Tag Archive: european commission

  1. Personal Mobility Devices Workshop – Commission: quo vadis?

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    The very well-attended European Commission workshop on Personal Mobility Devices (PMD) left us with mixed feelings. It is far from clear which direction the Commission wants to take further.


    Attendance was high for the Commission’s workshop on Personal Mobility Devices (PMDs). There were more than 70 people in the Brussels’ meeting room and about 150 attendants online. Unfortunately, the meeting could not really pass as a workshop. The Netherlands, France, Germany and Spain were given extensive time to present their national rules, mainly for e-scooters. After that, there was hardly any time left for discussion.

    Also, it is not clear what the purpose of presenting those national rules was. The workshop was organised by the Commission unit, which is responsible for Regulation 168/2013. E-scooters, along with electric bicycles and self-balancing vehicles, do not fall under Regulation 168/2013 but under the Machinery Directive. Consequently, one would expect that the Commission unit competent for the Machinery Directive would have at least attended the meeting. Quod non.

    Mark Nicklas, who became Head of the unit responsible for Regulation 168/2013 not that long ago, stated that he himself was not so sure where the current legislation came from. He argued that Regulation 168/2013 had been introduced at a time when PMDs did not really exist yet. However, electric bicycles, e-scooters and self-balancing vehicles were already on the market in 2013. The Commission deliberately excluded them from Regulation 168/2013 because they simply did not know what to do with them. Moreover, they did not realise that by excluding them, they were referring the vehicles to the Machinery Directive. Even almost 10 years later, Mark Nicklas admitted that he was very surprised, when he took on his new position, to find that the vehicles were covered by the Machinery Directive.

    Nevertheless, the Netherlands, Germany and Spain explained at length the specific national technical rules they had developed, because they believe there is no European framework. So, they simply ignore the Machinery Directive as the current European harmonized framework for PMDs excluded from Regulation 168/2013. At the same time, through the Council, these very same member states have overruled the Commission’s proposal to exclude PMDs from the new Machinery Regulation to create an opportunity for a specific harmonized technical framework for PMDs.

    It is particularly unfortunate and incomprehensible that with this workshop, the Commission did not address the member states on their illogical and possibly illegal national rules. It is particularly unfortunate and incomprehensible that the Commission did not seize the opportunity of this workshop to start a real discussion on a European harmonized PMD framework. Nevertheless, the few companies that managed to get the floor, clearly expressed their despair at having to make a different vehicle for almost every member state. One of them was Nathan Debaets, from Taito a young Belgian company and member of LEVA-EU, which is enthusiastically developing a high-quality e-scooter. He stated: “It is nearly impossible for a start-up like ours to follow up on all those different requirements.

    The Light Electric Vehicle (LEV) sector has been plagued and hampered by legal obstructions for over a decade now. In these times of climate, energy and cost-of-living crises, it is no longer morally justifiable for the European Union to continue to shelve a European LEV-framework.

  2. European Commission announces 100 cities participating in EU Mission for climate-neutral and smart cities by 2030

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    The European Commission today announced the 100 EU cities that will participate in the EU Mission for 100 climate-neutral and smart cities by 2030, the so-called Cities Mission. The 100 cities come from all 27 Member States, with 12 additional cities coming from countries associated with, or with the potential of being associated with, Horizon Europe, the EU’s research and innovation programme (2021-2027).     

    Our urban areas are home to 75% of EU citizens. Globally, urban areas consume over 65% of the world’s energy, accounting for more than 70% of CO2 emissions. It is therefore important that cities act as experimentation and innovation ecosystems to help all others in their transition to becoming climate-neutral by 2050.

    Ursula von der Leyen, President of the Commission, said: “The green transition is making its way all over Europe right now. But there’s always a need for trailblazers, who set themselves even higher goals. These cities are showing us the way to a healthier future. We will support them on this! Let’s begin the work today.”

    The Cities Mission will receive €360 million of Horizon Europe funding covering the period 2022-23, to start the innovation paths towards climate neutrality by 2030. The research and innovation actions will address clean mobility, energy efficiency and green urban planning, and offer the possibility to build joint initiatives and ramp up collaborations in synergies with other EU programmes.

