in 2006. The EU must ensure that its trade defence instruments are applied in a way that truly reflects the interests of the entire market, rather than disproportionately favouring one group of stakeholders.”

      LEVA-EU will continue to engage with policymakers, industry stakeholders, and trade experts to push for this much-needed review of EU trade defence policy.

    4. LEVA-EU Calls for Shift from Trade Defense to Strengthened Market Surveillance and Removal of Duties on Bike Components

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      The European Commission has completed its expiry review of the anti-dumping and countervailing measures against imports of electric bicycles from China. As widely expected, the Commission proposes to extend the measures for another five years. Their investigation concluded that “the repeal of the measures would in all likelihood result in a significant increase of dumped imports from the PRC at injurious price levels.” However, LEVA-EU is convinced that these trade defense measures encourage the import of extremely cheap electric bicycles from China that do not comply with technical regulations. These substandard products have already caused several accidents, including at least one fatality.

      According to the Commission’s investigation, the Union Industry experienced a significant recovery between 2020 and 2022, with all macro- and microeconomic indicators trending positively during that period. However, during the review investigation period from January 1 to December 31, 2023, the situation suddenly deteriorated again. The Commission acknowledges this was due to overstocking during COVID-19 and to the sudden economic shift with high energy costs and inflation. The Commission believes that the Union Industry in these circumstances needs further protection, given the likelihood of recurrence of injury from Chinese imports. They therefore propose to extend the measures for another five years.

      The Commission also underscores China’s substantial production capacity and the EU market’s attractiveness. They state: “The Chinese exporting producers exported to their main third markets at prices significantly below the average sales prices of the Union producers on the Union market during the review investigation period. Therefore, exporting to the Union is potentially much more attractive for Chinese exporters. Consequently, it can be reasonably expected that, should the measures be repealed, Chinese exporting producers would start to export high volumes of the product under review to the Union.” This raises the question of which other main third markets these might be and at what prices Chinese e-bikes are sold there. E-bikes imported from China into the EU during the review investigation period were already reportedly offered at remarkably low prices, ranging between €210 and €650, according to the Commission.

      This finding puts the finger on the wound. The trade defense measures have driven serious Chinese companies with long-term ambitions for the European market, out of China and toward Europe and Taiwan. Those still producing electric bicycles in China for the European market can only target the lowest price segment. With trade defense measures adding up to almost 80% to import prices, competing in the mid and high segments in Europe is unfeasible.

      This raises further questions about how electric bicycles priced between €210 and €650 can meet Europe’s technical regulations. How can an electric bicycle be placed on the market at that price carrying a CE label, proving compliance with Machinery, EMC, and RoHS directives? How can a company for such low-cost products afford EN 15194- and EMC-testing, an authorised representative in the EU, keeping a technical file, or organising the collection of end-of-life batteries and vehicles? How can it prepare for the upcoming implementation of the highly challenging Battery Regulation?

      While it might barely be possible for bicycles priced at €650, it is undoubtedly impossible for those priced below €650. It might work for very large-scale production, but even that is questionable, as only 220,914 electric bicycles were imported from China in 2023, representing a 4.4% market share.

      This situation supports the view that the trade defense measures are not designed to stop cheap Chinese imports but rather to prevent Chinese manufacturers from entering the mid- and high-end segments. This approach has worked effectively for conventional bicycles for the past 31 years.

      Moreover, the measures have nearly eliminated the possibility of importing acceptable-quality electric bicycles from China. How many of the 220,914 bicycles imported in 2023 complied with European technical regulations remains a pressing question. This issue became particularly urgent this year with the so-called fat bike problem in the Netherlands. Public opinion was inflamed by the large number of “fat” e-bikes that assisted at speeds exceeding 25 km/h.

      It took considerable time before the Dutch government acted, inspecting e-bikes from suppliers for compliance with European technical regulations. This resulted in the confiscation of thousands of e-bikes, but unfortunately, this measure came too late to prevent at least one traffic fatality. The issue is not confined to the Netherlands; similar illegal electric bicycles can be found in all other EU member states, often sold in large quantities via online platforms.

      Aside from the question of compliance with European technical regulations, there is also the issue of potential circumvention of the trade defense measures. Under HS code 8711 60 90 90, several million vehicles are imported into the EU annually. How many of these are intentionally misclassified electric bicycles to evade the measures? Meanwhile, customs authorities seem much more focused on inspecting and penalising European assemblers for potential violations of the rules on bicycle components.

      LEVA-EU urges the Commission to shift its focus from Trade Defense Measures (TDM) to strengthening market surveillance mechanisms. Currently, excessive resources and efforts are allocated to TDM, while there is a significant shortfall in effective market surveillance regarding European technical legislation. Robust market surveillance is the only way to address the growing influx of low-quality products that often fail to comply with legal obligations.

