Comments Off on Last Call for LEVA-EU Standardization Workshop 27/02
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?
Comments Off on EN 50604-1+A1 is not a legal requirement for EPACs
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.
Comments Off on EU Commission finally confirms: Series Hybrid Cycles are EPACs excluded from L-category
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.
Comments Off on European Commission: Machinery Directive unsuitable for vehicles
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