Tag Archive: EPAC

  1. ZIV Proposal Poses Serious Risk to the Future of EPACs and Cargo Bikes in Europe

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    Last week, LEVA-EU took part in the International Cargo Bike Festival (ICBF) in Utrecht. We hosted a well-attended stand and an open information meeting, dedicated to the Battery Regulation and the ZIV position on EPACs. Our conversations in Utrecht clearly showed that many LEV companies have either not thoroughly read the ZIV position or do not fully understand the consequences for their vehicles and their businesses. Therefore, we will once again explain the possible implications of the ZIV position here. We will also keep our open letter calling on ZIV to withdraw its position online for one more week.

    The German Bicycle Industry Association, ZIV, claims that the legal status of the Electrically Power Assisted Cycle (EPAC) is under threat and that the legal definition of EPAC therefore needs clarification. However, ZIV does not explain how or by whom the EPAC status is supposedly being threatened. The narrative around this EPAC status is also particularly confusing. ZIV asserts that the EPAC has the legal status of a bicycle, which is simply incorrect. Legally, the EPAC is not treated in the same way as a conventional bicycle. The technical requirements that ZIV seeks to change in order to “protect” the EPAC status are entirely different from those that apply to bicycles without motors.

    What is true is that the 27 Member States have granted EPACs the same rules of use as conventional bicycles. However, EPACs are not unique in this regard. In some Member States, electric scooters, powered cycles (L1e-A) and speed pedelecs also enjoy similar usage conditions. Furthermore, no Member State is currently questioning these conditions for EPACs.

    Yet according to ZIV, there is such danger that they propose to restrict the EPAC to a certain category of two-wheeled electric bicycles. This would mean pushing a large part of current EPAC vehicles out of this category and instead placing them under Regulation 168/2013 and its type-approval framework.

    Amending Article 2.2(h)

    In essence, ZIV is saying—though not explicitly—that their proposal would only be possible by amending Article 2.2(h) of Regulation 168/2013. That article currently excludes from type-approval

    “Pedal cycles with pedal assistance equipped with an auxiliary electric motor having a maximum continuous rated power of 250 W, where the motor output is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km/h.”

    To implement the ZIV proposal in legislation, this article would need to be changed to:

    “Pedal cycles with pedal assistance with a maximum weight of 250 kg for single-track cycles or 300 kg for multi-track cycles which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, a maximum assistance power of 750 W at the drive wheel, a support ratio of 1:4, and a support ratio of 1:6 possible up to a maximum of 15 km/h, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km/h.”

    Destructive Proposal

    As a result, a large number of EPACs would be removed from the current Machinery Directive framework—combined with standards such as EN 15194, EN 17404 and the EN 17860 series—and instead be pushed into the L1, L2, or L6 categories. This also means that the existing compliance procedure—where self-certification is possible, optionally combined with testing by a test laboratory of choice—would be replaced by a mandatory type-approval system. Under this system, you must build a vehicle type in accordance with 1,032 pages of requirements and tests. That type must then be approved by an accredited technical service. There are only a handful of such services in the EU capable of testing LEVs to L-category legal requirements. Worse still, these legal requirements are completely unsuited to the technical characteristics of LEVs.

    If vehicles are pushed into the L-category, they will automatically lose their existing usage rights in Member States. Many Member States do not even know how to deal with L1e-A vehicles, of which there are virtually none on the road today. In L1e-B, L2 or L6, these vehicles are almost automatically classified as mopeds.

    Under the ZIV proposal, the following vehicles, for example, would be forced into the L-category:

    • EPACs with two wheels and an assistance factor > 4, even if assistance is limited to 25 km/h, maximum continuous rated power to 250W, and peak power to < 750W
    • EPACs with two wheels and peak power > 750W, even if assistance is limited to 25 km/h, maximum continuous rated power to 250W, and assistance factor to < 4
    • EPACs with two wheels weighing over 250 kg, even if assistance is limited to 25 km/h, maximum continuous rated power to 250W, peak power to < 750W and assistance factor to < 4
    • EPACs with three or four wheels weighing over 300 kg, even if assistance is limited to 25 km/h, maximum continuous rated power to 250W, peak power to < 750W and assistance factor to < 4

    It appears that ZIV uses “weight” to refer to total permitted weight, including the vehicle, rider, passenger(s), and cargo.

