Tag Archive: LEV market

  1. Taiwan E-bike Sector News

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    Taiwan’s Ministry of finance reported staggering export numbers of its e-bike industry. The industry exported a volume of 452,000 e-bikes in the first 9 months of 2019, which is a growth of 131.4% compared to last year. Just as the volume, the total value has grown remarkably to $591 billion (€530 billion), resulting in a plus of 119.51%. However, the average price of a Taiwanese e-bike dropped to 1,307.59$ (€1.175), a 5,2% down compared to last year.

    Biggest importer of e-bikes from Taiwan is the Netherlands, who replaced the USA this year. When combining both conventional and e-bike  exports from Taiwan, the Netherlands is the biggest customer, followed by the USA, Germany, United Kingdom and Spain.

    Sources: Bikebiz & Bike-EU

    Photo by chuttersnap on Unsplash

  2. EU registrations of electric motorcycles, mopeds and quadricycles up by 70%

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    Source: ACEM – EU combined registrations of electric mopeds, motorcycles and quadricycles reached 35,810 units during the first six months of 2019. This represents a substantial increase of 70,0% compared to the registration levels of the first half of 2018 (21,062 units). Most of the electric L-category vehicles registered in the first six months of 2019 are mopeds (28,577 units), followed by motorcycles (5,812 units) and a much smaller number of quadricycles (about 1,421 units).

    The largest European markets in terms of volume were France, where combined registrations of mopeds, motorcycles and quadricycles totalled (8,723 units, +60,6% on a year-on-year basis), followed by Belgium (8,087 vehicles, +111,0%), the Netherlands (6,321 vehicles, +62,1%), Spain (4,052 vehicles, +35,8%) and Italy (2,426 vehicles, +86,2%).

    It should be noted that the category of electric mopeds also includes speed-pedelecs, i.e. electric bicycles with pedal assistance up to 45 km/h.

  3. LEVA-EU welcomes long awaited TRL research into factor 4.

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    The European Commission has finally decided to appoint TRL to carry out the long awaited research into the type-approval requirement of a maximum assistance factor for speed pedelecs. LEVA-EU is welcoming this research and committed to giving TRL full support. Any company or research institute with relevant information is invited to contact TRL.

    Speed pedelecs, i.e. electric bicycles with pedal assistance up to 45 km/h, must comply with the European, technical rules laid down in the Type-Approval for category L1e-B “mopeds”. These rules consist of hundreds of pages of text and are therefore extremely complicated. Furthermore, the rules have originally been written for mopeds and are therefore not accurate for speed pedelecs or for any other electric bicycles for that matter.

    Thanks to ETRA, the European trade association for bicycles dealers, which ceased to exist in 2013, some parts of the text have been adapted to better accommodate electric bicycles in the Type-Approval. However one specific paragraph was introduced in the texts, which throughout the years has continued to cause controversy. Certain parties thought this paragraph was necessary to make a clear distinction between bicycles and mopeds.

    As a result, the Commission introduced the following paragraph: “Cycles designed to pedal of vehicle category L1e-B shall have a mass in running order of ≤ 35 kg and shall be fitted with pedals enabling the vehicle to be propelled solely by the rider’s muscular leg power. The vehicle shall feature adjustable rider positioning in order to enhance the ergonomic posture of the rider for pedalling. The auxiliary propulsion power shall be added to the driver’s pedal power and shall be less than or equal to four times the actual pedal power.”

    ETRA fiercely opposed that paragraph mainly because of the maximum assistance factor requirement. ETRA argued that there was no evidence what so ever to show that this maximum assistance factor was necessary to ensure the safety of speed pedelecs. The requirement was nothing but an unnecessary design limitation that hampers the technological and market development of electric bicycles in the Type-Approval. As a compromise, the Commission introduced in the texts the promise to have the maximum assistance factor four examined, based on scientific data and statistics on vehicles placed on the market. The Commission stated that this examination could potentially result in the review of factor four. That research has now been assigned to the British Transport Research Laboratory (TRL).

