Tag Archive: Dutch LEV-Framework

  1. Sign LEVA-EU’s Letter to the Dutch Minister to Stop LEV-Framework

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    The Netherlands wants to introduce new national rules for light electric vehicles, more specifically e-cargobikes and e-scooters, called the “LEV-kader.” LEVA-EU believes these rules are illegal and bad for the sector and is asking the Dutch Minister of Infrastructure and Water Management, Vincent Karremans, to cancel them.

    We need your support. If your company works with light electric vehicles, please add your name to our letter below. The more companies that sign, the stronger our message to the Minister.


    What we’re asking you to do

    We have prepared a letter addressed to Minister Karremans. That letter is here below.

    If you’re unable to open the letter, send us a mail and we will send you the letter directly.

    This is how you can join our action:

    • Please read the letter carefully.
    • Decide whether you agree with the content and whether you want to support the call for withdrawal.
    • If the answer to both questions is “yes”, fill in the form below and submit it through the website.
    • Should you wish, you can also come round to our booth at Eurobike, Hall 12 F50, to sign the letter there.


      Why the Framework has to go

      The Netherlands is about to impose a purely national approval regime on light electric vehicles — e-cargo bikes, e-scooters, pedal-assist cycles and comparable vehicles. If it goes ahead, manufacturers will have to build a special “Dutch” version of vehicles that are already lawfully sold across Europe, and submit them to a second national inspection on top of the CE marking they already carry. This is exactly the kind of fragmentation that the European single market was designed to prevent — and, ironically, exactly the fragmentation the Netherlands itself has been warning against in Brussels.

      It conflicts with Dutch law. The framework would require approval for vehicles that Dutch law itself explicitly exempts, including pedal-assist cargocycles up to 25 km/h and 250 W. Subjecting those vehicles to approval is at odds with the Netherlands’ own Regeling Voertuigen.

      It conflicts with EU law. Light electric vehicles that fall outside Regulation (EU) 168/2013 are already covered by a broad package of harmonised EU legislation — the Machinery Directive and Machinery Regulation, the EMC, RoHS, Radio Equipment and Low Voltage Directives, the Batteries Regulation and the Market Surveillance Regulation. The Machinery Directive is explicit: Member States may not prohibit, restrict or impede the placing on the market of machinery that complies with it. A national type-approval on top of CE marking does precisely that. What a requirement is called does not matter; what matters is what it does — and a product-safety requirement dressed up as “road admission” is still caught by EU law. Where a Member State genuinely doubts a product’s safety, the proper tool is market surveillance and the safeguard clause, not a blanket prior approval that ignores conformity already demonstrated.

      It threatens the industry with lasting damage. If the LEV-framework is pushed through, it will cause serious and, in some cases, irreversible harm to the companies that design, build and supply LEVs and LEV components in the Netherlands and across Europe. Some businesses will not survive it. And if the survivors are later forced to switch back from a Dutch regime to a European one, the damage will only deepen — slowing the very shift to sustainable urban mobility that LEVs make possible.

      The Netherlands is contradicting itself

      On 4 December 2025, the Netherlands raised light electric mobility at the EU Transport Council, supported by fifteen other Member States, and stated:

      It is clear that we do not need 27 different types of national regulation for fairly comparable vehicles on our roads. European action is needed here. […] The declaration calls above all for the harmonisation of a type-approval-like system for these emerging PMDs, without any concession to safety.”

      We wholeheartedly share the principle: a patchwork of 27 national regimes is the wrong answer, and safety must come first. But the Netherlands cannot credibly warn against national fragmentation in Brussels while building its own national framework at home. It has to choose: the European route it advocates, or the national route it is actually walking. It cannot be both.

      There is a better way

      The existing harmonised EU framework works — millions of light electric vehicles are already on Europe’s roads without structural technical problems. The real issues come from illegal products, for which market surveillance exists to address, and from infrastructure and traffic that are out of balance, which is solved by giving LEVs and other vulnerable road users more and safer space.