    The above examples clearly show that the ZIV proposal—supposedly intended to protect the EPAC—would in reality devastate a large portion of the EPAC market.

    Violation of Technological Neutrality Principle

    Regulation 168/2013 already violates the legal principle of technological neutrality because it places vehicles with exactly the same kinetic energy into two completely different legal frameworks. An EPAC weighing 25 kg, with assistance up to 25 km/h and 250W, produces exactly the same kinetic energy as one with 300W. Yet the first is excluded from Regulation 168/2013 and subject to the Machinery Directive (under which millions of EPACs have successfully been placed on the market), while the second falls under L1e-A (under which almost no EPACs have entered the market).

    ZIV likes to portray LEVA-EU as merely trying to endlessly raise power limits. Coincidentally or not, LEVA-EU has recently been attacked twice by journalists based on this misconception. ZIV knows full well that an EPAC with a maximum continuous power of 500W limited to 25 km/h cannot travel a nanosecond faster than one with 250W. They also know that for instance heavy cargo bikes need higher peak power to operate safely, especially in hilly environments.

    With the ZIV proposal, many EPACs would be removed from the Machinery Directive and instead fall under Regulation 168/2013, destroying the existing market for these vehicles. Nearly all vehicles seen in Utrecht would be affected. A representative of a multinational e-commerce and logistics company asked at ICBF how cities would react if all electric cargo bikes currently used for urban logistics had to be replaced by vans again in the short term.

    Destructive proposal

    With this disastrous proposal, ZIV claims to be safeguarding active mobility. The idea of manipulating technical legislation to supposedly promote certain forms of mobility while killing others is utterly absurd. Active mobility is encouraged through financial or fiscal incentives, not by rewriting technical legislation to exclude certain vehicles from the market. The claim that “the majority of global bicycle manufacturers, together with 13 drive system manufacturers” support this proposal is incomprehensible—unless, of course, these manufacturers do not fully understand its consequences.

    We therefore once again strongly urge you to carefully read the ZIV proposal and its potentially disastrous consequences for the LEV sector. Part of the LEVA-EU Info Meeting at ICBF was dedicated to this topic. You can find the relevant part of the presentation here: https://tinyurl.com/3y53hbhv

    If you have any further questions, we are ready to answer them. If you, like us, believe that this proposal must be urgently withdrawn, and you have not yet signed the open letter, you can still do so here: https://leva-eu.com/sign-leva-eu-open-letter-stop-ziv-proposal/. Please scroll down to the bottom of the webpage. The letter will be definitively closed on Friday evening, 24 October.

  2. Berlin Study on EPAC Regulation Shows Clear Bias Towards Status Quo

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    The recently released Kurz-Studie on Electrically Power Assisted cycles (EPACs), published by the Zentrum Nachhaltige Transformation (zNT Berlin), presents itself as an objective contribution to the mobility debate. A closer look, however, reveals that the study is biased towards preserving the current legal framework and fails to address some of the most urgent regulatory challenges facing Europe’s mobility transition.

    From the outset, the study narrows its scope by equating EPACs almost exclusively with conventional two-wheeled bicycles (2wheels) limited to 25 km/h and 250 watts. Other important EPAC categories, such as cargo bikes or inclusive vehicles for people with disabilities, are barely mentioned. This narrow perspective sidelines precisely those vehicle types that could make the greatest contribution to sustainable urban logistics and inclusive mobility solutions.

    Equally striking is the absence of any discussion of technical neutrality. Regulation 168/2013 has created a distorted situation in which vehicles with similar performance as EPACs are regulated differently depending on technical details such as throttle control or maximum continuous rated power. This breach of neutrality is one of the key barriers to fair regulation in the light electric vehicle sector, yet the study ignores it completely. As a result, the analysis paints a misleadingly positive picture of the existing framework, without acknowledging how many vehicles are effectively locked out of the market.

    This lack of perspective is particularly apparent when considering innovation. While the study celebrates the success of the EPAC market under current rules, it does not mention the many vehicle types that have been stifled by the system. Heavy-duty cargo bikes, EPACs designed for (very) hilly terrain or adaptive solutions for mobility-impaired users are all subject to regulatory burdens that obstruct their market entry and uptake. A true assessment of the framework should weigh both the successes it has enabled and the opportunities it has prevented. Instead, the study only tells half the story.