    Benefits for cities include tailor-made advice and assistance from a dedicated Mission Platform run by NetZeroCities, additional funding and financing opportunities and the possibility to join large innovation actions and pilot projects. The Mission also provides networking opportunities, exchange of best practices between cities and support to engage citizens in the mission.

    Next Steps

    The Commission will invite the 100 selected cities to develop Climate City Contracts, which will include an overall plan for climate neutrality across all sectors such as energy, buildings, waste management and transport, together with related investment plans. This process will involve citizens, research organisations and the private sector. The clear and visible commitments made by the cities in the Climate City Contracts will enable them to engage with the EU, national and regional authorities – and most importantly with their own citizens to deliver on this ambitious objective.

    Moreover, in light of the overwhelming interest from 377 cities to join the mission, the Commission is also putting in place support for cities that were not selected, including support through the Mission Platform and funding opportunities under the Cities Mission Work Programme of Horizon Europe.

    Members of the College said:

    Executive Vice-President Frans Timmermans, for the European Green Deal, said: Cities are at the forefront of the fight against the climate crisis. Whether it’s greening urban spaces, tackling air pollution, reducing energy consumption in buildings, or advancing clean mobility solutions: cities are often the hub of the changes Europe needs to succeed in our transition to climate neutrality. My congratulations to the cities selected today, I look forward to the solutions you will develop to guide your inhabitants and businesses towards a greener future.

    Executive Vice-President Margrethe Vestager, for A Europe Fit for the Digital Age, said: “We need to speed up Europe’s transition to climate neutrality, to end our reliance on fossil fuels, and to deliver benefits such as cleaner air and lower energy bills for our citizens. It is great that so many cities will participate. We can support their ambition with our EU research and innovation budget. The Cities Mission has the potential to make a major contribution to our Green Deal and for Europe to become a climate-neutral continent by 2050.” 

    Mariya Gabriel, Commissioner for Innovation, Research, Culture, Education and Youth, said: “Horizon Europe Missions have a great potential to deliver the European Green Deal objectives, including European energy security. The selected cities represent a first step in covering a wide geographical footprint. We want concrete benefits to reach all our regions and citizens, through innovation, empowering large and small cities with different levels of experience and capacities. I encourage all cities to reach out and work with all stakeholders, including of course their citizens, to achieve together our ambitious goals.”

    Adina Vălean, Commissioner for transport, said: “In their quest to become smart and climate-neutral by 2030, the 100 EU cities announced today will be natural “test beds” for innovative integrated solutions to many of the issues facing our citizens today, including urban mobility. Drawing on our New Urban Mobility Framework, they have the tools to make interurban and urban mobility healthy and sustainable, for instance by doubling high-speed rail traffic and developing extra cycling infrastructure over the next 10 years, investing in safe bike lanes, and ensuring connectivity with rural and suburban areas so that commuters are given sustainable mobility options. I am sure they will succeed, and I encourage other cities across Europe to follow their lead.”

    Virginijus Sinkevičius, Commissioner for Environment, Oceans and Fisheries said: “The Mission for climate-neutral and smart cities will help us deliver our environmental commitments on zero pollution, biodiversity and circular economy. Many of the selected cities have already shown their environmental credentials in our Green Capital, Green Leaf and Green City Accord initiatives by tackling air, noise and waste issues. These cities’ ambitions for climate and innovation, as well as the Mission’s wider research funding, will help make urban living greener, cleaner and healthier for European citizens.”

    Background

    Cities were invited to express their interest to become part of the Mission in November 2021. The call closed on 31 January 2022. In a first step, independent experts evaluated each expression of interest. In a second step, the Commission applied additional criteria to ensure a geographical balance and a diverse group of cities in terms of size, impact and innovative ideas. Overall, 377 cities applied to be part of the cities mission. The 100 EU Cities chosen today represent 12% of the EU population. 

    The Commission launched the Mission for 100 climate-neutral and smart cities by 2030 in September 2021 with the adoption of a Communication on EU missions. This following the approval of the missions’ individual implementation plans in summer 2021. As well as the Cities Mission, there are four other EU missions covering global challenges in the areas of adaptation to climate change, restoring our ocean and waters, healthy soils and cancer. A dedicated Work Programme for Horizon Europe Missions was published on 15 December 2021. 