      What the sector needs is not a national workaround but a dedicated EU regulation for light electric vehicles — one that, like the Machinery Directive does for machinery, sets essential safety requirements for all LEVs, complemented by harmonised standards and appropriate compliance methods, and developed in close consultation with the sector. That is also what the Commission’s own Expert Group on Urban Mobility recommended back in 2024. The way forward is for the Netherlands to shelve the LEV-framework and open a dialogue with Commissioner Séjourné and DG GROW on exactly such a regulation.

      We are also formally requesting a meeting for the Minister to consult the sector before any further decisions are taken. As a constructive suggestion, we are proposed the International Cargo Bike Festival at the Royal Dutch Jaarbeurs in Utrecht on 12–13 October 2026 — which brings together manufacturers, operators and experts from across Europe — as an ideal occasion for such a consultation. Should that timing not suit the Ministry, we have offered to meet at the Ministry on alternative dates and to align with the Minister’s availability.

      Safety and harmonisation: yes. But with the right instrument, and together with the sector that knows these vehicles best. Stand with us.


      LEVA-EU vzw — Jan Baptist Guinardstraat 32, B-9000 Ghent — annick@leva-eu.comwww.leva-eu.com – +32 475 500 588

    • Why the Dutch LEV framework should be scrapped

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      LEVA-EU has filed its response to the Dutch consultation on rules for Light Electric Vehicles (LEVs), mainly e-cargocycles and e-scooters. Our position is clear: the proposed LEV framework conflicts with both Dutch and EU law, duplicates a regime that already works, and would do serious harm to LEV manufacturers and suppliers.


      A national approval the law does not allow

      The framework would require national type approval for vehicles that EU law deliberately exempts from type-approval — including standard pedal-assist e-cargocycles up to 25 km/h and 250 W and e-scooters. These vehicles are also explicitly exempt in Dutch legislation, under the Netherlands’ own Regeling Voertuigen (Article 3.10.1(d)), which points to the European exemptions in Regulation (EU) 168/2013. Forcing them into an Article 21.1 approval (Wegenverkeerswet) therefore contradicts the Dutch government’s own rules.

      Nor does it help that the government has quietly taken certain vehicle types off that national exemption list, apparently to bring them under a national type approval. Doing so changes nothing under EU law: every LEV excluded from 168/2013 falls automatically under the Machinery Directive (and, from January 2027, the Machinery Regulation), alongside the EMC, Low Voltage, Radio Equipment, RoHS, WEEE, Batteries, Cyber Resilience and Market Surveillance rules. It is that EU regime — not the Dutch list — that determines what the Netherlands may require. These are comprehensively regulated products, not a gap waiting to be filled.

      “Road admission” does not change what a requirement is

      The framework regulates these vehicles through a national approval — the road-admission route. But in EU law the substance counts, not the label: a product-safety requirement does not escape the Machinery Directive by being renamed. The Directive’s Annex I already covers these vehicles’ safety in full, and Article 6(1) forbids Member States from layering a second national approval on top of CE marking. CE marking carries a presumption of conformity the Netherlands must respect; where a product is genuinely unsafe, the proper tool is market surveillance, not blanket prior type approval.

      The same problem applies to the proposal to capture vehicles up to 25 km/h and 1,250 W maximum continuous rated power that run without pedal assist. These are no faster than the exempt e-cargocycles — they simply work differently — and they already fall under existing 168/2013 categories (L1e-A, L1-B, L2e or L6e). A parallel national regime collides directly with that Regulation.

      The existing regime already works

      Millions of e-cargocycles and e-scooters are on Europe’s roads without structural technical problems. The issues that do arise come from illegal, non-compliant vehicles — a market-surveillance task — and from inadequate infrastructure and unbalanced traffic, not from a lack of national approval.

