Comments Off on EN 15194 Since 15 May: Can You Still Sell Your EPACs?
Two versions of EN 15194, the European standard for EPACs (electric bicycles on two wheels), were in circulation until recently. The difference between the two versions concerns the battery requirements. The transition period between the “old” and the “new” version of the standard ended on 15 May 2026. Since that date, only the most recent version of EN 15194 may be used.
LEVA-EU continues to receive many requests for clarification about this transition. Companies are asking questions such as:
Can we still sell EPACs that comply with the old standard after 15 May?
Do we need to recall EPACs whose battery requirements comply with IEC 62133?
Are our EPACs compliant if their batteries meet EN 50604-1?
Will my EN 15194:2017 certificate remain valid after 15 May?
Do existing EPAC models need to be re-certified?
Is an EPAC fully compliant with EU legislation if it complies with EN 15194?
Does EN 15194 also apply to electric cargo bikes?
Is the CE marking on EPACs certified according to EN 15194:2017 still valid?
If I comply with EN 15194, do I automatically comply with the EU Battery Regulation?
LEVA-EU addresses these and many other questions in a dedicated Briefing on the transition from the old to the new EN 15194.
This Briefing is free for LEVA-EU members. Companies that are not members of LEVA-EU can obtain the Briefing at a price of €195 (ex VAT).
To order the Briefing, send an email to annick@leva-eu.com with the full name and address of your company as well as your VAT number. We will send you an invoice, and upon receipt of payment, we will send you the Briefing.
If your company joins LEVA-EU within three months after the Info Meeting, that amount will be deducted from the LEVA-EU membership fee.
Comments Off on Understanding EN 50604 Battery Standard, Its Relation to EN 15194 & Machinery Directive
There is a great deal of confusion in the industry about the battery standard EN 50604. LEVA-EU witnessed this first-hand at Eurobike, where many visitors came to the LEVA-EU stand with questions. During LEVA-EU’s information meeting at Eurobike —partly dedicated to EN 50604—it became clear once again just how widespread the confusion is.
Wild claims are circulating, such as: • All batteries must comply with EN 50604 retroactively. • EN 50604 has been postponed. • It is legally mandatory to comply with EN 50604.
All above statements are incorrect.
The situation shows that legislation for electric bicycles—and by extension for all light electric vehicles (LEVs)—is becoming increasingly complex and difficult for companies to navigate. LEVA-EU is one of the very few, if not the only, organisation consistently guiding and advising its members on this legislation, thanks to a unique position:
• LEVA-EU experts are directly involved in European technical committees that develop relevant standards, such as CEN TC333 (electric and cargo bicycles) and CENELEC TC21X (batteries, including EN 50604). • This allows LEVA-EU to understand both the content of the standards and their relationship to legislation—providing members with valuable, practical expertise.
Common Misunderstandings About EN 50604
Here is what EN 50604 is not: • ❌ There is no legal obligation to comply with this standard. • ❌ The standard has not been postponed. • ❌ It is not true that all batteries must comply with EN 50604 retroactively.
Batteries that do not meet EN 50604 may still be imported, distributed, and sold.
How EN 15194 Fits Into the Picture
• All EPACs must comply with the Machinery Directive’s Essential Safety and Health Requirements (ESHRs). These are general rules for all machinery, not specifically for e-(cargo)cycles, so the sector translated them into specific standards like EN 15194. • EN 15194:2017 is the European standard for EPACs—electric bicycles (2 wheels only) with pedal assistance up to 25 km/h and a maximum continuous rated power of 250 W. • When the European Commission determines that a standard covers all relevant ESHRs, it publishes a reference in the Official Journal of the EU (OJEU)—this is called harmonisation. • Harmonisation gives presumption of conformity: if there’s a legal dispute, the manufacturer can rely on the standard as proof of compliance with the Machinery Directive, and it is up to the opposing party to prove otherwise. • In 2019, EN 15194:2017 was harmonised under the Machinery Directive. Using a harmonised standard is not legally required—manufacturers may use alternative solutions to prove the “state of the art”, but in that case they lose presumption of conformity and must document their compliance in detail.