      The Commission is also still reviewing dumping duties on conventional bicycles from China. These rights have been extended to some essential bicycle parts. Although these components are exempt from dumping duties when used in e-bike assembly, the exemption process is overly complex, causing major difficulties for assemblers. In addition, customs accuses numerous companies that import parts for electric bicycles of circumventing the measures against electric bicycles from China. Moreover, European production of these parts is far from sufficient to meet demand.

      Because of all these major problems, LEVA-EU calls on the Commission to take the parts into account in the review of the measures against conventional bicycles and, after 27 years, to finally put an end to the duties on those parts from China. This will remove major obstacles for many electric bicycle assemblers in Europe, and enable them to expand their business, thus fostering growth in the sector.

      LEVA-EU is currently carrying out a survey on the dumping duties on bicycle components. If your company assembles e-bikes in the EU, we would very much appreciate you participation in this survey, which is here: https://www.surveymonkey.com/r/LEVA-EU-Dumping-Survey

    5. LEVA-EU Invites European E-Bike Assemblers to Share Insights on Anti-Dumping Duties in New Survey

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      LEVA-EU is inviting European e-bike manufacturers and assemblers to participate in a survey designed to assess the impact of European Union (EU) anti-dumping duties on bicycle components imported from China. The survey seeks to gather perspectives directly from companies on how these duties affect their business operations, competitiveness, and the overall European e-bike market.

      The survey is here: https://www.surveymonkey.com/r/LEVA-EU-Dumping-Survey

      Background

      The EU introduced anti-dumping duties on conventional bicycles from China in 1993, later extending these duties in 1997 to essential bicycle components, impacting both conventional and e-bike assemblers. The European Commission is currently reviewing these duties, providing an opportunity for industry stakeholders to share their perspectives on how these tariffs influence their operations and growth potential within the European market.

      LEVA-EU has consistently highlighted that these duties impose additional costs and sourcing limitations for e-bike manufacturers and assemblers, particularly affecting small and medium-sized enterprises (SMEs). The organisation advocates for a reassessment of these duties to support sustainable growth in the sector. You can read more about LEVA-EU’s position on this issue here.

      Why Your Input Matters

      The European e-bike market has been growing rapidly, spurred by rising interest in eco-friendly transportation and urban mobility solutions. However, the anti-dumping duties on Chinese components present challenges for many European manufacturers and assemblers. This survey aims to collect feedback on how these duties affect manufacturers and assemblers across various areas, including:

      • Production Costs: Higher tariffs can increase component costs, affecting both profitability and pricing structures.
      • Supply Chain Flexibility: Restrictions on affordable components from China may challenge assemblers, particularly those with fewer supplier options.
      • Competitiveness in the EU Market: With increased competition, maintaining cost-effective and efficient production is critical for e-bike companies of all sizes.

      Survey responses will help LEVA-EU gather data to better understand the needs of European manufacturers and assemblers. The findings will inform LEVA-EU’s ongoing policy discussions with the European Commission in relation to the review of these duties.

      Survey Details

      This survey, which takes around 5–10 minutes to complete, addresses various topics such as company size, sourcing practices, challenges related to anti-dumping duties, and policy perspectives. The survey also includes questions on exemptions or end-use authorizations companies may use to reduce duty-related costs.

      Key areas of feedback include:

      • The impact of anti-dumping duties on business operations
      • Challenges in obtaining exemptions or authorizations
      • Opinions on the potential benefits of adjusting/removing these duties

      How to Participate

      The survey is here: https://www.surveymonkey.com/r/LEVA-EU-Dumping-Survey

      Participation in this survey allows e-bike manufacturers and assemblers to provide essential feedback that could shape future trade policies. This effort aims to ensure that the needs of the industry are well-represented in upcoming discussions.

      For questions or more information, please contact LEVA-EU’s Policy Manager, Annick Roetynck, at annick@leva-eu.com.

    6. TRA finds scrapping e-bike tariffs could save UK £51m per year

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      Source TRA – The Trade Remedies Authority (TRA) has published its initial findings recommending that anti-dumping and anti-subsidy measures on electric bicycles (e-bikes) from China should be revoked. 

      Following the transition reviews of the measures, the TRA found that keeping them in place would not be in the economic interest of the UK. Revoking the measures could:

      • benefit the UK economy by an average of £51m per year;
      • save consumers an average of £260 per e-bike; and
      • result in an average of 31,000 more e-bikes being bought per year in the UK.

      Sales of e-bikes in the UK reached an estimated £325 million in 2023, compared with £96 million in 2018, and are expected to grow further in the coming years. Although it is likely that dumping and subsidisation of Chinese e-bikes would likely recur if the measures were no longer applied and that the UK production industry would suffer some injury, it was found that this injury did not outweigh the benefits to the UK economy or consumers if the measures were revoked.