      A contradiction in the Dutch position

      In December 2025, the Netherlands warned the EU Transport Council (see 17h30) — backed by 15 Member States — against having “27 different national rules” and called for European harmonisation! Yet it has spent years building exactly such a national framework. The country warning against fragmentation is contributing to it. The sector is entitled to ask which route the Netherlands is actually taking.

      There is also a deeper point. The Commission’s own TRL studies already concluded that type approval under 168/2013 is unsuitable for LEVs and recommended a separate, sector-tailored framework. Proposing a new “type-approval-like” system without acknowledging that — and without consulting the industry — risks repeating a problem that has already been identified.

      What the sector should ask for instead

      LEVA-EU has long argued for a dedicated EU LEV Regulation that covers all LEVs with essential safety requirements, with categorisation and conformity methods worked out in consultation with the sector. The Commission’s Expert Group on Urban Mobility recommended exactly this in 2024 — a recommendation still unanswered.

      The constructive path is straightforward: the Dutch ministry should shelve the national framework and open a dialogue with Commissioner Séjourné and DG GROW on a dedicated LEV Regulation and a LEV Expert Group to guide the work.

      Safety and harmonisation: yes — but with the right instrument, and together with the sector that knows these vehicles best. That serves light electric mobility not in one Member State, but in all 27.

    • Netherlands consults on new rules for e-bikes, e-cargo bikes & e-scooters – deadline 9 June

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      The Dutch government has opened a public consultation on a draft decree setting new rules for light electric vehicles (LEVs). Companies, associations and individuals can respond until 9 June 2026: internetconsultatie.nl


      The draft is formally a decree amending several existing orders in council (an algemene maatregel van bestuur, or AMvB). It forms part of the broader Dutch Light Electric Vehicle (LEV) framework that has been under development since the fatal 2018 Stint accident and the Dutch Safety Board’s subsequent report Veilig toelaten op de weg (“Safe admission to the road”). That report concluded that the Netherlands needed one clear approach for all LEV types, with tailored rules for each vehicle category.

      Why now

      According to the Dutch government, the number of e-bikes in the Netherlands rose from roughly 1.2 million in 2014 to about 4.6 million in 2024. Emergency-department admissions of 12-to-17-year-olds following e-bike accidents rose roughly sixfold between 2020 and 2024. The government also points to early signals from abroad — including a 62% rise in e-scooter accidents in Belgium in the first quarter of 2025 compared with a year earlier — as a warning of what could follow as more legal LEV models reach the market.

      That comparison is not exactly intellectually honest. The 62% figure refers to the number of injury accidents involving e-scooters; across the full year the increase was 33.7%, reaching a total of 2,453. For context, that same year saw 26,050 injury accidents involving cars and 11,923 involving bicycles. The figure also comes without any reference to the number of e-scooters actually on the road, which makes the comparison effectively meaningless.

      The reference to rising accident numbers among 12-to-17-year-olds is open to the same objection. What was the total number of e-bike users in that age group against which those injury figures should be set? What were the circumstances of the accidents — were the riders struck by another vehicle, a car perhaps? Or were they riding an illegal e-bike? In that last case, a helmet requirement would definitely not solve the problem.

      A second driver for the LEV-framework is the patchwork nature of the current rules. The existing regime for “special mopeds” (bijzondere bromfietsen) has grown up piecemeal over the years, so the rules don’t always fit together and differ between vehicle types for reasons that aren’t always clear. The government also flags that pedal-assisted cycles and e-scooters can currently reach the market through self-certification, where the manufacturer simply declares conformity — something the Dutch vehicle authority, the RDW, considers an insufficient safety guarantee.

      This is, to put it mildly, a curious position, given that the same vehicles reach the market through self-certification in the great majority of EU member states too — without any notable structural problems, provided they comply with existing EU legislation.

      What the draft proposes

      The proposal combines several measures rather than relying on a single instrument.

