Tag Archive: L1e-A

  1. Is EU type-approval dangerous for speed-pedelec riders?

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    Early February, LEVA-EU, together with the project partners of 365SNEL, organized a European symposium on the legal status and market position of the speed-pedelec. In this symposium, attended by the European Commission, several manufacturers testified about the great difficulties they are having to get their vehicles approved. Furthermore, from the results of the 365SNEL research, it can be deduced that this type approval creates risks for speed-pedelec riders.

    365SNEL is a project subsidized by the Environment Department to investigate the potential of speed-pedelecs for commuting in Flanders. It is one of the (very) few projects in the context of the European Clean Power for Transport (CPT) that focusses on light vehicles rather than on electric cars or other heavy means of transport. It is no coincidence that this project is being carried out in Flanders. That is the only constant growth market for speed-pedelecs in the EU. In 2017, more than 4,500 speed-pedelecs were registered in Flanders, in 2018 that was over 8,500 and last year the 12,000 milestone was achieved. Interesting comparison: in 2019 only half as many electric cars were registered.

    45 km / h?

    In the 365SNEL project, a test fleet of approximately 15 speed-pedelecs was deployed at 10 companies and organizations, varying in size (from small company to international group) and in nature (from educational institution to hospital). The call for test drivers was consistently answered enthusiastically. No fewer than 520 candidates applied. Among them, 106 test riders were selected, who were invited to commute with the speed-pedelec for three consecutive weeks.

    That group was interviewed before and after the test rides to determine the most important motivations and obstacles and which shifts in all this the effective use of the speed-pedelecs caused. In addition, the vehicle itself was also examined. Several findings are particularly relevant for the industry and the government.

    The main motivation for testing was speed. Most of the candidate test riders were under the assumption that they would be able to ride a constant speed of 45 km/h with a speed-pedelec and that they would therefore save a lot of time. None of the test vehicles was able to meet that expectation. The speed-pedelecs with a 350W motor offered a cruise speed of 30 to 35 km/h, those with a 500W motor of 35 to 40 km/h.

    Speed-​​pedelec = moped

    The test riders quickly overcame the disappointing speed performance of their vehicle because they experienced other benefits. In particular, the predictability of travel time and the positive effect on their mental health was a huge boost for many. Only, there is something special going on in Belgium, which explains why the speed-pedelec is a success there and not in the rest of the EU.

    In the technical regulation (Regulation 168/2013), the European Union has categorized the speed-pedelec as a moped. And so, all Member States have slavishly copied that category in their traffic codes; all Member States except Belgium. Thanks to some visionary civil servants, the speed-pedelec in the Belgian traffic code is not put aside as a moped “full stop”, instead a separate category has been created: Moped Class P – Speed ​Pedelec. This made it possible to develop adapted traffic rules with new traffic signs which, by using the letter P, allow or exclude speed-pedelecs.

    Moreover, this separate categorization made it possible to subject the speed-pedelec to the same financial incentives as traditional (e)-bikes. In Belgium, you can enjoy a tax-free allowance of up to € 0.24 if you commute by bicycle, electric bicycle or speed-pedelec. The test riders of 365SNEL covered an average of 21.6 km a day. This can result in more than € 1,300 extra this year, tax-free. Sales are further boosted by advantageous leasing formulas through employers.

    Road safety was an important obstacle before testing. But that concern faded quickly. The test riders felt at ease because of the choice between road and cycle path, which the Belgian traffic code offers. The general rule is that if the speed limit on the road is 50 km/h, the speed-pedelec rider can choose between road or cycle path. If on the road the speed limit is higher than 50 km/h, they are obliged to use the cycle path.

    New means of transport

    During the symposium, Jakob Luksch, CEO of Stromer, confirmed that the adapted traffic code is a crucial element in the Belgian success of speed-pedelecs. In other countries, speed-pedelecs are banned from cycle paths and they must be used on the road. However, if those speed-pedelecs, with a 350W motor, can only handle 30 to 35 km/h on average, then that is a particularly dangerous speed difference with the cars and trucks that you have to ride with. That explains the civil disobedience of some speed-pedelec riders in the Netherlands. If they find it safer on the cycle path, they take their number plate off and put it back on when they are on the road. So far, speed-pedelecs can hardly be recognized anyhow.

    The essence of the regulatory problem is that a speed-pedelec is a new type of vehicle that cannot be squeezed into the old concepts’ corset. It is not a bicycle, it is not a moped, it is a new means of transport. And yet, governments are stubbornly trying to subject the speed-pedelec to outdated rules.