    The bias becomes even clearer in its treatment of industry positions. LEVA-EU’s proposals for reform, such as abolishing the arbitrary and senseless 250W limit or creating a new, fairer legislation for light electric vehicles, are described as risky, theoretical or destabilising. With that, the study ignores the fact that LEVA-EU’s proposals have been recommended by the Expert Group on Urban Mobility to the European Commission. By contrast, the proposals of the Zweirad-Industrie-Verband (ZIV) are framed as pragmatic and stabilising. This rhetorical imbalance conceals the fact that the ZIV’s suggestions—such as additional limits on weight, power and support ratios—would in practice push many EPACs into Regulation 168/2013.

    This would result in type approval requirements, with the accompanying terms of use that are not adapted to the vehicles such as no access to bicycle traffic rules, helmet obligations, motor vehicle insurance obligations, etc. Such a shift would devastate large parts of the market. None of this is acknowledged in the study.

    Finally, the study leans heavily on the results of a Civey user survey, which finds that most current EPAC owners are satisfied with their Electrically Power Assisted Bicycles and see little need for change. While this finding is unsurprising, it is also limited. Surveys of today’s users naturally reflect the bulk of the existing market, but they say nothing about the untapped demand for vehicle categories that are currently limited or excluded by Regulation 168/2013. Presenting these results as evidence for regulatory stagnation misses the wider picture.

    Europe’s mobility transition cannot be achieved by freezing outdated definitions in law. A regulatory framework that is truly fair and future-proof must be based on technical neutrality, must enable innovation, and must ensure that the full diversity of EPACs and light electric vehicles can reach the market. This conclusion is also supported by the conclusions of the LEV4Climate study conducted by the German Aerospace Center (DLR) and commissioned by LEVA-EU. The study demonstrated that light electric vehicles have significant potential to reduce greenhouse gas emissions and replace car trips—potential that can only be realised if legislation allows a broad spectrum of LEVs onto the market rather than restricting them to narrow, outdated categories. Protecting the status quo may serve the interests of incumbent industry players, but it undermines the broader goals of sustainability, innovation and inclusivity.

    Annick Roetynck, LEVA-EU Managing Director, concludes: “Europe’s mobility transition cannot succeed by freezing yesterday’s definitions in law. We need a regulatory framework that is fair, technically neutral, and future-proof—one that enables the full diversity of EPACs and LEVs to reach the market.”

  3. Last Call for LEVA-EU Standardization Workshop 27/02

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    Tomorrow, Tuesday 27 February, LEVA-EU is presenting an exclusive workshop on standardization for light, electric vehicles, including EPACs, E-Cargocycles, E-Scooters, etc. This insightful event is co-organized with  SBS and promises a deep dive into the realm of standardization, offering invaluable information.

    The event will take place online only from 1 p.m. to 5 p.m.

    Participation in the workshop is free for LEVA-EU and for SBS Members. Non-members pay € 175 for one participant, € 325 for 2 and € 450 for three. Participants must register in advance here: https://rb.gy/aq6s9p.

    Upon registration (members) and payment (non-members), we will send you an invitation with a online link to the workshop shortly before the start of the meeting.

    The agenda is as follows:

    1. Short presentation LEVA-EU and SBS

    2. What are standards?

    3. Why European/international standards?

    4. How is a standard being made?

    5. How is a standard structured?

    6. What’s the procedure to make and vote standards?

    7. Why and how participate?

    8. What’s the relation between standards and legislation?

    9. What is (the use of) harmonizing standards?

    10. How is a standard applied/used?

    11. Which standards, relevant for light electric vehicles are currently being drafted?

    12. What are the relevant published standards?

  4. EN 50604-1+A1 is not a legal requirement for EPACs

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    LEVA-EU is receiving many questions regarding the new battery requirement introduced in the EPAC-standard EN 15194. The most popular question is whether the new clause is a legal requirement, to which the answer is no. Before discarding your battery stock or hastily procuring new batteries complying with EN50604-1:2016 and EN 50604-1:2016/A1:2021, please read the following.

    In the current EPAC-standard EN 15194:2017, clause 4.2.3.2 specifies the test method for the battery, with a note suggesting that testing “for example according to EN 62133 or EN 50604-1 is considered as sufficient test to fulfil this requirement.” Many years ago, the Netherlands issued a formal objection against this part of the EN 15194 being harmonized under the Machinery Directive. The Netherlands argued that the requirement is insufficient to guarantee safe batteries. It took the European Commission equally many years to officially lift the harmonization of the battery requirement, through a decision published in January this year. This decision means that EPAC- manufacturers no longer enjoy presumption of conformity for the battery in their EPAC. In case of battery-related incidents, it’s now up to the manufacturer to prove that the battery was compliant with the Machinery Directive, which is a legal obligation.