    In the meantime however, the Belgian University KU Leuven also became involved in the matter of type-approval for electric bicycles. Professor Jan Cappelle and his PhD student Bram Rotthier found that the maximum assistance factor is not a legal obligation for speed pedelecs. The “cycles designed to pedal” as described above are not a separate type-approval category. Type-approval legislation does not hold any legal obligations for electric bicycles in L1e-B to comply with maximum assistance factor four. It only holds a legal obligation to test the auxiliary propulsion power on its maximum assistance. Strangely enough, this obligation to test for maximum assistance factor also applies to all vehicles in L1e-A, even though the requirement itself does not. LEVA-EU has asked the Commision repeatedly to eliminate this unneccessary test, which is a waste of companies’ money, but the Commission continues to refuse. They state that the test holds valuable information for the end-user. To date, we have not yet found the first end-user who knows what maximum assistance factor means.

    If a speed pedelec complies with maximum assistance factor four, then the requirement for vehicle structure integrity is that the vehicle must be designed and constructed to conform with all prescriptions regarding strength and construction of front forks and frames as stipulated in standard ISO 4210:2014. This combined with the limitation of the weight to 35 kg, is the only practical consequence of the designation “cycles designed to pedal”. If the speed pedelec has an assistance factor higher than four, then it does not need to be tested according to ISO 4210:2014. Incidentally, the reference to this ISO standard itself has now become inaccurate since in 2017 a completely revised EN 15194 has been published. The ISO standard refers to conventional city bikes, the revised EN 15194 has specific requirements for electric bicycle frames and forks.

    LEVA-EU has taken over the battle for accurate technical rules for electric bicycles from ETRA. LEVA-EU considers adequate technical rules the single most important condition to enable this sector to fully tap on the potential of electric bicycles and LEVs in general. LEVA-EU therefore very much welcomes the fact that the Commission’s promise of further research on factor 4 has now come to fruition. Obviously, LEVA-EU is giving TRL its full cooperation. It is however essential for TRL to hear as many testimonies as possible from companies involved in the speed pedelec business. So TRL has launched the following appeal:

    For speed pedelec companies as well as speed pedelec component companies to provide TRL with information on

    • design philosophy of speed pedelecs e.g. the choice of assistance factor, powertrain configuration and control methodology
    • current usage profiles e.g. types of journeys undertaken, rider’s age and gender, whether journeys are conducted on cycle paths or highways
    • any issues encountered while riding e.g. collisions or incidents, interactions with other road users;
    • perceptions of the effects of assistance factor on safety e.g. issues with controllability or stability encountered while riding.

    TRL also wishes to hear from anybody who has any research in the area of assistance factor and safety.

    If you have any relevant information on the above mentioned issues, please contact:
    Dr Ianto Guy – TRL Vehicle Safety and Technology Consultant
    Email [email protected] – tel. +44 [0]1344 770 084 – mobile +44 [0]7436 270343

     

  4. Registrations of electric L-category vehicles in the EU up by 49%

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    Combined registrations of electric mopeds, motorcycles and quadricycles reached 36,270 units during the first nine months of 2018. This represents a substantial increase of 52.8% compared to the registration levels of the same period of 2017 (23,722 units).

    Most of the electric L-category vehicles registered in 2018 are mopeds (26,210 units), followed by motorcycles (7,652 units) and a much smaller number of quadricycles (about 2,408 units).

     

  5. 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, [email protected], tel. +32 9 233 60 05.

  6. Motor Vehicle Insurance Directive: LEVA-EU asks EP to exclude certain LEVs

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    The European institutions are currently reviewing the Motor Vehicle Insurance Directive. This is relevant to the sector of light, electric vehicles because this Directive stipulates which vehicles are subject to a special motor vehicle insurance.

    So far, there was a clause in the Directive, which gave the member states the authority to exclude certain vehicles from the motor vehicle insurance directive. 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 scooters, self-balancing vehicles, electric hoverboards, etc. were also excluded on the basis of this clause.

    All this may now be jeopardized because the European Commission believes that a larger variety of vehicles should be included. They have proposed a text to the European Parliament (EP), to which the EP has developed a number of amendments. These amendments will be voted in the IMCO Parliamentary Committee on Tuesday 22 January.