    Mortal danger

    The European technical regulations for speed-pedelecs were originally written for conventional mopeds. This type-approval is an extremely complex, inadequate and extremely expensive affair. Speed ​​pedelecs come under legislation that consists of 1,036 pages of text, which is largely about limiting emissions and about safety features that do not concern speed-pedelecs.

    During the symposium, there were extensive testimonies about the flaws of type-approval. Markus Riese, from Riese & Müller, stated in no uncertain terms that it is not wise for a company to venture into the speed-pedelec market. His company tries to persevere because they believe that speed-pedelecs can contribute to the fight against climate change. Riese & Müller are just about the only ones with a cargo speed-pedelec in their portfolio. The vehicle was part of the 365SNEL fleet and was greatly appreciated by the test riders. Markus Riese immediately pointed to the crux of the matter: “Factor 4 does not allow you to build cargo speed-pedelecs that allows to ride uphill in a safe way. Factor 4 barely allows to achieve 10 km/h and if you are then obliged, for example with 2 children in the front, to ride on the road, you risk their lives.

    Factor 4

    Factor 4 means that the motor may not deliver more than 4 times the power than the rider delivers himself. This assistance factor 4 itself is not mandatory, the speed-pedelec only needs to be tested for the assistance factor. If the power is higher than 4, this means that for instance the frame and forks of the speed-pedelec do not necessarily have to be tested according to the ISO standard for traditional bicycles. Furthermore, the speed-pedelec is no longer exempt from the electric range test. Don’t worry if you don’t understand this. The technical services accredited to approve speed-pedelecs don’t seem to know this either, they are convinced that factor 4 must be complied with and oblige their customers to do so.

    During the symposium, Ianto Guy presented the TRL study on factor 4, which was carried out at the request of the European Commission to investigate the influence of factor 4 on vehicle safety. TRL concluded that due to a lack of accident statistics, it was impossible to determine whether factor 4 had a positive or negative impact on safety. But the researcher still had some interesting footnotes to that conclusion. He confirmed what was established in 365SNEL: “Unless you are Chris Hoy, it is impossible to reach a speed of 45 km/h with a factor of 4.

    He added that torque is the most important factor in the controllability of the vehicle: “Rideability may have a bigger impact on safety than limiting power through a maximum assistance factor. Perhaps this group of vehicles sits very uncomfortably in the type-approval for L-category vehicles

    Industry testifies

    The proposition that torque is much more important than the assistance factor was repeated time and time again that day, including by Tomas Keppens who developed the Ellio through his Belgian start-up. He was one of the few participants who found type-approval a positive thing. He is currently going through type-approval with his vehicle at a technical service and had already taken numerous hurdles. The last one was the so-called steerability test. As described in the Functional Safety Regulation, the test for speed-pedelecs is physically impossible unless you position the pedals so high that the driving position becomes particularly uncomfortable.

    Robbert Rutgrink from Santos had a clear proposal to improve the legislation. He argued for a regulation that would allow “real” speed-pedelecs, without assistance factor and with more powerful motors that allow for 45 km/h. He also argued for allowing a throttle so that “the entire 45 km/h landscape could be used by speed-pedelecs.

    Finally, Arno Saladin brought the story of Rad Power Bikes. As far as we know, that is the only producer of powered cycles in L1e-A and a three-wheeled cargo speed-pedelec in L2e-U. Rad Power Bikes chose these categories because they found it impossible to create a pedal assisted vehicle that would function properly with a maximum continuous power of 250W.

    Once they had ploughed through the type-approval, they still had to cope with another major struggle: explaining to the different Member States where and how they had to fit these vehicles into their traffic code. This only worked flawlessly in Belgium, where the government decided to put  1e-A vehicles completely on a par with conventional bicycles, so no helmet, no driver’s license, no license plate, … In all other countries, Rad Power Bike was confronted with insurmountable problems, which proved really insurmountable in Great Britain, preventing them from getting their vehicles on the road there.


    Furthermore, the symposium was peppered with countless examples of major and minor obstacles in the type-approval for speed-pedelecs. For example, you must mount the brake levers exactly the  opposite way of what is common practice for bicycles. However, this is not allowed by the German traffic code. The most recent anomaly dates from January 1 this year, when the World Motorcycle Test Cycle 3 (WMTC) has become applicable. As a result, all vehicles in L1e-A and L1e-B must be submitted to an energy consumption test, which is technically impossible to perform on vehicles with pedal assistance. The original purpose of that test was to measure fuel consumption, with a view to monitoring the environmental performance of internal combustion engines. It was clearly never the intention to subject electric vehicles to this test. Unfortunately, their explicit exclusion was overlooked.