    To address the harmonization issue, CEN TC333, responsible for EN 15194, opted to replace the entire clause 4.2.3. with a new clause referencing EN 50604-1:2016 and EN 50604-1:2016/A1:2016 as the only valid standard to use for EPAC-batteries. The amended standard with the new clause, EN 15194:2017+A1:2023 became available on 23 August 2023 and stipulates a transitional period of 2 years. During this period, manufacturers may use either the clause in the “old” EN 15194 or the clause in the amended standard EN 15194:2017+ A1:2023. As of 23 August 2025, the old standard will no longer be valid and therefore only batteries complying with EN50604-1:2016 and EN 50604-1:2016/A1:2021 will be in line with the requirements in the standard.

    Importantly, it must be reiterated that this is not a legal requirement; EN 15194:2017+A1:2023 serves as a means to comply with the Machinery Directive. Manufacturers retain the legal freedom to apply alternative or additional measures they deem state-of-the-art.

    Another, very important point is the fact that using the new battery clause does not yet confer harmonization with the Machinery Directive, leaving manufacturers responsible for proving conformity in case of incidents. Harmonization requires a decision by the European Commission, published in the Official Journal. There is no information available as to when this might happen. The competent Commission department is very busy with the implementation of the new Machinery Regulation, which will replace the Machinery Directive as of 14 January 2027.

    To date, there is no certainty as to whether EN 15194:2017+A1:2023 will get harmonized under the Machinery Regulation. What’s more, CEN TC333 has just decided to fundamentally review the existing standard, which is now 5 years old. This is another exercise that may well influence the battery requirement in the future standard.

    LEVA-EU has consistently advocated for a selective implementation of EN 50604-1:2016 and EN 50604-1:2016/A1:2021 in EN 15194, focusing on relevant requirements for EPACs. Since LEVA-EU’s plea was ignored, the industry now grapples with stringent battery requirements amid the prevailing uncertainty about harmonization. Fortunately, in IEC TC125 an ad hoc group has been created to investigate which battery requirements in different standards, including EN 50604, are most suitable for e-transporters. The results of this exercise can also be used in the revision of EN 15194. Until then, the message remains clear: EPAC manufacturers can currently use batteries complying with EN 62133, EN 50604-1 or with EN50604-1:2016 and EN 50604-1:2016/A1:2021, with none providing presumption of conformity with the Machinery Directive. It is advisable to leverage personal or supplier knowledge of state-of-the-art to ensure that batteries meet the legal safety requirements as mandated by the Machinery Directive.

    Annick Roetynck, LEVA-EU Manager, annick@leva-eu.com

    Photo by Henry & Co. on Unsplash

  5. EU Commission finally confirms: Series Hybrid Cycles are EPACs excluded from L-category

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    In 2018, several German e-bike dealers received an official warning from Kraftfahrt Bundesambt (KBA), the official German approval authority. If they were to continue selling a specific electric bike without a chain as an EPAC, they could receive a € 5,000 fine. The electric bike concerned differed from other bikes by the absence of a chain. Instead, it had a so-called Series Hybrid (SH) system. It took LEVA-EU and its members almost 5 years of hard work to convince the European Commission and the Members States that Series Hybrid Cycles are EPACs after all.

    An EPAC is a pedal assisted cycle with maximum 25 km/h and 250W, excluded from Regulation 168/2013 following Article 2.2(h). A vehicle equipped with a Series Hybrid drive system has no mechanical chain. Instead, energy flows directly from a pedal generator into the motor. According to KBA, such vehicles required type-approval in the L-category. Later, BMVI, the German Transport Ministry came out in support of the KBA-position. The concerned bike was even literally chained up for over a year. However, a few years earlier, the Dutch approval authority, RDW, had issued a formal statement to confirm that they considered a cycle equipped with a Series Hybrid system to be an EPAC, excluded from Regulation 168/2013.