      Heavy electric cargo bikes would need to be type-approved by the RDW and carry a number plate. Owners would have to take out third-party liability insurance under the Dutch Motor Insurance Act (WAM). A transitional period would give owners of vehicles already in use time to register them and obtain a plate.

      A minimum age of 18 would apply to riders of heavy electric cargo bikes, reflecting the greater responsibility involved in carrying goods or passengers on heavier vehicles. The government expects limited disruption here, since these vehicles are mostly used commercially.

      A helmet requirement for under-18s — both riders and passengers — would apply to pedal-assist cycles and to e-scooters. The stated aim is to reduce avoidable head injuries among young people. In the Netherlands there is a tradition of so-called BSO-busjes: light electric vehicles used to carry up to eight children from school to an after-school care location until their parents collect them. The helmet requirement would apply to these children as well — which, at the very least, raises the question of how much a helmet requirement really adds for passengers.

      A notable shift on helmets

      The youth helmet element is worth flagging, because it marks a change in direction. When the LEV framework was first presented in 2021, the Dutch government explicitly chose not to impose a helmet requirement on these vehicles, arguing that public support was low, that the health benefits of cycling outweighed the accident risk, and that helmet use was a matter of personal responsibility. The new draft introduces a targeted requirement for under-18s, driven by what it describes as a sharp rise in youth head injuries — a rise that, as noted above, appears to be asserted rather than substantiated.

      What businesses are already saying

      The proposal has been through a mandatory SME impact assessment, which surfaced a real tension between road safety on one hand and the extra cost and administrative burden on the other — particularly for heavy electric cargo bikes. Operators expect higher costs from plates, insurance and especially from the national type-approval procedure. Some have warned that this could push businesses toward small vans instead of cargo bikes — an outcome at odds with wider sustainability goals. Childcare organisations also questioned how much the helmet requirement adds for passengers of child-transport cargo bikes. The government says these points were considered but did not change its choices.

      Three further mandatory assessments — a police enforceability test, an RDW implementation test, and a regulatory-burden review by the ATR advisory board — are running in parallel with the consultation, so their outcomes are not yet known.

      The European dimension

      The Netherlands continues to push this purely national initiative — even though, at a Council meeting in December last year, an earlier composition of that very same government formally asked the European Commission to do the opposite.

      Its statement read: “The Netherlands would like to bring to your attention the subject of Personal Mobility Devices. It is clear that we do not need 27 different kinds of regulations on a national level or for rather similar devices on our roads. European action is called upon. To bring about change the NL has issued a statement supported by (15) other Member States addressing the European Commission. The statement, most importantly, argues for harmonisation of a type-approval like systems for these upcoming PMDs with no compromise on safety.

      A call for one European approach rather than a patchwork of national ones — backed by no fewer than 15 other Member States. And yet, a year on, the Netherlands continue to build exactly the kind of national framework it warned against.

      At a recent open meeting, LEVA-EU presented its legal analysis of the Dutch LEV framework to members and non-members alike. The analysis concludes that the proposed framework breaches both EU and Dutch law. LEVA-EU is now bringing manufacturers, importers and other affected companies together behind a single joint protest letter against the framework. A dedicated article setting out that letter will be published in the coming days. In the meantime, anyone who would like the presentation from the meeting can request it with a short email to info@leva-eu.com.

      How to respond

      The Dutch consultation is open to everyone — companies, associations and individuals — until 9 June 2026 via internetconsultatie.nl, where the full draft decree and the accompanying policy document (the Beleidskompas) can be downloaded. Comments can be submitted on all parts of the proposed rules and the explanatory memorandum.

    • Last Call: Open Industry Meeting on the Dutch LEV Framework – LEVA-EU Members and Non-Members Welcome

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      The Netherlands is pushing ahead with a national type-approval scheme for light electric vehicles — not driven by evidence of safety failures, but by political symbolism following an accident with an entirely different vehicle type. LEVA-EU is organising an open online meeting to explain what the Dutch LEV framework means for your business and to present a concrete plan to stop it. The meeting takes place on Wednesday 27 May and is open to all companies in the sector, whether or not they are LEVA-EU members.