    Missions are a novelty of Horizon Europe and support Commission priorities, such as the European Green DealEurope fit for the Digital AgeEurope’s Beating Cancer PlanAn economy that works for people and the New European Bauhaus. For instance, Mission Climate is already a concrete element of the new Climate Adaptation Strategy, Mission Cancer of Europe’s Beating Cancer Plan and the Mission Soil is a flagship initiative of the Long-term Vision for the EU’s Rural Areas.

  3. TRL-study: LEVA-EU pleased but not fully satisfied

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    LEVA-EU has fully analysed the TRL-study on Personal Mobility Devices for the European Commission. The trade association is extremely pleased with TRL’s conclusion that dedicated legislation for LEVs is the best way forward. However, LEVA-EU is not as pleased with some of the finer details of the study.


    Regulation 168/2013 on the approval and market surveillance of 2- or 3-wheel vehicles and quadricycles is the core of technical legislation and categorization of light electric vehicles (LEVs).

    These are either included in the scope of the legislation. That is for instance the case for electric cargocycles with more than 250W or for speed pedelecs. Or, they come under one of the exclusions listed in Article 2.2 of the Regulation. That is for instance the case for EPACs, i.e. electric bikes with pedal assistance up to 250W and 25 km/h, but also for e-scooters, self-balancing vehicles, etc.

    If they are excluded from Regulation 168/2013, the vehicles come under the Machinery Directive. This opens the possibility of developing harmonized standards, which offer presumption of conformity. If your vehicle complies with the standard, it is presumed to be in conformity with the Machinery Directive.

    So far, there is only one harmonized standard for LEVs, i.e. EN 15194:2017. The EN 17128:2020 for vehicles without a seat and self-balancing vehicles has not been harmonized.

    Two major legal problems

    Current legislation for LEVs poses two major problems. First, the legislation has not been specifically written for LEVs and is therefore not adequate. This results in very serious legal bottlenecks, which obstruct market development. One of the worst affected vehicle categories is L1e-A “Powered Cycles”, i.e. electric cycles with a maximum speed of 25 km/h and maximum 1 kW. As a result, virtually no vehicles have been type-approved in L1e-A

    Second major problem is that inclusion in Regulation 168/2013 results in national rules that are particularly restrictive and hindering, since they have been developed for vehicle concepts, which are quite different from LEVs. The worst example is the categorization of speed pedelecs as mopeds. Consequently, in most member states they are subject to moped terms of use that seriously hinder the use of speed pedelecs, thus the market development.

    Commission acknowledges problems

    Vehicles excluded from Regulation 168/2013 are for their use completely dependant on national rules. Some member states for instance do not allow the use of e-scooters on public roads. On the other hand, all member states have granted EPACs the same status as conventional bicycles, which allowed the market to prosper.

    As the market is growing, the European Commission is beginning to acknowledge that there are problems. In April, the Commission has proposed to exclude all vehicles from the Machinery Directive. With that however, the Commission has not yet made any statements as to where these excluded vehicles should be housed instead. It appears this decision is left to the Commission department responsible for Regulation 168/2013.  

    5 regulatory options

    Last year, that department has commissioned TRL to conduct a study into so-called “Personal Mobility Devices” (PMDs). This term covers standing and seated e-scooters, EPACs, L1e-A Powered Cycles, cycles designed to pedal in L1e-B (speed pedelecs), electric cargocycles, self-balancing vehicles, e-hoverboards, e-monowheels and e-skateboards.

    The study had 5 objectives:
    1) to provide a PMD-inventory
    2) to provide a detailed analysis of the market and of the influence of existing legislation at EU and national level
    3) to collect and evaluate data on PMD-accidents
    4) to assess current use and safety aspects of PMDs not covered by Regulation 168/2013
    5) to provide recommendations on technical requirements and traffic rules

    The most important element of the study consisted of the 5 regulatory options, which TRL formulated:

    1. Include all PMDs within the scope of Regulation (EU) No 168/2013,
    2. Exclude from the scope of Regulation (EU) No 168/2013 any PMD with a maximum speed less than 25km/h,
    3. Exclude from the scope of Regulation (EU) No 168/2013 any PMD with a maximum speed less than 30km/h,
    4. Exclude from the scope of Regulation (EU) No 168/2013 any PMD with a maximum motor power less than 1,000W, and
    5. Devise a dedicated system for the harmonised approval of PMDs that is separate from both Regulation (EU) No 168/2013 and the Machinery Directive.