    In the meantime, more companies started to develop SH systems and, especially e-cargocycle manufacturers discovered the many advantages of the system for their vehicle. Because the system has fewer mechanical parts, it offers the benefit of less wear and maintenance costs. That in turn allows for reduction of fleet maintenance and service intervals. It also offers more design freedom and a higher potential to customize the digital system to the needs of specific riders, e.g. for elderly and handicapped people, commuters, delivery and courier riders, etc. Finally, the SH-system also allows a reverse function, which is particularly interesting for e-cargocycles or other EPACs with more than 2 wheels.

    From its start, LEVA-EU has argued and worked for the removal of legal bottlenecks in technical legislation, which seriously obstruct technological development. LEVA-EU’s position on technical legislation for light electric vehicles is based on the principles of kinetic energy and technology neutrality. LEVA-EU therefore immediately committed to help its members concerned with the SH-issue.

    A first meeting with the European Commission in 2018 yielded no result. Nevertheless, LEVA-EU continued to work on the issue. In ISO, CEN and IEC, LEVA-EU experts also actively and consistently worked to ensure for SH systems to be covered by ISO, CEN and IEC-standards.

    Towards the end of last year, LEVA-EU requested a new meeting with the Commission. By that time, the trade association for LEV-businesses, had no less than 12 members concerned by Series Hybrid. The uncertainty on the legal status of Series Hybrid, in or out of Regulation 168/2013, was becoming a major stumbling-block for their potential customers and/or investors.

    In close cooperation with these 12 members, LEVA-EU explained in detail the technical aspects of the system as well as its market potential to the Commission. Following that consultation, the Commission had a meeting with the EU Member States in the Forum for the Exchange of Information on Enforcement on 17 February. At that meeting, the Commission clarified the following “on the requirements that need to be met by pedal cycles to meet the requirements of Article 2.2(h) of Regulation 168/2013”:

    • Equipped with an auxiliary electric motor with a max continuous rated power of 250 W.
    • The motor is cut off when the cyclist stops pedaling.
    • The motor is otherwise progressively reduced and finally cut off before it reaches 25 km/h.
      • The auxiliary function of the motor means that the vehicle should not be able to be propelled by the motor only, without pedalling (except for the walk assist up to 6 km/h).
    • The motor provides assistance only as long as the cyclist pedals continuously.
    • Whether the vehicle has a chain or not is not taken into consideration to fall under this exemption: respect of technology neutrality.

    The Commission herewith officially confirmed that electric cycles equipped with a SH-system are EPACs, excluded from Regulation 168/2013, Article 2.2(h). The Commission also confirmed that there were no further comments from the Member States as the Commission’s interpretation was accepted by all.

    This statement finally puts an end to an agony that has lasted for almost 5 years and to a problem that posed a significant threat to the development and success of electric cycles in general and electric cargocycles in particular. This statement also provides WG9 in CEN TC333 – Cycles, which is in the process of developing standards for e-cargocycles, with a definitive answer as to whether the SH system should be taken into account in future standards or not. And last, but not least, e-cycles equipped with a SH-system enjoy the same status on the road as conventional bicycles in all EU Member States.

  6. European Commission: Machinery Directive unsuitable for vehicles

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    The support for LEVA-EU’s proposals in favour of a review of light electric vehicle legislation appears to be growing. The Commission has now explicitly confirmed that the Machinery Directive is not suitable for vehicles. In their study for the Commission, TRL recommends the creation of a dedicated approval process for PMDs, separate from Regulation 168/2013 and the Machinery Directive.

    In the Motorcycle Working Group meeting of 17 March, TRL has presented its long-awaited study on so-called Personal Mobility Devices (PMD) and type-approval legislation. The study is aimed at helping the Commission to decide whether current technical legislation for PMDs needs changing. The term PMD covers a broad range of light, electric vehicles such as electric cycles for personal transport or to carry people or cargo, speed pedelecs, e-scooters, monowheels, self-balancing vehicles etc.

    Today, some of these vehicles, such as speed pedelecs or cargocycles with more than 250W come under type-approval. Other vehicles, such as electric bikes with pedal assistance up to 25 km/h and 250W, e-scooters or self-balancing vehicles are excluded from type-approval and come under the Machinery Directive.

    From the day the association was established, LEVA-EU has argued that both regulatory frameworks are ill-adapted and inaccurate for light, electric vehicles (LEVs). In anticipation of the TRL-study, LEVA-EU had developed an exhaustive position paper. The main point for LEVA-EU is to take LEVs up to 50 km/h out of both Regulation 168/2013 and the Machinery Directive. Instead, the EU should develop a new horizontal Vehicle Regulation, which could be complemented with harmonized standards and, if necessary, for certain vehicles even type-approval.