    Two amendments are aimed at excluding all vehicles that are excluded from Regulation 168/2013 from this insurance, two other amendments are rather aimed at making these vehicles also subject to the Motor Vehicle Insurance Directive.

    In anticipation of the vote on Tuesday,  LEVA-EU has sent a statement to all members of the IMCO Committee. LEVA-EU requests them to approve the amendments aimed at excluding those vehicles that are excluded from Regulation 168/2013 as well as L1e-A category vehicles. The latter are already severely obstructed by an aberration in technical legislation and would be further hampered if they were made subject to a motor vehicle insurance. LEVA-EU also requests the MEPs to vote against the two amendments aiming at enlarging the scope of the Motor Vehicle Insurance Directive.

    LEVA-EU will continue to monitor this issue very closely and will continue to discuss this with the European authorities with a view to obtain the best outcome for the European LEV-Sector.

    For further information, please contact LEVA-EU Manger, Annick Roetynck, email [email protected], tel. +32 9 233 60 05.

  7. 60 European SMEs request Commissioner Malmström to act against unsubstantiated dumping allegations

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    No less than 60 European SMEs from 13 different EU member states have sent a motivated request to Trade Commissioner Malmström. In the letter, the importing companies explain why the Commissioner should review the Commission’s intention to impose up to 79.3% duties on import of electric bicycles from China. The 60 companies label this plan as “an extremely severe punishment for unsubstantiated dumping allegations”.

    The request of the 60 SMEs is being supported by another 27 European companies that are active in the E-bike sector but don’t import electric bicycles from China. They are European producers of components, accessories, LEVs other than e-bikes, but also distributors, dealers, service providers, … All 87 European signatories together employ 1,419 people. The letter has received further support from non-European companies active in the e-bike sector as well as from Chinese e-bike assemblers. The signatories’ list holds a total of 176 names but is confidential.

    Unsubstantiated dumping allegations

    Dumping measures must always be founded upon three pillars: dumping on the EU market, injury to the EU producers and a causal link between the two. The most important argument for this request to Commissioner Malmström is the fact that the Commission has been unable to establish injury. On the contrary, the Commission itself has established economic performance indicators, which show that the EU producers are fit and healthy[i]:

    • Sales volume: + 21%
    • Production volume: + 29%
    • Production capacity: + 35%
    • Employment: + 40%
    • Labour costs: -10%
    • Profitability: + 25%
    • Investments: + 77%
    • Return on investment: + 103%

    The only extremely weak argument for the Commission to claim injury is the fact that the industry profitability was 3.4% in the investigation period (Sept. ’16 – Sept. ’17), whilst the Commission feels it should be 4.3% as it was in 2015.

    Abuse of TDI

    The 60 importers conclude that the Commission intends to impose duties up to 79.3% in order to allow the EU industry (31 companies according to the Commission) to increase its profits by a meagre 0.9% (percentage of sales turnover) at the expense of an estimated 150 European SMEs. According to the letter writers, this calls into question the whole economic efficacy of imposing such duties, resulting in extremely high costs and a huge impact on both Union importers and consumers, whilst the benefit to the Union Industry is outright marginal.

    The group warns the Commissioner that final duties will have an immensely negative effect on the whole European e-bike sector. Therefore, they call upon her to reconsider the proposed measures, which will only be for the benefit of a handful of EU companies “who are abusing a trade defence instrument to disturb the market and upset competition”.

    Final judgment

    On 18 December, the EU member state representatives in the Trade Defence Instruments Committee will meet to give their final judgment on the Commission’s proposal. The 60 SMEs have sent the same request to their respective representatives in the TDI Committee. The decision of the Committee on final measures comes under the examination procedure. This means that the committee’s opinion is delivered by a qualified majority (55% of member states representing at least 65% of EU population). All aspects of this Committee’s meetings are confidential.

    This letter marks the final effort of the Collective of European Importers of Electric Bicycles supported by LEVA-EU to fight the Commission’s proposal for the imposition of dumping duties. The Collective will now await the Commission’s final decision, announced for January 2019, upon which they will confer on potential further actions.