    Preferred option

    TRL added a judgment to these options. Option 1 should be dismissed. Options 2, 3 and 4 would simplify the criteria for exclusion from Regulation 168/2013. This would open up possibilities for creating new types of PMDs. However, TRL points out that these options do not resolve the issue of harmonizing the rules for PMDs across Europe. Option 5 provides for technical regulation outside the Machinery Directive and Regulation 168/2013 and would, according to TRL, be tailored to the needs of the PMD industry. The system could include a variety of assessment methods, ranging from self-certification to independent testing. TRL concludes on option 5: “In our view this new system for the regulation and approval of PMDs would provide the flexibility necessary to support innovation in this rapidly evolving sector, while maintaining technical standards and road safety.

    Option 5 itself does not hold any criteria for exclusion from Regulation 168/2013. TRL suggests that for this purpose, option 5 could be combined with option 2, 3 or 4. In their recommendations they take the matter a step further: they propose to exclude all vehicles up to 30 km/h from Regulation 168/2013. The proposal to increase the limit to 30 km/h is “to bring the speed of these vehicles in line with the speed limits now being used in many urban areas”.

    In line with LEVA-EU position

    TRL’s preferred option, i.e. dedicated LEV-legislation, is fully in line with LEVA-EU’s position as explained in our position paper. Such dedicated legislation offers many advantages that are essential to the development of the LEV-market. Just like Regulation 168/2013 does for conventional mopeds and motorcycles, a horizontal regulation with essential requirements for all LEVs can provide for an automatic right for vehicles to be placed on the market. This would prevent Member States from denying vehicles that comply with the Regulation access to public roads.

    Second important advantage is that such a horizontal Regulation will force Member States to think carefully about categorization of vehicles. It will no longer be possible to bury them in unadapted categories, as is the case now, for example with L1e-A vehicles and speed pedelecs in the moped category.

    The Member States will also be forced to think about the terms of use for LEVs. LEVA-EU believes that the Commission must play a proactive role in this by encouraging the Member States to exchange experience and of best practice. In this framework, the Commission could for instance initiate an LEV observatory. This observatory could monitor market developments and analyse how regulations in the Member States influence that development.

    And last but not least, dedicated legislation will curb the growing tendency of Member States to develop their own, national, technical requirements. This will allow the LEV-sector to return to the basic principle of the single market in which manufacturers can supply the whole of the EU with one and the same vehicle. This, in turn, creates the possibility to organize structural consultation with the LEV-sector on that technical legislation. Today, the national requirements developed by Member States are too often resulting from guesswork.

    Repurpose L1e-A

    Whilst LEVA-EU fully supports TRL’s preferred option for dedicated legislation, we find their additional proposals unacceptable and illogical. In their recommendations, they propose to only exclude vehicles up to 30 km/h from Regulation 168/2013. For vehicles with a higher speed limit, such as speed pedelecs, TRL suggests to repurpose category L1e-A. In this category the speed limit should be raised to 45 km/h, whilst the power limit of 1,000 W could be retained.

    TRL adds: “The revision of this category would provide for mechanism by which cycles designed to pedal could be regulated separately from mopeds. This would allow special consideration to be given to the standards and tests that need to be applied to these vehicles without inadvertently interfering with the arrangements in place for mopeds. Moving cycles designed to pedal into L1e-A would also permit manufacturers to design three and four wheeled cycles designed to pedal, which are currently not permitted under L1e-B, thus creating a sub-category that would be highly suitable for pedal assisted cargo tricycles and quadricycles.