    Instead of considering the principle, the current discussion with the Commission is about how the test can be turned and twisted so that it becomes feasible for pedal assisted vehicles. This will result in yet another goalless test at the expense of the producer, or rather at the expense of the consumer. 365SNEL clearly shows that the price of speed-pedelecs is an obstacle.

    Steep prices

    The European type-approval pushes the price of a speed-pedelec in the direction of a cheap car. That car is also subject to type-approval, but the procedure is specifically designed for cars, the manufacturer is used to it and he can sell approved types in series with at least five zeros. Speed ​​pedelecs come under an inadequate and very expensive system, in which in the best case one type will be sold in a circulation of a few thousand.

    In the run-up to Regulation 168/2013, the European Commission assessed the impact of the then newly proposed rules. In that assessment, type-approval cost for speed-pedelecs was estimated at € 10,000. In reality, that cost is at least 4 times higher and with that, we are not taking into account the enormous development costs to be able to meet the type-approval.

    Since its formation, LEVA-EU, the European professional association for companies in the light, electric vehicle sector, has been striving for a structural improvement of the rules for electric bicycles in general and speed-pedelecs in particular. The symposium was an excellent opportunity to submit a proposal for fundamental changes to the regulations to the Commission and to industry.

    LEVA-EU proposes

    Currently, only electric bikes with pedal assistance up to 25 km/h and 250W are excluded from the type-approval. Vehicles that are outside the scope of the type-approval automatically come under the Machinery Directive. This Directive contains general safety instructions for a wide range of products. However, the Machinery Directive allows a sector to develop a European safety standard for their specific product within CEN/CENELEC, the European standardization body. That is exactly what happened for the “conventional” electric bikes. As soon as they were excluded from the type-approval, the technical committee that is competent within CEN for bicycles started to write a standard for electric bicycles. This EN 15194 is an instrument for the industry to comply with the safety regulations of the Machinery Directive. Manufacturers may test and certify their products according to that standard themselves; they are not obliged to work with a technical service. This system is adequate, accessible and affordable for producers. In 2018, it is estimated that more than 2.7 million electric bicycles were put on the market under this legislation in Europe. The regulatory framework does not cause any significant safety issues.

    That is why LEVA-EU proposes not only for electric vehicles, but for all zero-emission vehicles for individual transport up to a maximum speed and weight, to be determined in consultation with the industry, to be excluded from the type-approval for mopeds and motorcycles. This will allow for the abolishment of the L1e-A category, whilst the offer of vehicles will become much more varied. LEVA-EU considers it essential to delete the current power limit of 250W. It is much more important to control the acceleration instead of the power. The technological limitations (pedal assistance only) must also be removed from the law in order to make technological developments possible.

    An electric bicycle with a motor assisting up to 25 km/h which, for example, has a throttle in addition to pedal assistance, may well considerably improve safety. Among other things, it allows drivers to start quickly when the lights go green and to obtain the necessary acceleration to escape from dangerous situations.

    Technological and market development

    Zero emission vehicles for the transport of passengers or goods up to a certain speed, to be determined in consultation with the industry, must also be excluded without a power limit from the type-approval for mopeds and motorcycles. Within CEN, a working group has recently been set up to write a standard for cargo bikes. The above-mentioned exclusion will offer that working group the opportunity to develop an accurate standard for well performing vehicles. Now the 250W is a huge obstacle to the technological and market development of e-cargo bikes, although that market offers fantastic prospects.

    For zero emission vehicles up to 45 km/h with a maximum weight, to be determined in consultation with the industry, the European Commission should, according to LEVA-EU, carry out a new impact analysis to determine the best way forward. LEVA-EU believes that there are two solutions. Either, these vehicles could be excluded from the L category, which means that they automatically come under the Machinery Directive and it gives CEN the opportunity to write a standard. Or the Commission creates a totally new category, completely separate from the current L category, in which a type-approval is being developed, specifically for light zero emission vehicles up to 45 km/h with a maximum weight.

    As a result of this, Member States would no longer slavishly categorize speed-pedelecs and other light zero-emission vehicles in the L category in the moped category of their traffic code. They would be forced to reflect on an adapted position of these vehicles in their traffic code and about adequate traffic rules and terms of use.