    [i] PP 14-16 of the AD643 General Disclosure Document

  8. Ceci n’est pas un cas de dumping. (This is not a dumping case)

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    René Magritte’s painting, “Ceci n’est pas une pipe”, caused quite a stir at the time. Magritte stated that he would be lying if he called it a pipe because his painting was only a representation of a pipe. By analogy with Magritte, the dumping case against electric bicycles from China should not be called a dumping case, but a representation of a dumping case. However, truth needs to be more and more touched up to make it resemble a dumping case. This is again apparent from the Regulation of 18 July through which the European Commission has imposed provisional duties. A selection of the incongruities in that text, against which the Collective has officially protested once again.

    For now, the Commission concludes that electric bicycles from China are being dumped and that European industry suffers injury as a result. The extent of the injury is such that provisional duties are necessary to prevent further deterioration.

    Expressed in figures, the “damage” to European industry from 2014 to 30 September 2017 is as follows:
    – Sales volume: + 21%
    – Production volume: + 29%
    – Production capacity: + 35%
    – Capacity utilization: -4%
    – Employment: + 40%
    – Labour costs: -10%
    – Profitability: + 25%
    – Investments: + 77%
    – Return on investment: + 103%

    As for the only negative result in this list, capacity utilization, the Commission itself states that the relevance of this indicator is limited because production lines can be used for both conventional and electric bicycles (recital 172).

    Fitting the numbers to the story

    Against all logic and sense, the Commission has managed to conclude from all the above that the European industry is suffering injury. This is how the system apparently works. Whilst, according to the Regulation, the sales volume of the European industry increased by 21% between 2014 and 30 September 2017, total consumption grew by 74%. As a result, sales’ share of the European industry declined in theory from 76% to 53% in that period, and that was due to the alleged harmful, growing imports from China, according to the Commission.

    With that however, it appears that figures are sometimes inexplicably adjusted upwards or downwards to fit the story of injury. One obvious example of this is profitability mentioned in recital 192. The Commission interprets the evolution of this indicator as follows: “Starting from a low base of 2,7 % in 2014, profits margins eroded from 4,3 % in 2015 to 3,4 % in the investigation period.” (Recital 194) If an increase of profit margins by 25% is referred to as “eroding“, then one must seriously question whether any argument can be raised at all against the Commission’s determination to prove dumping.

    Mathematically impossible

    But there’s more. The Commission does not mention what profitability has been established at the verification visits of the sampled producers. These percentages are shown in the table below.

    201420152016IP
    Accell Group100194223189
    Derby Cycle Holding GmbH100148204193
    Eurosport DHS SA1007072,2222,795
    Koninklijke Gazelle NV100431236332
    Prophete GmbH & Co. KG related company to Eurosport DHS SA1006881118
    % Profit Determined in Provisional Regulation100160142125

    Source: EU Sampled Producers Questionnaires After Verification

    The above stated profitability of Accell, Derby and Konkinklijk Gazelle is set out in the graph below.

    Chart 1: Comparison of Profitability Trends Reported by the Sampled EU Producers Compared to Profitability Established in the provisional Regulation (IIP)

    Doc1

    Source: EU Sampled Producers Questionnaires After Verification and Provisional Regulation Table 11

    Index 2014 = 100

    This graph clearly shows that an increase of only 25%, as stated by the Commission, is mathematically impossible. The lack of consistency permeates the whole Regulation and reaches a culmination in recital 177 where the Commission concludes that “The Union Industry had to reduce its production, sales, employment and capacity between 2016 and the investigation period due to dumped imports from the PRC.” Once again, we question why the Commission makes a comparison between 2016 and the investigation period. In that period, production declined by a modest 1.7%, sales by 3%, production capacity by 9.2%, while employment grew by 1.8%. For the entire period however, these factors were respectively 29%, 21%, 40% and 35% higher on 30 September 2017 than on 1 January 2014.

    More inconsistent numbers

    In addition to the fact that several numbers in the complaint and the Regulation do not match, there is also an inconsistency in the production figures used. Nevertheless, both the Regulation and the EBMA complaint refer for these to the same source: EBMA’s sister organization CONEBI. In its very first position, the Collective has pointed out this inconsistency, but has never received any response to this.