    Under the heading “Important findings and recommendations”, TRL states the following on type-approval: “It should be noted that for pedal cycle derived vehicles different frame sizes of the same model and men’s and ladies’ versions of the same model are treated as separate types for type approval purposes. Thus, the overall cost of getting one model of bicycle approved may be some multiple of that figure. However, the costs of type approval do not add significantly to the overall purchase price to the consumer – one manufacturer estimated that type approval added only €8 per vehicle sold. More important than the economic cost of the process was the incompatibility of the business model of many PMD manufacturers and importers who have a short design cycle, often releasing new models every year and a diversified supply chain that has been developed to ensure resilience and redundancy so that component availability never stops production. This approach is fundamentally at odds with the type-approval system which requires design-freeze at the point of assessment and robust conformity of production throughout the product’s lifecycle. Clearly some middle ground needs to be found that ensures the safety and environmental sustainability of PMDs while acknowledging the differences in business approach between the PMD and automotive industries. An approach that is proportional to the level of risk resulting from potential technical failures should be devised.

    The issue of type-approval

    We find it utterly illogical for TRL to conclude one thing for EPACs and something completely different for current L1e-A vehicles and cycles designed to pedal up to 45 km/h, such as speed pedelecs. All the above is equally valid for all those “pedal cycle derived vehicles”, which are now in type-approval.

    The issue of the type-approval system is mainly to do with the fact that conventional mopeds and motorcycles are made up of components that are specifically designed for these vehicles and “pedal cycle derived vehicles” not. These are assemblies for components that may be used in different types of vehicles both in and out of type-approval. This shows that the TRL-study fails to meet one of the 5 predefined objectives: to provide a detailed analysis of the of the influence of existing legislation at EU level. The report does not say a word about the technical inappropriateness and inaccuracy of type-approval for light, electric vehicles. The proposal for repurposing L1e-A is therefore fundamentally unfounded. All arguments to set up dedicated legislation for LEVs up to 30 km/h are equally as valid for LEVs up to 50 km/h. LEVA-EU will continue to work for this.

    Factor 4

    One last important footnote: TRL proposes to get rid of assistance factor 4, should L1e-A be repurposed for vehicles up to 45 km/h and 1,000 W. That power limit “would provide sufficient differentiation from L1e-B.” To LEVA-EU this means exchanging one superfluous obstacle for another. The fact that TRL fails to acknowledge the huge damage caused to the LEV-sector by clinging to maximum continuous rated power limits is further proof of the fact that their analysis of the influence of existing legislation is failing.

    Finally, we hope that the European Commission will read the latest edition of “Science for Environment Policy”. A study on material efficiency strategies concludes: “the current demand level of personal motorized transport is compatible with ambitious climate targets only under two major conditions: (1) consumers must switch to more energy- and material-efficient vehicles, for example, smaller or shared electrified vehicles, and (2) the energy used to charge these vehicles must be highly decarbonized.” They add that policy incentives will be required in order to nudge consumers toward more efficient behaviour. Specific LEV-legislation that allows the market to develop is one of those required policy incentives.

    Photo by Aaron Burden on Unsplash

  4. LEVA-EU proposes to end discrimination of EU e-bike assemblers

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    On 7 December 2020, LEVA-EU has reported on how Regulation 2020/1296 discriminates EU e-bike assemblers compared to companies that assemble both conventional and electric bicycles. The current rules result in truly surreal situations as described in the article below. Just before Christmas, LEVA-EU has presented the European Commission with amendments to remove the discrimination.


    In order to prevent circumvention of anti-dumping duties on conventional bicycles, in 1997 the European Commission extended the duties to a number of essential bicycle components such as frames, forks, wheels, etc. In 2013, the Commission confirmed that, if these components were to be used for the assembly of electric bicycles, the 48.5% anti-dumping duty did not apply. This was laid down in Regulation 512/2013. E-bike assemblers could obtain that exemption from the duties by applying for end-use authorization. However, it has only now become clear how wrong and unfair the procedure of end-use authorization is.

    Paying for non-existing duties

    First of all, the application for end-use authorization can only be initiated if the company is already importing components. Even though the anti-dumping duty does not apply, the company has to pay the duties until end-use authorization is granted. There is in other words no suspension of duties during the procedure and no possibility of having the duties refunded once authorization is granted. This makes it virtually impossible for new assembly operations of e-bikes tot start up in Europe, unless the company has access to very substantial financial resources.