The Battery Requirements Change
In 2023, the European Commission withdrew harmonisation of EN 15194:2017 only for battery requirements, after the Dutch government raised concerns that the existing battery requirements were too weak.
• In the old EN 15194:2017, battery safety was only covered by a note, not be a requirement, suggesting testing according to EN 62133 or EN 50604-1 was sufficient. These standards were not specific to EPACs and offered limited safety guarantees. • The CEN/TC333 EPAC working group revised the battery section, resulting in EN 15194:2017+A1:2023, which requires testing according to EN 50604-1+A1 (a stricter version).
Transition Periods
• Normally, amendments get a 12-month transition period. • For the battery update of the EN 15194, the sector was given 24 months—until 23 August 2025—to allow adaptation. • During the transition, manufacturers can still use the old standard, but without presumption of conformity for battery requirements. Alternatively, they can use the new standard in which case their batteries must comply with EN 50604-1+A1
In 2024, the European Commission extended this transition from 23 August 2025 to 15 May 2026.
What This Means for You
If you hear that “EN 50604 is postponed”, that’s incorrect. What was postponed is the full replacement of the old EN 15194:2017 by EN 15194:2017+A1:2023.
After 15 May 2026, only EN 15194:2017+A1:2023 will give presumption of conformity for EPACs and their batteries—and compliance with EN 50604-1+A1 will be mandatory within that standard. Compliance with EN 50604-1+A1 will never become mandatory to comply with the Machinery Directive/Regulation
Harmonisation Challenges for LEVs
EN 15194 is currently the only harmonised standard for e-(cargo)cycles under the Machinery Directive. • Standards for e-MTBs, e-cargocycles, and EN 17128 (e-scooters, self-balancing vehicles, etc.) are not harmonised. • Harmonising LEV standards is becoming more difficult. The upcoming Machinery Regulation (replacing the Machinery Directive on 1 January 2027) may include even more requirements irrelevant to LEVs, but compliance may still be demanded for harmonisation. • This raises doubts whether EN 15194 will be harmonised under the new Regulation.
Other Battery Standards and Legal Requirements
• EN 17860-5 includes compliance with EN 50604-1+A1 for e-cargocycles. • EN 50604-1+A1 itself is under systematic review, with LEVA-EU actively participating. • The EU Battery Regulation imposes legally binding requirements on batteries in EPACs, e-cargocycles, and other LEVs—separate from battery requirements in existing standards.
How LEVA-EU Supports You
LEVA-EU keeps track of all developments in standards and legislation to provide accurate, up-to-date guidance to companies. We actively participate in both standards development and legislation drafting, defending our members’ interests and advocating for clear, proportionate rules—especially for SMEs.
A dedicated battery working group is open to all members, where questions are discussed. If necessary, LEVA-EU takes unresolved issues directly to the European Commission.
Questions or need expert guidance? Email: info@leva-eu.com Call: Annick Roetynck, LEVA-EU Managing Director — +32 475 500 588
Comments Off on Eddie Eccleston appointment as SBS-expert extended
Further to the call for experts published in June 2020, the SBS General Assembly confirmed the selection of 61 experts to represent the European SME position on standardisation Technical Committees, Sub-Committees and Working Groups in CEN, CENELEC, ETSI, ISO and IEC.
The selected experts, from 15 countries across Europe, will be active on 70 standardisation Technical Committees and more than 150 Working Groups, allowing SBS to influence the development of standards across more than 14 sectors.
LEVA-EU is very pleased with the reappointment of Eddie Eccleston to defend SME-interests in WG 5 – EPACs and WG 9 – (e)cargobikes of CEN TC 333.
Comments Off on ISO/TS4210-10:2020 is NOT a standard
ISO has published ISO/TS 4210-10:2020. This document is not a standard but a technical specification with safety requirements for electrically power assisted cycles (EPACs).
