Tag Archive: PMD-Framework

  1. Netherlands consults on new rules for e-bikes, e-cargo bikes & e-scooters – deadline 9 June

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    The Dutch government has opened a public consultation on a draft decree setting new rules for light electric vehicles (LEVs). Companies, associations and individuals can respond until 9 June 2026: internetconsultatie.nl


    The draft is formally a decree amending several existing orders in council (an algemene maatregel van bestuur, or AMvB). It forms part of the broader Dutch Light Electric Vehicle (LEV) framework that has been under development since the fatal 2018 Stint accident and the Dutch Safety Board’s subsequent report Veilig toelaten op de weg (“Safe admission to the road”). That report concluded that the Netherlands needed one clear approach for all LEV types, with tailored rules for each vehicle category.

    Why now

    According to the Dutch government, the number of e-bikes in the Netherlands rose from roughly 1.2 million in 2014 to about 4.6 million in 2024. Emergency-department admissions of 12-to-17-year-olds following e-bike accidents rose roughly sixfold between 2020 and 2024. The government also points to early signals from abroad — including a 62% rise in e-scooter accidents in Belgium in the first quarter of 2025 compared with a year earlier — as a warning of what could follow as more legal LEV models reach the market.

    That comparison is not exactly intellectually honest. The 62% figure refers to the number of injury accidents involving e-scooters; across the full year the increase was 33.7%, reaching a total of 2,453. For context, that same year saw 26,050 injury accidents involving cars and 11,923 involving bicycles. The figure also comes without any reference to the number of e-scooters actually on the road, which makes the comparison effectively meaningless.

    The reference to rising accident numbers among 12-to-17-year-olds is open to the same objection. What was the total number of e-bike users in that age group against which those injury figures should be set? What were the circumstances of the accidents — were the riders struck by another vehicle, a car perhaps? Or were they riding an illegal e-bike? In that last case, a helmet requirement would definitely not solve the problem.

    A second driver for the LEV-framework is the patchwork nature of the current rules. The existing regime for “special mopeds” (bijzondere bromfietsen) has grown up piecemeal over the years, so the rules don’t always fit together and differ between vehicle types for reasons that aren’t always clear. The government also flags that pedal-assisted cycles and e-scooters can currently reach the market through self-certification, where the manufacturer simply declares conformity — something the Dutch vehicle authority, the RDW, considers an insufficient safety guarantee.

    This is, to put it mildly, a curious position, given that the same vehicles reach the market through self-certification in the great majority of EU member states too — without any notable structural problems, provided they comply with existing EU legislation.

    What the draft proposes

    The proposal combines several measures rather than relying on a single instrument.

    Heavy electric cargo bikes would need to be type-approved by the RDW and carry a number plate. Owners would have to take out third-party liability insurance under the Dutch Motor Insurance Act (WAM). A transitional period would give owners of vehicles already in use time to register them and obtain a plate.

    A minimum age of 18 would apply to riders of heavy electric cargo bikes, reflecting the greater responsibility involved in carrying goods or passengers on heavier vehicles. The government expects limited disruption here, since these vehicles are mostly used commercially.

    A helmet requirement for under-18s — both riders and passengers — would apply to pedal-assist cycles and to e-scooters. The stated aim is to reduce avoidable head injuries among young people. In the Netherlands there is a tradition of so-called BSO-busjes: light electric vehicles used to carry up to eight children from school to an after-school care location until their parents collect them. The helmet requirement would apply to these children as well — which, at the very least, raises the question of how much a helmet requirement really adds for passengers.

    A notable shift on helmets

    The youth helmet element is worth flagging, because it marks a change in direction. When the LEV framework was first presented in 2021, the Dutch government explicitly chose not to impose a helmet requirement on these vehicles, arguing that public support was low, that the health benefits of cycling outweighed the accident risk, and that helmet use was a matter of personal responsibility. The new draft introduces a targeted requirement for under-18s, driven by what it describes as a sharp rise in youth head injuries — a rise that, as noted above, appears to be asserted rather than substantiated.

    What businesses are already saying

    The proposal has been through a mandatory SME impact assessment, which surfaced a real tension between road safety on one hand and the extra cost and administrative burden on the other — particularly for heavy electric cargo bikes. Operators expect higher costs from plates, insurance and especially from the national type-approval procedure. Some have warned that this could push businesses toward small vans instead of cargo bikes — an outcome at odds with wider sustainability goals. Childcare organisations also questioned how much the helmet requirement adds for passengers of child-transport cargo bikes. The government says these points were considered but did not change its choices.

    Three further mandatory assessments — a police enforceability test, an RDW implementation test, and a regulatory-burden review by the ATR advisory board — are running in parallel with the consultation, so their outcomes are not yet known.

    The European dimension

    The Netherlands continues to push this purely national initiative — even though, at a Council meeting in December last year, an earlier composition of that very same government formally asked the European Commission to do the opposite.

    Its statement read: “The Netherlands would like to bring to your attention the subject of Personal Mobility Devices. It is clear that we do not need 27 different kinds of regulations on a national level or for rather similar devices on our roads. European action is called upon. To bring about change the NL has issued a statement supported by (15) other Member States addressing the European Commission. The statement, most importantly, argues for harmonisation of a type-approval like systems for these upcoming PMDs with no compromise on safety.

    A call for one European approach rather than a patchwork of national ones — backed by no fewer than 15 other Member States. And yet, a year on, the Netherlands continue to build exactly the kind of national framework it warned against.

    At a recent open meeting, LEVA-EU presented its legal analysis of the Dutch LEV framework to members and non-members alike. The analysis concludes that the proposed framework breaches both EU and Dutch law. LEVA-EU is now bringing manufacturers, importers and other affected companies together behind a single joint protest letter against the framework. A dedicated article setting out that letter will be published in the coming days. In the meantime, anyone who would like the presentation from the meeting can request it with a short email to info@leva-eu.com.

    How to respond

    The Dutch consultation is open to everyone — companies, associations and individuals — until 9 June 2026 via internetconsultatie.nl, where the full draft decree and the accompanying policy document (the Beleidskompas) can be downloaded. Comments can be submitted on all parts of the proposed rules and the explanatory memorandum.