    End-use authorization is granted by national customs who have the competence to decide on the procedure. In the cases reported to LEVA-EU, the customs impose often excessive administrative conditions and comprehensive guarantees. The authorization is only valid for a limited period of time, upon which companies have to reapply. Also, the companies have an obligation to discharge the end-use within 6 months. There is in other words a deadline for using the parts in the assembly of an e-bike. Imagine, today, with the huge shortage of component supplies that you are being stuck with for instance a number of frames that you cannot use in an assembly because other parts necessary to finish the e-bike will only arrive next year.

    698 days

    National customs authorities are not bound by any time limits in granting end-use authorization. So far, only two companies have confirmed to us that they have effectively obtained the authorization, which took several months. In another case, the company has first introduced an application in August 2018. In June 2020, exactly 698 days after their firs application, their request was denied and they were forced to introduce a new request. All this time, the company paid 48.5% on the essential bicycle components they imported for the assembly of e-bikes.

    Despite that, last summer the company was raided by the customs and subsequently accused of … circumventing anti-dumping on e-bikes! The case may well be referred to a criminal court with the risk of a judicial conviction as well as having to pay anti-dumping duties on e-bikes and penalties. By now, Franz Kafka must be turning in his grave. The crux of the matter is that in the past 2.5 years, customs have made the fundamental mistake of treating this application for end-use authorization as a request for authorization to import less than 300 pieces a month instead of an authorization for the assembly of e-bikes.

    Clear discrimination

    The absurdity of end-use authorization has only come to light following the imposition of anti-dumping duties on electric bicycles. The new measures forced a lot of companies to find alternatives for their assembly operations in China. A number of them decided to move assembly to Europe and often found EU assemblers prepared to subcontract for them. These assemblers had Commission exemptions for the import of bicycle components for conventional bicycles, which they also used to import components for electric bicycles. However, there was uncertainty as to the legality of this process. That is why the European Commission issued Regulation 2020/1296 as a result of which all exemptions for components for conventional bicycles were extended into exemptions also valid for components for electric bicycles.

    However, the capacity of European bike assemblers was quickly exhausted. So, some companies had to establish new assembly operations in Europe for electric bikes only. And these companies bumped into the huge hurdle of end-use authorization.

    Admittedly, for the benefit of e-bike assembly in Europe there was a need for the legal clarification though Regulation 2020/1296. However, why the Commission found it necessary to also introduce a clear discrimination of e-bike assemblers remains a big question mark.

    Substantiated proposal

    In a meeting shortly before Christmas, LEVA-EU asked the Commission exactly that question. We did not get an answer as to the reasoning behind this bizarre Regulation but the Commission invited us to propose a solution to the problem. In the meantime, LEVA-EU in cooperation with its lawyers, has developed a substantiated proposal for amending the Regulation. The proposal is aimed at providing e-bike assemblers with access to the same exemption procedure as companies that assemble both bikes and e-bikes. The procedure would no longer be the competence of national customs authorities but of the European Commission and would be subject to the same deadlines as the existing exemption procedure. During the procedure, duties would be suspended. LEVA-EU also proposes to convert existing end-use authorization into Commission exemptions and on-going applications into applications for Commission exemptions.

    The Commission has acknowledged receipt of LEVA-EU’s proposal. We are now waiting for the Commission’s answer on the substance. However, it is clear that this Regulation, which directly prohibits the establishment of new companies in the EU cannot remain unchanged. LEVA-EU calls on all companies who have applied for end-use authorization as well as those who have obtained end-use authorization to come forward. Please contact Annick Roetynck

  5. Second TRL-survey on-line

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    The second TRL on-line survey for their study on safety requirements for LEVs is online until 4th January.


    At the request of the European Commission, TRL is carrying out a study aimed at identifying the minimum safety requirements for safe use of light, electric vehicles on public roads. The study is also meant to assist the Commission in possible changes of vehicle categorization and technical requirements in the L-category. LEVA-EU welcomes this initiative since the trade association has been consistently arguing that current type-approval needs a fundamental change. The legislation creates huge bottlenecks for light, electric vehicles.