    EU Industry Production201420152016IP
    CONEBI website1,030,0001,164,000
    EBMA complaint856,0001,023,0001,004,0001,025,000
    Regulation842,531987,1111,108,0871,089,541
    EBMA complaint index100120117120
    Regulation index100117132129

    Prejudiced Commission

    Another remarkable finding in the Commission’s Regulation, in the framework of the injury to the European industry is that during the investigation period four European producers have gone bankrupt. This is communicated at the end of recital 204, which provides details of the detrimental effects of Chinese dumping on European producers. In fact, in this Regulation, the Commission insinuates twice that the bankruptcies are the result of dumping. Since the Commission omits to mention who the manufacturers concerned are, it is impossible to check this statement for accuracy.

    With this, the Commission proves itself prejudiced and not for the first time. In the Registration Regulation for instance (Recital 14), the Commission argued that the importers were are or should have been aware that there was dumping at the start of the proceeding. Hence, the Commission implies in no uncertain terms that there is effective dumping at a moment when the investigation is still in full swing. This means, therefore, that the accused are found guilty before their guilt has been proven, which is in direct contradiction to the indisputable legal principle that someone is innocent until proven guilty.

    Commercial advice

    Under the heading “6.3.Interest of unrelated importers” there are some further remarkable points. The Commission extensively argues that for importers of electric bicycles from China, the alternatives for supply are plentiful. Of the 450 bicycle manufacturers in Europe, there are still only 37 who produce electric bicycles. In other words, there are hundreds of European bicycle producers left who could help out the importers, whilst the 37 existing electric bike producers can still allegedly expand their capacity. What’s more: “The import statistics show that Vietnam and Taiwan supplied substantial quantities of electric bicycles to European importers. It is also likely that other countries with a strong position in the production of ordinary bicycles could potentially supply importers.” (Recital 239) This despite the fact that the Commission could not find a single producer from any of these countries to cooperate and provide data to assist it in the dumping calculations.

    An objective analysis in a dumping case does not, in our view, require commercial advice to affected importers. A dumping procedure is an instrument to remedy a temporary abuse in international trade, not to convince importers to stop supplying themselves from the accused country! This is not the first time that importers are confronted with such commercial advice from the Commission.

    Obstinate refusal

    In doing so, the Commission once again ignores the information provided by the Collective on the relationship between the importers and their suppliers in China. These importers develop, brand and market their own bicycles, which they have produced in China, because a complete supply chain is available there and because they have built relationships with their suppliers for many years. Consequently, the Commission refuses to apply the necessary adjustments in order to calculate normal value and obstinately adheres to the OEM level of trade: ” (…) the Commission did not find any consistent and distinct difference in functions and prices of the Union industry between their OEM and non-OEM sales on the Union market at the level of product types, within the meaning of Article 2(10)(d)(i) of the basic Regulation. Article 2(10)(d)(ii) of the basic Regulation was equally inapplicable as the relevant level of trade – OEM – does exist on the domestic market of Union producers.” (Recital 115) We repeat that the sample of EU producers consists of Accell, Gazelle, Derby and oh, yes, Eurosport with its related importer Prophete, which was included without further explanation after the sample of producers was decided on and communicated.

    65 companies, 1,000 people

    The Commission puts forward further arguments for the claim that there are few reasons for importers to worry: the imposition of duties could only “have an adverse effect on a number of mainly small importers” (Recital 242). Upon publication of the Registration Regulation, LEVA-EU carried out a small Internet survey about possible injury caused by the proceeding to importing companies. 72 companies have completed the survey of which 65 (= 90%) confirm that the proceeding is causing actual damage to their business. The reported damage is significant and diverse:

    • Almost 42% is short of product to sell, in the height of the season;
    • 39% state that they already had to increase the price of their products;
    • 5% have suffered financial loss since the initiation of the dumping proceeding;
    • 33% have stopped import of electric bikes from China and have not found an alternative solution;
    • 6% state that their company will have to close down if retro-active collection is imposed;
    • 21% will not continue if definitive duties are imposed;
    • Almost 21% had to lay off staff.