      Background

      Seven years after the Stint accident — whose cause was never established, and whose directors were cleared of intentional wrongdoing by a court in February 2026 — the Netherlands is still pressing ahead with its so-called LEV framework. The scheme would require electric scooters and (e)cargo bikes above 75 kg to obtain a national type-approval from the RDW.

      The problem is fundamental: the Stint was a completely different vehicle type. The vehicles targeted by the LEV framework are already subject to comprehensive EU legislation — the Machinery Directive, EMC, RoHS, the Battery Regulation — and to European standards ampng which the EN 17860 -series developed under the coordination of NEN, the Dutch standardisation institute. No structural safety incidents have occurred, in the Netherlands or in any other EU member state where the same vehicles circulate without a comparable framework.

      Three governments have come and gone, and for the fourth government the LEV framework remains unfinished — supported by a growing library of studies and reports, yet with no demonstrated safety benefit. What has been established, with increasing clarity, is the damage it will cause to the sector.


      Why This Affects Your Business

      This is not a distant regulatory concern. If the Dutch LEV framework is adopted, the consequences for your business are direct and concrete:

      • Additional costs — a costly Dutch type-approval on top of existing EU certification, for a market of just 18.4 million people.
      • RDW monopoly — the RDW sets the technical requirements and carries out the inspections. LEVA-EU questions whether this is compatible with NMA and DG Comp competition rules.
      • Market fragmentation — manufacturers would need to develop Netherlands-specific vehicle variants, adding cost and reducing model availability. Single market, anybody?
      • No sector dialogue — four governments have passed without any structured consultation with the LEV industry. Survey responses for research reports do not qualify as dialogue.

      The Dutch framework does not stop at the Dutch border. If it is allowed to stand, it sets a precedent. Other Member States may follow. The fragmentation of the European single market for LEVs — vehicle by vehicle, country by country — is a real and present risk. This is not a Dutch problem. It is a European one.


      Meeting Details

      The meeting will take place on Wednesday 27 May 2026 at 3.30 pm CET. It’s an online meeting only and participation is free.

      This meeting is open to all manufacturers, importers, distributors and dealers of electric scooters and (e)cargo bikes — regardless of whether you are a LEVA-EU member, and regardless of your country of origin.

      To participate, you just need to register by sending a quick mail to state your interest to annick@leva-eu.com. You will receive the link to the meeting shortly before the start of the meeting.


      What the Meeting Will Cover

      At the meeting, LEVA-EU will:

      • Explain clearly what the Dutch LEV framework is — what it requires, which vehicles it targets, and what the timeline looks like
      • Set out the risks for manufacturers, importers, distributors and dealers across Europe
      • Present a concrete action plan to challenge the framework, both with the Dutch authorities and before the European Commission

      This is not a passive information session. It is the starting point of a coordinated industry response — and the strength of that response depends entirely on how many companies show up. The more companies that attend, the stronger the collective signal.

      If you manufacture, import, distribute or sell electric scooters or (e)cargo bikes — in the Netherlands or anywhere else in Europe — this concerns you. Register now and help LEVA-EU make the case that cannot be dismissed.

      Send your registration to annick@leva-eu.com and include:

      • Company name
      • Activity (manufacturer, importer, distributor, dealer…)
      • Brand(s) and vehicle types (e-scooters, (e)cargo bikes, or both)
      • Name, job title and email of participant(s)

    • Petition for Withdrawal Dutch LEV- Framework to Close Next Friday: Sign Now!

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      So far, 60 companies have signed the LEVA-EU petition for the withdrawal of the Dutch LEV-Framework. The petition will close on 24 January. It only takes a few minutes to sign. So, don’t miss out on this opportunity to keep the Dutch market open for electric cargobikes, e-scooters and self-balancing vehicles.