    A first on-line survey for the study took place in October. TRL has now launched a second survey, in which they ask to rate a range of potential regulatory measures. The survey will be online until 4th January.

    If you haven’t received a direct email from TRL inviting you to complete the survey and you wish to do so, please contact Rosie Sharp at TRL, rsharp@trl.co.uk.

    In October, LEVA-EU has organized a series of on-line meetings to provide LEV-companies with a better understanding of the current legislation and the problems resulting from those rules. The presentations and on-line recordings of these meetings are available upon simple request to daan@leva-eu.com. There were 4 meetings, respectively on:

    • E-bikes & Speed Pedelecs
    • E-cargobiles
    • PLEVs
    • 3- & 4-Wheels

    In the framework of this ongoing review, LEVA-EU has proposed to introduce the concept of Zero-Tailpipe Emission (ZEV) vehicles to allow all light, electric vehicles to enjoy the same commercial success as electric bicycles with pedal assistance up to 25 km/h and 25W. Further details on this proposal are here: https://leva-eu.com/leva-eu-proposes-zev-concept-for-light-electric-vehicles-to-give-manufacturers-same-commercial-success-as-e-bikes/

    After this second on-line survey, TRL will organize in January an on-line workshop, in which they will discuss a shortlist of potential measures with the LEVA-sector. The study is expected to be completed by February 2021.

  6. Is EU Commission to overlook LEVs in Strategy for affordable, accessible, healthy and clean transport?

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    The European Commission is currently collecting feedback on their roadmap in preparation of a Strategy for Sustainable and Smart Mobility. One of the objectives of the Strategy will be a 90% reduction of GHG emissions by 2050.

    Having analysed the roadmap, LEVA-EU concludes that the Commission may well once again focus unilaterally on alternative fuels and charging infrastructure to achieve that objective. In it’s feedback, the trade association for businesses in the LEV-sector, claims a prominent role for LEVs in the Strategy. They offer affordable, accessible, healthy and clean transport, which is exactly what the Commission is looking for. The full text of LEVA-EU’s feedback is below.

    LEVA-EU Feedback on the Commission’s Roadmap for an EU Strategy for Sustainable and Smart Mobility

    LEVA-EU is the only trade association in Europe that works exclusively for light electric vehicles. LEVA-EU currently represents around 50 companies, active in various parts of the LEV-business.

    The term light, electric vehicle (LEVs) includes a range of vehicles with one, two, three or more wheels that offer affordable, accessible, healthy and clean transport. These vehicles are included in the L-category or excluded through Article 2.2 of Regulation 168/2013.

    The objectives for the future Sustainable and Smart Mobility Strategy include:

    • Increasing the uptake of zero-emission vehicles
    • Making alternative solutions available to the people and businesses
    • Supporting digitalisation and automation
    • Improving connectivity and accessibility

    To what extent are LEVs at the forefront of the Commission’s mind in achieving these objectives?

    And yet, COVID-19 has clearly shown to what extent LEVs effectively offer a solution for sustainable transport. Thousands of cities throughout Europe, literally gave way, not only to pedestrians and cyclists but also to electric bicycles, electric cargo bikes, e-scooters, electric mopeds, light electric three and four-wheeled vehicles: affordable, accessible, healthy and clean transport.

    And yet, the EU and its member states either ignore or marginalize LEVs, or both. With the UK and the Netherlands, we only quote 2 examples of countries that are still not allowing e-scooters on public roads. In other member states, millions of citizens use them for short trips … trips, a large percentage of which previously would have been done by car. Fifty percent of all car trips in the EU are less than 5 km and 30 percent even less than 3 km. And still, the Commission is focussing to a very large extent on alternative fuels and on charging infrastructure, in other words on cars. In the meantime, millions of people have taken up commuting by e-scooter, e-bike, speed pedelec, … whilst a growing number of businesses deliver their goods and services by electric cargo bikes.

    The growing shortage of road space for pedestrians, bicycles and LEVs stirs up a public and political debate, not about pushing back big, polluting, noisy, dangerous, expensive vehicles and giving back space to affordable, accessible, healthy and clean travel. The debate is about how to continue to squeeze all that sustainable transport onto little strips on the side of the road.