      TRA Chief Executive Oliver Griffiths said: “We always assess the impact of a trade remedy measure on the UK economy. Our interim conclusion is that the benefits to UK bicycle producers from continuing the current measures on e-bikes would be significantly outweighed by harm to the rest of the economy. We project that removing the measures could save consumers around £260 per e-bike and could benefit the UK economy by around £51 million annually.“

      Alternative options

      Under the UK’s revised trade remedies regime, if the TRA finds that a measure is not in the economic interest of the UK, it offers the Secretary of State for Business and Trade alternative options to revoking the measures.

      These alternative options included only applying the measures to folding e-bikes as UK producers are more heavily concentrated in this market. A period of consultation is now open for on all of the options presented, after which the TRA will make its final recommendation to the Secretary of State.

      As part of these reviews, for the first time, the TRA conducted a consumer survey as part of its assessment of how measures on these imports would affect the overall UK economy. The survey targeted e-bike customers and helped the TRA assess consumer sensitivity to e-bike prices. 

      Businesses that may be affected by the reviews (such as importers or exporters of the products or UK producers of similar products) can now comment on the initial findings via the TRA’s online case platform. They can also stay up to date with developments in each case, which will be posted on the TRA’s public files.

      Following Article 21 of the Basic Regulation, the EU Commission also has a legal duty to determine whether it’s in the interest of the whole EU Community. “(…) whether the Community interest calls for intervention shall be based on an appreciation of all the various interests as a whole, including the interests of the domestic industry and users and consumers; (…) Measures, as determined on the basis of the dumping and the injury found, may not be applied where the authorities, on the basis of all the information submitted, can clearly conclude that it is not in the Community interest to apply such measures.“

      LEVA-EU has already raised the issue of Community interest with the Commission, given the enormous difficulties and damage caused by trade defense measures to EU companies and the wider implications for sustainable mobility and public health.

      If the Commission would be willing to test the Community interest in this year’s reviews, with the same thoroughness as TRA applied in the Economic Interest Test, there is a very good chance that the measures will also prove to cause much more damage to the EU than the benefits they bring to those few EU manufacturers who continue to defend the measures through thick and thin.

      TRA finds scrapping e-bike tariffs could save UK £51m per year

      . If the Commission would be willing to test the Community interest in this year’s reviews, with the same thoroughness as TRA applied in the Economic Interest Test, there is a very good chance that the measures will also prove to cause much more damage to the EU than the benefits they bring to those few EU manufacturers who continue to defend the measures through thick and thin.

      Photo by James Giddins on Unsplash

    7. LEVA-EU calls on EU assemblers for support to end dumping duties on bicycle parts

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      The anti-dumping measures on conventional bicycles from China are to expire on the 30th August 2024. The measures are now in their 31st year. In 1997, they were extended to essential bicycle components based on alleged circumvention. Those measures are now in their 27th year.

      There is no doubt that EBMA has already or will very soon request the Commission to review the measures against conventional bikes with a view to continuing them for another 5 years. To gather the necessary support for their request, they visit bike assemblers up and down the continent, inviting them to co-sign the request for the review. In doing so, they will undoubtedly explain how it is necessary to continue the measures to avoid Europe being flooded with cheap Chinese bicycles, which would undoubtedly destroy European assemblers. They will add that the measures will allow production to be brought back to Europe and will create jobs.

      The other half of the story

      However, that is only half the story. LEVA-EU hereby invites all European assemblers to think carefully before explicitly expressing their support for EBMA’s request. After all, the other half of the story goes like this.

      The anti-dumping measures against bicycles from China were expanded in 1997 to include essential bicycle parts. Anyone who assembles in Europe must be able to prove that no more than 59% of the value of their components comes from China or that at least 25% value is added in the assembly. Anyone who can prove this will receive an exemption from the European Commission, meaning that 48.5% duties will not be levied on bicycle frames, forks, gears, sprockets, brakes, wheels and handlebars from China.

      When ADD and ASD were levied on electric bicycles in 2018, this had a major impact on the duties on essential bicycle parts. European assemblers who use essential bicycle parts for electric bicycles could also receive an exemption if they proved that they used the parts for electric and not for regular bicycles. Please note that the Commission has not (yet) extended the rights to essential bicycle parts for the European assembly of electric bicycles. Many European assemblers make electric bicycles of which the value of the components amounts to more than 59%. In some cases, the electric bicycles even consist of 100% Chinese components. The European assembly sector cannot do without these Chinese components because the availability of parts outside China is too limited to meet full demand.

      To circumvent or not to circumvent, that is the question.

      The EBMA’s request to the Commission to extend the duties on bikes to essential bicycle components, came almost immediately after the imposition of the duties on bikes, alleging massive circumvention by China. In the case of electric bicycles however, EBMA misses no opportunity to assure European assemblers that they can use as many Chinese parts as they want. And so, companies are happily assembling in a way that, according to the law, can very easily give rise to anti-circumvention measures.