      Should the Netherlands go ahead with the framework, it will become much more difficult to put these vehicles on the market there. The LEVA-EU petition is addressed to the Dutch Minister, Barry Madlener, and Secretary of State, Chris Jansen, responsible for Infrastructure and Water Management and argues that the current draft contradicts established EU legislation, undermines the principles of the European Single Market, and ignores years of expert-driven standardisation work and key stakeholder engagement.


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


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

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

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

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

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

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

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

      Key Requests of the Petition:

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

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

      Petitioners’ Requests:

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

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

    • Sign Now: Petition for Withdrawal Dutch LEV- Framework

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


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


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

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

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

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

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

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

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

      Key Requests of the Petition:

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

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

      Petitioners’ Requests:

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

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

    • Dutch LEV framework postponed yet again

      Comments Off on Dutch LEV framework postponed yet again

      The RAI Association, the Dutch professional organization for (e-)bike manufacturers, has announced that the Dutch LEV framework has once again been postponed until July 2025. Until recently, January 1, 2025, was the proposed date. Meanwhile, the new government and the new parliament are not exactly showing much interest in the matter.


      From July next year, e-scooters and (e-)cargo bikes, among others, will be subject to a mandatory inspection by the RDW (Netherlands Type-Approval Authority) based solely on Dutch technical requirements. In addition, the Netherlands is working on national road use conditions for so-called Light Electric Vehicles (LEVs). For example, cargo bike riders would need to hold an AM (moped) license, and all LEVs, including scooters, would be required to have a license plate.

      Over the past few years, LEVA-EU, together with ICBF, the LEV knowledge center, and Legaal Rijden, has consistently protested against these specifically national regulations. According to LEVA-EU, the Dutch technical requirements not only complicate access to the Dutch market, but also hinder the sustainability of mobility by limiting the growth of LEVs.

      In countries such as Belgium and France, for example, both e-scooters and (e-)cargo bikes are required to meet the Machinery Directive, the EMC Directive (Electromagnetic Compatibility), and the RoHS Directive (Restriction of Hazardous Substances). Belgium and France do not impose additional technical requirements for their use on public roads, which does not result in structural safety issues. This demonstrates that the harmonised European technical framework is sufficient to ensure the safety of these vehicles.

      Development of European standards

      At the European level, standards for (e-)cargo bikes are currently being developed within CEN (European Committee for Standardization) to facilitate the application of the Machinery Directive. Ironically, the secretariat of this CEN working group is led by NEN, the Dutch standardization institute. For e-scooters, a European standard has existed for some time, and its revision has recently begun. This makes the development of specific Dutch requirements all the more questionable, according to LEVA-EU.

      The Stint incident and political pressure

      The origin of the strict Dutch LEV framework lies in a tragic accident involving a Stint several years ago, in which several children died. Although the cause of the accident was never found, the LEV framework seems to be a political response to show strength to the public. LEVA-EU emphasizes that e-scooters and cargo bikes have no connection to the vehicle type to which the Stint belongs.

      Political impasse

      LEVA-EU hopes that the new Dutch government and parliament will opt for a drastic course change and scrap the technical approval framework for LEVs. The organisation claims that previous policymakers systematically rejected any requests for a dialogue with the companies directly involved.

      A recent invitation from LEVA-EU to use the upcoming ICBF (International Cargo Bike Festival) to exchange ideas with cargo bike companies was once again rejected by Chris Jansen, the new State Secretary for Infrastructure and Water Management. Only three of the 29 members of the parliamentary committee responded to LEVA-EU’s invitation, of which only one member promised to review their agenda for a possible meeting after the ICBF. Neither the chairman nor the vice-chairman of the committee responded. LEVA-EU concludes that the LEV framework still does not appear to be a priority for the relevant policymakers.