WG15 of ISO TC149/SC1 had been working on a draft standard for EPACs for a number of years. The idea was to come to an international standard that could potentially replace EN 15194, which is only valid in the EU.
The draft text for the future ISO standard was to a very large extent based on EN 15194. However, it becomes increasingly apparent that the quality of the electrical part of the EN 15194 is poor. CEN TC333 is currently dealing with a number of national objections against the standard for that reason.
Another issue of the draft ISO-standard for EPACs was the fact that it had too many requirements, which did not result from safety considerations and which created regulatory bottlenecks for innovation and technological development.
LEVA-EU is working in the ISO WG15. For all the above reasons, together with a significant number of other experts, we have rejected the draft text for the standard twice. ISO procedures did not allow for a third vote on the standard. That is why ISO has now published the text as a Technical Specification (TS). According to ISO: “A Technical Specification addresses work still under technical development, or where it is believed that there will be a future, but not immediate, possibility of agreement on an International Standard.”
All this changes nothing to the status of EN 15194:2017, this is still the European standard for EPACs, harmonised under the Machinery Directive.
For further details, please contact Annick Roetynck, tel. +32 9 233 60 05, email annick@leva-eu.com.
Comments Off on LEVA-EU to champion better rules for manufacturers as board member is appointed as SBS-expert
Trade association LEVA-EU, the sole voice for the light electric vehicle sector, is announcing the appointment of one of its board members, cycling industry veteran Eddie Eccleston, as Small Business Standards (SBS) expert. SBS is mandated by the European Commission to watch over SME-interests in European standardisation through the appointment of dedicated experts. In his position as SBS-expert, Eddie will help drive better rules for LEV manufacturers operating in the European Union.
LEVA-EU represents a wide range of LEV manufacturers in the EU, Norway, Switzerland, China and Korea, a large number of which are small businesses active in the European e-bike sector. Eddie Eccleston comments; “It is brilliant for LEVA-EU to gain a stronger voice through SBS as this is a key organisation which can help drive better rules and regulations for the LEV sector, which is not well understood always at EU level.” He continued: “The coronavirus crisis is accelerating the use of LEVs as a safe, alternative, green and healthy form of travel. However, legislation must keep up with the sector and there are serious issues where the rules are not fit for purpose for LEVs and they need resolving urgently.”
Eddie’s appointment comes as LEVA-EU campaigns among other things for the exclusion of e-cargo bikes from legislation that it says is stifling industries that rely on them. LEVA-EU has already written to the European Commission calling for urgent legislative change for LEVs centering on the technical legislation for L-category vehicles – mopeds and motorcycles.
The European Council and Parliament decided in 2013 to only exclude electric bicycles with pedal assistance up to 25 km/h and 250 W from this L-category in Regulation 168/2013. All other electric bicycles are included in technical legislation that was originally written for internal combustion engine mopeds and motorcycles, leaving manufacturers forced to navigate complicated and costly procedures. E-cargo bike manufacturers currently limit their vehicles to 250W to avoid the regulation and the ensuing type approval.
Eddie said: “This is a big issue I have already raised with SBS and we want as much input from LEV manufacturers as possible,” he said. “The 250W power limit, which e-cargo bike manufacturers must adhere to to stay out of type approval, is clearly insufficient in view of the increasing weight of the loads and for hilly areas. At the same time, European cities are banning cars, vans and trucks, and e-cargo bikes are being seen as a brilliant alternative. For this reason, and for e-cargo bike manufacturers to really thrive, it is essential that these types of vehicles are more widely excluded from the legislation so that the industry can reach its full potential.”
In his position of SBS-expert Eddie will be watching over the specific interests of small and medium sized enterprises (SMEs) in CEN TC 333 – cycles. There he is looking to ensure that standards do not hold any requirements, which are too difficult or too complicated for SMEs to comply with.