    LEVs do not need alternative fuels, nor charging infrastructure. They all work on small amounts of electricity, which they can get from just plugging them into any power point. LEVs first and foremost need the right regulatory framework. Their uptake is very seriously hampered by European and national regulatory bottlenecks, which the Commission refuses to solve.

    The roadmap promises to set the right regulatory and non-regulatory framework for a leading European transport industry, both in clean and connected mobility. The plea for taking LEVs out of the legislative framework for ICE mopeds and motorcycles to give them their own accurate framework is now more than 20 years old. The LEV market still consists for 95% of electric bicycles with pedal assistance up to 25 km/h and 250W. These electric bicycles are the only LEVs to enjoy their own regulatory and non-regulatory framework. The market needs new solutions, a wider variety of vehicles but Regulation 168/2013 remains untouched, causing no type-approvals in L1e-A, huge constraints for electric cargo-bikes and speed pedelecs and many people with physical impairments being denied access to electric bicycles.

    Furthermore, LEVs need exchange of good practice, research and regulatory support for:

    • sufficient and safe on and off-road infrastructure for LEVs
    • the modernisation and update of national traffic codes, which today or still based on outdated vehicle concepts
    • the integration of LEVs in MaaS
    • the development of the most effective fiscal incentives
    • the integration of LEVs as full-fledged transport solution in public procurement

    Under the title “Problem the initiative aims to tackle” the Commission writes: “Investments in sustainable alternative fuels and clean technologies as well as renewals of transport fleets by public authorities and companies are essential to achieve the transition that is needed.

    This clearly shows the lack of awareness among the Commission as to the potential of LEVs in “delivering a 90% reduction in transport-related greenhouse gas emissions by 2050 to support the EU’s aim to become the first climate neutral continent.

    LEVA-EU herewith calls upon the Commission to study light, electric vehicles, to research their potential for providing affordable, accessible, healthy and clean transport and to start a dialogue with LEV-businesses and users.

    If the future Mobility Strategy aims at giving LEVs a primary role, the citizens in the European Union will enjoy, next to affordable, accessible, healthy and clean transport, a wealth of additional benefits: congestion reduction, improvement of public health, safer transport that remains available during pandemic crises, huge savings on external costs in exchange of huge external benefits, creation of green jobs whilst greening the economy. LEVA-EU calls upon the Commission to give LEVs a prominent role in the Strategy since they will play a key role in delivering the 90% less GHG emissions.

    A Strategy that aims at establishing affordable, accessible, healthy and clean transport, cannot afford to ignore and overlook means of transport, which already are affordable, accessible, healthy and clean. LEVA-EU is at the Commission’s disposal for any further details on LEVs and for assisting in liaising with the LEV community.

    Photo by Gemma Evans on Unsplash

  7. European Commission launches research into braking systems for L3e-A1

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    Motorcycles in sub-categories L3e-A2 and A3 are required to be fitted with an anti-lock braking system. Motorcycles in sub-category L3e-A1 (maximum continuous rated or net power ≤ 11 kW and power/weight ratio ≤ 0,1 kW/kg) may be equipped with either an anti-lock braking system or a combined braking system or both at the discretion of the manufacturer.

    However, the European Commission must submit a report to the European Parliament and the Council in which the mandatory fitting of an anti-lock braking system and an optional combined braking system to motorcycles in sub-category L3-A1 is to be examined. The Commission has now assigned Transport Research Laboratory (TRL) with a study, which is meant to support the Commission in the preparation of that report.

    The study is aimed at determining the relative effectiveness of anti-lock braking systems (ABS) compared to supplemental combined braking systems (CBS) in reducing the frequency and severity of collisions involving motorcycles in sub-category L3e-A1. Also, it should determine the cost-benefit relationship for the fitment of ABS and CBS, to motorcycles in L3e-A1, for society and motorcycle users. Based on the study, TRL is expected to propose possible amendments to Regulations and guidelines necessary to implement any change into law.

    Manufacturers of electric L3e-A1 motorcycles who wish to obtain further details on the TRL study and the European Commission’s report or who wish to have an input into this research are invited to contact Annick Roetynck, LEVA-EU Manager, tel. +32 9 233 60 05, email annick@leva-eu.com.

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