    TRL has clearly taken LEVA-EU’s arguments on board. One of the objectives of the study was to formulate recommendations for the Commission. Among the 8 recommendations is the following: “Create a dedicated approval process for PMDs separate from Regulation (EU) No 168/2013 and the Machinery Directive.” It even looks like LEVA-EU has won at least one big battle. Shortly before the Motorcycle Working Group meeting, the Commission confirmed in an email to LEVA-EU: “(…) as far as the Machinery Directive is concerned, we would like to inform you that the directive was never meant to cover vehicles for the transport of people on the road. PMD are intended for the transport of people on the road, and as such, the Machinery Directive is not the right safety legal framework for them. In the revision of the Directive we intend to clarify this point.”

    This confirmation comes exactly 15 years after ETRA and COLIBI/COLIPED asked the Commission in vain to exclude electric bicycles with pedal assistance up to 25 km/h and 250W from the Machinery Directive.

    This confirmation also comes at a time when it is becoming painfully clear how difficult, if not impossible, it is to harmonize standards for PMDs under the Machinery Directive. The attempts failed for the EN 17128:2020 and recently also for the PrEN 17404, the draft standard for electric mountain bikes. Furthermore, the harmonization of EN 15194:2017 is under threat following two formal objections. All this makes it increasingly clear that the Machinery Directive is not suitable for vehicles. What’s more, it damages the LEV-businesses who have to comply with this unsuitable Directive whilst being deprived from suitable tools, i.e. harmonized standards, for that compliance.

    The question remains how the Commission is going to follow up on their conclusion that the Machinery Directive is unsuitable. There are only two options available. The first one would be to move the vehicles from the Machinery Directive into Regulation 168/2013. However, this goes against TRL’s recommendation to “ensure that EPACs remain outside the scope of Regulation (EU) No 168/2013”. If EPACs stay out of the Regulation, where would they go instead? Also, how could one justify bringing other light vehicles with the same maximum speed, such as e-scooters, under the Regulation after all? All this points even more towards a separate regulation dedicated to Zero Tailpipe Emmission Vehicles as the only fundamental solution.

    Unfortunately, TRL seems to be supportive of this idea only for vehicles up to 25 or 30 km/h. For vehicles with a higher speed, they only refer to speed pedelecs and thereby make a particularly unfortunate recommendation. They suggest to move speed pedelecs to L1e-A, whilst adding a 1,000W power limit. This is unfortunate because the recommendation does not clarify that type-approval requirements would still need to be adapted to the vehicles. Furthermore, the recommendation does not take into account that L1e-A is currently a technology neutral category. That means it is open to all types of cycles, not only with pedal assistance. Finally, it is unfortunate because this recommendation does not take into account that there are light, electric vehicles with a speed limit of 45 km/h other than speed pedelecs.

    The only positive element in the recommendation for speed pedelecs is the removal of the maximum assistance factor four. In an earlier study on factor four, TRL had concluded that there is no evidence showing that factor four has either a positive or negative impact on safety. However, this conclusion did not lead TRL to recommend the removal of the maximum assistance factor. Apparently, TRL has found something in this new study that has made them change their mind.

    Another disappointing recommendation relates to power limitations. TRL states: “If it is necessary to regulate maximum motor power do so at a level that does not discourage the development of new vehicle configurations (1,000W).” This wording only implies doubt about the necessity of power limits. What’s worse, it doesn’t mention the absolute necessity of requirements to ensure safe control of acceleration, as proposed by LEVA-EU. Hopefully, the full argumentation behind this recommendation will be in the study itself.

    The study is not completed yet. At the Motorcycle Working Group meeting, TRL only showed the following presentation: https://bit.ly/3f4DofZ. LEVA-EU also had the opportunity to respond in the meeting with a short presentation, which is here: https://bit.ly/3vQuFDV

    The Commission concluded that if they were to go ahead with a review, that work would not be initiated before the second half of next year. Such a review would first require a road map and an impact assessment. LEVA-EU will ask the Commission about this timing. It seems to us that, given the urgency of the climate crisis, no further time should be wasted in removing legal bottlenecks to unlock the market potential of light electric vehicles.

    For further details, contact Annick Roetynck, annick@leva-eu.com

    Photo by Aaron Burden on Unsplash