“Every day, LEVA-EU receives information requests from small businesses that are totally unable to grasp the EU rules and regulations that apply to their products,” he said. “It is our hope that having a voice through SBS will considerably contribute to both simplifying the standards and making them more effective, through a better harmonisation under the different relevant directives. In particular we want to ensure that the future standard for e-cargo bikes is tailored to small businesses.”
Eddie said he is now in the process of setting up a mirror group for businesses in the E-Bike and E-Cargobike sector to input into his work within CEN TC 33. Eddie is working in WG5 – EPACs and in WG9 – (E)Cargobikes.
“This mirror group is not only meant to share information on what is going on in CEN TC 333 it is also meant to consult and discuss the ongoing standardization work,” he said. “As a result, mirror group members will have direct access to and participation in the standardization work.”
For further information on standardization work for light, electric vehicles please contact LEVA-EU, email leva-eu@telenet.be, tel. +32 9 233 60 05
In CEN TC 333 Eddie Eccleston follows up on:
– CEN TC 333 – Cycles – General Assembly where general progress of the standardization work is discussed as well as potential new work items and miscellaneous issues.
– CEN TC 333 – Cycles – WG5 EPACs: this is the working group in which EN 15194:2017 has been developed. This working group discusses potential corrections, amendments and revisions of EN 15194:2017.
– CEN TC 333 – cycles – WG 9 (E)Cargobikes: this is a new working group that is preparing a European draft standard for (E)Cargobikes.
SBS background
Small Business Standards is a European non-profit association, co-financed by the European Commission and EFTA Member States. The SBS reported goal is to represent and defend small and medium-sized enterprises’ (SMEs) interests in the standardisation process at European and international levels. Moreover, it aims to raise awareness to SMEs about the benefits of standards and at encourage them to get involved in the standardisation process. For more information click here
LEVA-EU has a new briefing available on the EU technical rules applying to batteries for light, electric vehicles, i.e. electric bicycles, electric scooters, self-balancing vehicles, electric monowheels, hoverboards, etc.
In the briefing, we explain how battery rules depend on the legal framework that is applicable to the complete vehicle. The regulations for vehicles under type-approval are completely different from the regulations for vehicles under the Machine Directive.
We provide a detailed overview of the requirements resulting from these two frameworks. We focus not only on electric bicycles up to 25 km/h and 250W, but also on electric bicycles in L1e-A and L1e-B (speed pedelecs), on electric mountain bikes, electric cargo bikes, electric scooters, self-balancing vehicles, etc.
LEVA-EU looks back on a very successful Eurobike. At our booth, all meeting tables were used full time by LEVA-EU members meeting with customers and suppliers. We met with numerous LEV-companies wanting to learn more about what LEVA-EU has to offer them.
For the information meeting on EN 1594:2017 on Thursday, 63 participants registered. LEVA-EU Manager Annick Roetynck clarified the relationship between EN 15194 and legislation governing EPACs. For many attendants, it still came as a surprise to learn that EN 15194 is not a law, but merely a tool to comply with part of the legislation for EPACS. She further explained the difference between the old and the new EN 15194. She also provided all details on on the structure and the scope of the standard. She listed what makes an EPAC fully legal. She concluded with explanations on how the standardization process in Europe works, encouraging the companies present to get involved in the standardization work.
On Thursday evening, LEVA-EU and LEVA welcomed no less than 40 guests for the networking dinner in the Zeppelin Hangar restaurant. A very wide variety of companies were there: vehicle producers, assemblers, component and accessory manufacturers, designers, HR companies, etc. After a short introduction of each company during the aperitif, the guests could then decide which companies to sit with for further networking during dinner itself. It was a (sometimes literally) resounding success, and upon general request the dinner will be on again at Eurobike 2020.
Should you be interested in a copy of the presentation on EN 15194 and/or in the introductions of the companies that participated in the networking dinner, please contact Annick Roetynck, tel. +32 9 233 60 05, email annick@leva-eu.com