      It is bizarre, to say the least, that while the European Commission responded to EBMA’s request without hesitation for conventional bicycles, the same Commission now simply ignores the situation, even though they could initiate an investigation at their own initiative. After all, why would the Chinese, accused of massive circumvention for conventional bikes, not resort to the same solution for electric bicycles.

      LEVA-EU calls on all assemblers in the EU to treat the EBMA reassurances with utmost caution. In reality, not everyone who assembles in Europe appears to be safe, as EBMA pretends. While the Commission is not currently interested in possible circumvention, some assemblers have indeed been attacked, more specifically by customs services. They determine that insufficient value is added in the assembly, upon which they categorize the import of parts as the import of a complete electric bicycle to which anti-dumping and anti-circumvention duties apply. With this alleged circumvention, the company is committing a criminal offense for which not only arrears are charged, but also extremely heavy fines and possible prison sentences. It will take 5 to 10 years to reach a conclusion in the case. During that period, given the extremely serious threat, it is impossible for the company to grow even if it is ultimately acquitted.

      Pushing businesses straight into the abyss

      So, when you sign certain EBMA requests to the Commission, which are allegedly intended against China and for Europe, keep in mind that this will not necessarily protect you from customs actions that may push your business straight into the abyss. As mentioned, LEVA-EU has no position on the dumping measures against conventional bicycles. As for the extension of the measures to essential bicycle parts, we say loud and clear: in the interests of European assemblers, these measures must be terminated as quickly as possible. No European company benefits from a legal restriction on the use of Chinese parts, nor from a very complex and expensive administration to enforce that restriction.

      LEVA-EU strongly hopes that European assemblers will consider this call and will no longer support EBMA requests that result in the continuation of the additional measures on essential bicycle parts from China.

      There is another important reason to terminate the duties on essential bicycle parts. That legislation makes it virtually impossible for new electric bicycle assemblers to enter the market. To obtain a Commission exemption or end-use approval, they must first pay 48.5% anti-dumping duties on essential bicycle parts from China. This is completely unacceptable because legally there are no anti-dumping duties on essential bicycle parts for electric bicycles.

      Which start-up can afford to include an additional cost of 48.5%, that serves no purpose and even has no legal basis, in their business plan? And to get rid of that 48.5%, which is not reimbursed in the case of end-use authorizations, they must provide significant guarantees!

      This makes EBMA’s claim that anti-dumping measures against electric bicycles from China are necessary to reshore production and to create jobs an outright lie. You may think that it is a good thing for your company if it is difficult for new companies to enter the market. Restriction of competition inevitably results in a reduced, thus less attractive offer and higher prices that ultimately leads consumers to quit. That response will eventually affect all remaining companies, including yours.

      LEVA-EU acknowledges that this is a complex matter and remain therefore at the disposal of anyone seeking further clarification: annick@leva-eu.com, tel. +32 475 500 588.

      Photo by Lance Grandahl on Unsplash

    8. Join the Ad Hoc Group in Opposing Extension Measures on E-Bikes from China

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      Is your company involved in any of the following:

      • Importing electric bicycles, electric cargo bikes, or speed pedelecs from China and paying duties?
      • Importing electric bikes, electric cargocycles, or speed pedelecs from a non-EU country OTHER THAN China?
      • Importing components from China for the assembly of electric bikes, electric cargocycles, or speed pedelecs within the EU?

      Is your company facing:

      • Investigation by national customs services and/or OLAF?
      • Accusations of circumventing measures against China?
      • Legal action for circumventing measures against China?
      • Sentencing or acquittal for circumventing measures against China?

      If so, we strongly recommend that you become a part of the Ad Hoc Group established by LEVA-EU to collectively oppose the potential extension of these measures.

      What will the Ad Hoc Group do?

      • Request recognition from the European Commission as an interested party.
      • Submit joint comments on the Commission’s review.
      • Seek a hearing from the European Commission, allowing companies to express their views.
      • Provide assistance from a specialized lawyer.
      • Communicate the group’s activities to the press and on social media.
      • Lobby other influential entities on this matter.

      How to Participate?

      • A modest contribution, based on the number of employees in your company, is required for participation in the Ad Hoc Group.
      • Participation can be kept confidential.
      • LEVA-EU membership is not a prerequisite for joining the Ad Hoc Group.
      • LEVA-EU members receive a discount on the contribution.

      Meeting Details:

      • The Ad Hoc Group will conduct multiple meetings, with the first scheduled for February 15, both in-person in Brussels and online.
      • If the Commission grants a hearing, it will be held in-person in Brussels; all other meetings will be accessible online.

      How to Join?

      Your involvement will make a difference in challenging the extension of the measures affecting the European electric cycle industry.