    According to the Commission, the EU Industry currently consists of 37 companies. It is difficult to understand how stated damage to 65 companies, employing more than 1,000 people can be so simply dismissed by the Commission with the cursory understatement that final duties “could have an adverse effect on a number of mainly small importers”. Furthermore, the damage is occurring now, while the proceeding is ongoing and the accused have not been found guilty yet.

    Injury kept quiet

    Ceci n’est pas un cas de dumping. This is a political game which fits with the current, general European attitude to discourage trade with China. Furthermore, a very small number of large companies in Europe try, through abuse of trade defence instruments, to push competition out of those markets they have lost out on due to their own rigidity and short-sightedness.

    On the 20th July, Bike Europe reported on Accell’s outlook for the rest of 2018 as follows: “Accell Group expects continued turn-over growth in the second half of 2018, driven by higher sales or e-bikes and high-end regular bikes. Working capital at year-end 2018 is expected to be a major improvement, compared with the end of June 2018.” And CEO Ton Anbeek commented: “Based on these developments, we expect the group to record an increase in net turn-over and a higher operating result for the full year 2018, barring unforeseen circumstances.

    If there is injury to the European industry through dumping, then surely Accell must be among the most injured. How is it that Ton Anbeek, or any other Accell, Derby, Cycleurope, Decathlon, … executives, in their business analyses for the press, have never mentioned this with one word? Perhaps the press should finally ask them that question.

    In the meantime, the Collective is continuing its fight against this case. The group has requested a hearing with the Hearing Officer with a view to addressing the infringement of their right to defence in this and previous Regulations. Furthermore, the Collective is awaiting a decision on the admissibility of the lawsuit initiated against the European Commission.

    Annick Roetynck,
    LEVA-EU Manager

    (The above image represents a painting by René Magritte, which represents a pipe)

    The Dutch version of this article is available here:
    https://www.dropbox.com/s/75pagdcg7q9z1vt/PR%202018%20-%20Provisional%20duties%20NL.docx?dl=0

  9. LEVA-EU warns 4 EU Commissioners: duties will have fatal impact on European SMEs

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    In anticipation of the deadline for provisional duties, on 20th July, LEVA-EU has warned 4 European Commissioners for the fatal impact of potential duties on a large number of SME’s in Europe. The letter was addressed to Trade Commissioner Malmström, Transport Commissioner Bulc, Climate Action and Energy Commissioner Cañete and to Elżbieta Bieńkowska, European Commissioner for Internal Market, Industry, Entrepreneurship and SMEs.

    In the letter, LEVA-EU Manager, Annick Roetynck invites the Commissioners to look beyond fearmongering rhetoric and consider the facts instead. She points out that so far the Commission has found no injury to the EU-industry whatsoever. She also explains that the difference between EU manufacturers and importers is a mere € 25 to € 35 for the assembly cost of parts, which are to a large extent sourced outside Europe. So-called manufacturers incur this € 25 to € 35 in Europe, whilst so-called importers pay the cost in China. Some “manufacturers”, who were previously importing bicycles from China have even moved assembly to Europe because it is cheaper.

    Finally, she warns that duties will limit the offer, increase the prices and stifle product development and innovation. Electric bikes will become a lot less attractive and consumers will be deterred and encouraged to stay with their unsustainable means of transport.

    Annick Roetynck concludes: “Europe is facing many challenges today, among which the fight against climate change is far from over, whilst a global trade war is looming. Therefore special attention should be paid to those sectors which allow to progress towards a cleaner and stronger Europe. Imposing duties on e-bike imports from China would be an enormous setback as it would deal a fatal blow to a large number of European importers’ businesses and seriously limit the uptake of this sustainable means of transport. It is for these reasons that the Collective of European Importers of Electric Bicycles would kindly ask you to reconsider the imposition of both provisional and definitive duties.

    Here, (EU industry performance indicators), is the non-confidential version of the Commission’s report on the performance indicators for the sample of EU-“manufacturers”

    Here, (letter Commissioners), is the original version of the letter sent to the four Commissioners.

    For further details, please contact LEVA-EU Manager, Annick Roetynck, email [email protected], tel. +32 9 233 60 05

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