    New study

    Efren Sanchez-Galindo, who represented the Commission, followed the discussions during the symposium with great attention. At the end of the day, he acknowledged that there is a lot of room for improvement, but he added an ominous statement. He argued that further exclusions of electric bicycles and speed-pedelecs from the L category and associated type-approval were unlikely because several Member States had approached his unit with a clear question. They want the Commission to examine whether and how light, electric vehicles such as electric scooters and self-balancing vehicles can be included in the type-approval. The request originates from Member States who have quite a few problems at home to get the new mobility phenomena regulated.

    The European Commission intends to order a study on this issue some time this year. If that study argues that, for example, e-scooters should be classed under the L category, all hell will be loose. In that case, there would be no arguments left to even keep conventional, electric bikes out of L-category. And the consequences of such a conclusion would be simply catastrophic!

    Annick Roetynck,
    LEVA-EU Manager

    This article is also available in Dutch, contact Annick Roetynck for a copy, tel. +32 9 233 60 05 , email annick@leva-eu.com

  2. Initial TRL-findings: type-approval makes electric bikes unattractive for industry & consumers

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    In the last MCWG meeting of 19 March, TRL presented a progress update on their research into the maximum assistance factor for electric bicycles in L1e-B. Their initial findings show that the current type-approval stands in the way of speed pedelecs and other e-bikes in the type-approval.

    In the Motor Cycle Working Group (MCWG), the European Commission consults with member states and with stakeholders, one of which is LEVA-EU, on the type-approval for the L-category. This working group is the discussion platform for all amendments, corrections and changes to Directive 168/2013 and its 4 Implementing Acts.

    In the last MCWG meeting, TRL presented a progress update on their investigation into the safety effects of the assistance factor for cycles designed to pedal in L1e-B. For further background information on the origins of the TRL research, please read https://leva-eu.com/2019/03/14/leva-eu-welcomes-long-awaited-trl-research-into-factor-4/

    For many years, first ETRA and now LEVA-EU have been arguing that this type-approval procedure is not suitable for electric bicycles. The procedure is originally written for mopeds and motorcycles. It is far too complicated, expensive and above all totally inaccurate for electric bicycles. It is very encouraging that the initial TRL findings appear to corroborate this position.

    A selection of the most relevant TRL findings so far:

    • No definitive evidence has been found to support the notion that the level of assistance factor provided by a pedelec affects the safety of the vehicle in either a positive or negative way.
    • From a safety perspective the most important implications of differentiating ‘cycles designed to pedal’ from the rest of the vehicles in L1e-B is that their maximum mass is limited to 35 kg.
    • The requirements applicable to L1e-A and L1e-B categories do not make them attractive to manufacturers and users.
    • The current assistance factor test method fails to address the most common accident type, which occurs at low speed

    During the meeting, TRL researcher Dr. Ianto Guy, added a few extremely relevant observations to his presentation. He stated: “We struggle to understand why in this Regulation a choice has been made to regulate power rather than torque. From a controlling point of view it is far more important to control torque than to control power.

    That was exactly the reason for ETRA, when the draft Regulation 168/2013 was discussed, to work for the abolition of the 250W limit applicable for the exclusion of electric bicycles from the type-approval. Had the argument been accepted, we would now not be stuck with the completely useless L1e-A type-approval for electric bicycles 25 km/h with more than 250W. These +250W bikes would also have been excluded from the type-approval. Therefore they would have come under the Machinery Directive and CEN TC 333 would have had the possibility to adapt EN 15194 to include +250W electric bicycles. What’s more, electric cargo bicycles would now not have been obstructed by this annoying limit and the new WG 9 in TC 333 could have developed a European standard for electric cargo bikes that helps instead of limits the market.

    TRL also found that “the regulation of assistance factor is regarded as being important in differentiating pedelecs from mopeds but not in influencing the safety of the machine”. This view appeared to have been expressed by Bosch. It is exactly a secret that Bosch is one of the main supporters of factor 4. The TRL researcher added to this finding that it was very questionable whether type-approval should be used to define the design of vehicles. LEVA-EU has consistently argued that type-approval should only pursue safety and environmental objectives and should not pursue design limitations.

    Two stakeholders in the meeting vigorously protested against the fact that in their view the TRL research was going beyond the scope set out by the Commission. Such reaction was foreseeable for ACEM, the Motorcycle Manufacturers’ Association. They dread the potential competition from electric bicycles for their traditional mopeds. As for CONEBI, who also protested against going beyond the scope, to date we fail to fathom this reaction. The current type-approval is clearly not in the interest of the electric bicycle sector. So why would an e-bike trade association protest against independent research that corroborates this conclusion and therefore paves the way for better regulation? In the meeting, the European Commission refuted the objections from both associations.

    In the meantime, the research is still on-going and TRL are appealing for further stakeholder engagement. Should you have any observations on the maximum assistance factor and/or on the effectiveness of type-approval for electric bicycles, please contact:
    Dr Ianto Guy – TRL Vehicle Safety and Technology Consultant
    Email iguy@trl.co.uk – tel. +44 [0]1344 770 084 – mobile +44 [0]7436 270343

  3. LEVA-EU asks EP to exclude L1e-A from Motor Insurance Directive (MID)

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    Following the IMCO vote, not all electric bicycles will be excluded from the Motor Vehicle Insurance Directive. LEVA-EU is working for the exclusion of at least one more category of electric bicycles, i.e. L1e-A “powered cycles”. The category is already hampered by its technical rules and will be further obstructed by a mandatory insurance.

    The current Directive gives the Member States the competence to exclude certain vehicles from the MID. In the majority of the Member States this clause was used to exclude electric bicycles with motor power up to 250W and assistance up to 25 km/h. In a number of Member States, other light, electric vehicles such as electric scooters, self-balancing vehicles, electric hoverboards, etc. are also excluded on the basis of this clause.
    All the above could have been jeopardized because the European Commission believes that a larger variety of vehicles should be included. They proposed a text to the European Parliament (EP) aimed at making these vehicles subject to a mandatory motor vehicle insurance.

    IMCO Vote

    IMCO, which is the Parliamentary Committee responsible for this Directive, did not accept the original proposal of the European Commission (EC). They decided that a mandatory motor vehicle insurance must apply to all L-category vehicles in Regulation (EU) No 168/2013. As a result, Member States retain the competence not to apply a mandatory motor vehicle insurance to:
    1) Electric bicycles with pedal assistance up to 25 km/h and maximum 250W
    2) Self-balancing vehicles and vehicles without a seating position, such as electric scooters, hoverboards, etc.
    However, all other categories of electric bicycles in Regulation 168/2013 will definitively become subject to a compulsory Motor Vehicle Insurance.  In LEVA-EU’s opinion it would be a serious mistake to include L1e-A vehicles in the MID.  This concerns electric bicycles with a motor assistance up to 25 km/h and a maximum continuous power of 1 kW, which are categorized as L1e-A “powered cycles”.

    Legal bottleneck

    The only difference between this category of electric bicycles and the category with pedal assistance up to 25 km/h that is excluded from Regulation 168/2013 is the fact that they have a higher maximum continuous power. This higher power is by no means meant to make the electric bicycles faster, the motor cuts out at 25 km/h anyway.
    The limit of 250 W, which applies to the category that is excluded from Regulation 168/2013, has been determined in 1999 in a completely arbitrary way. It was the limit of one of the very few electric bicycles on the market at that time, i.e. the Yamaha Pass.
    Since then, this arbitrary limit continues to cause a legal bottleneck for the development of electric bicycles.
    Regulation 168/2013 and the resulting type-approval procedure is an extremely expensive, complicated and inaccurate technical framework for these vehicles. As a result, there are hardly any vehicles type-approved in this category. The very few companies that do try to cope with the legal bottleneck of type-approval for L1e-A”powered cycles” will encounter another setback if member states will be forced to make L1e-A “powered cycles” subject to a motor vehicle insurance.
    Today, there are Member States, such as Belgium, which have given L1e-A vehicles the exact same status as a conventional bicycle. This includes among other things, bicycle status on the road, objective liability, financial compensation for commuting, no compulsory helmet, etc. If L1e-A is not explicitly excluded from the new MID, all this will be jeopardized and the legal bottleneck for L1e-A will become even worse. Furthermore, there are no safety arguments to include L1e-A in the Motor Vehicle Insurance Directive.

    For all the above reasons, LEVA-EU is now lobbying the European Parliament with a view to having category L1e-A excluded from the Motor Vehicle Insurance Directive.

    For further details, please contact LEVA-EU Manager, Annick Roetynck, annick@leva-eu.com, tel. +32 9 233 60 05.

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