Tag Archive: Regulation 168/2013

1. LEVA-EU info-meetings on revision type approval

   05/10/2020 18:24 Comments Off on LEVA-EU info-meetings on revision type approval

   LEVA-EU has argued long and hard for a revision of Directive 168/2013, which regulates type-approval for vehicles with two or more wheels. The European Commission has now finally initiated such a review. It is particularly important that as many LEV companies as possible participate in this review. To help them in this, LEVA-EU organizes info-meetings.

   From its start, LEVA-EU has argued long and hard for a review of Directive 168/2013. The professional organisation has extensively argued how the market potential of light electric vehicles (LEVs) covered by that type approval is being thwarted.

   To date, electric bicycles with pedal assistance up to 250W and 25 km / h, vehicles without a saddle, self-balancing vehicles and vehicles with a seat below a certain minimum height are excluded from Regulation 168/2013. In addition, electric bicycles 250W – 25 km / h have been given the status of a conventional bicycle in the traffic code of all member states. As a result, this category has been growing and thriving for years.

   LEVs that have remained in the Regulation, on the other hand, have a particularly difficult time. Speed ​​pedelecs, for example, have great difficulties to really develop because in most cases they are categorized as classic mopeds. However, the terms of use for mopeds are unsuitable for speed pedelecs. And so, massive uptake of speed pedelecs is not forthcoming. In L1e-A, powered cycles, the situation is even worse. In this category for electric bicycles 25 km / h with more than 250W, virtually no type approvals have been carried out since 2013.

   After all this time, LEVA-EU’s complaints have finally been heard. The European Commission has asked TRL, a research centre specialized in mobility, to investigate the position of LEVs in the type approval and their position in national traffic codes. All LEVs are scrutinized, i.e. electric scooters, self-balancing vehicles, electric bicycles in and outside the type approval, electric cargo bicycles, etc.

   TRL has started a broad survey of the sector through an online questionnaire that can be completed until October 30th. However, the current legal framework is extremely complex and confusing. It is important that LEV companies have a good understanding of that framework, in order to provide an informed and relevant response to the survey.

   LEVA-EU wants to help companies with this by means of a number of information meetings. These meetings are intended to provide a clear picture of the current legal framework. In addition, LEVA-EU will explain the opportunities and risks of the ongoing review.

   The online information meetings will start on October 13 with a first session reserved for LEVA-EU members. Then follow open meetings according to vehicle type:

   – Electric bicycles and speed pedelecs
   – Electric cargo bikes
   – PLEVs such as electric scooters and self-balancing vehicles
   – Three and four-wheel electric vehicles with pedaling function for passenger transport

   Each meeting will last 1 hour with information provided in the first half hour and questions answered in the second half hour. To participate in the meeting, interested parties should send an email to daan@leva-eu.com stating which meeting (s) they wish to attend. They will receive a personal invitation to the meeting.

   LEVA-EU Information Meetings Revision LEV Type Approval

   – Tuesday October 13, 10.30 GMT + 2: only for LEVA-EU members
   – Tuesday October 13, 14:00 GMT + 2: electric bikes and speed pedelecs
   – Wednesday October 14, 10.30 GMT + 2: PLeVS (e-scooters, self-balancing vehicles, …)
   – Wednesday October 14, 14:00 GMT + 2: electric cargo bikes
   – Thursday October 15, 10.30 GMT + 2: 3 & 4-wheel electric vehicles with pedalling function for passenger transport

   Photo by André Ravazzi on Unsplash

2. Commission Asks TRL to Revise Technical + Road Use Rules for ALL LEVs

   27/08/2020 17:09 Comments Off on Commission Asks TRL to Revise Technical + Road Use Rules for ALL LEVs

   On behalf of the European Commission, TRL has started an investigation into the appropriateness and accuracy of European rules governing light, electric vehicles. The Commission had announced this research at the LEVA-EU symposium in February but then seemed to indicate that the scope would be limited to “Personal Mobility Devices”, i.e. e-scooters, self-balancing vehicles, monowheels, etc. The scope now appears to include all LEVs, which creates a unique opportunity to prove the need for fundamental change.

   Last February, LEVA-EU organised a symposium on the legal status and market position of the speed pedelec. This symposium, attended by the European Commission, clearly showed how European technical rules result in great difficulties for manufacturers and that the categorisation as L-vehicle create great safety risks for speed pedelec riders.

   Speed pedelecs are not the only LEVs suffering from inadequate and outdated rules. As electric cargo-bikes take up an ever increasing role in city logistics, the 250W limit to keep them out of the L-category becomes an ever increasing obstacle. There are legal bottlenecks for LEVs excluded from the L-category just as well. Some Member States, such as the Netherlands and the UK, still forbid e-scooters on public roads. Other Member States develop their own technical rules, thus undermining the principle of European harmonisation and the single market. The national terms of use for electric tricycles and quadricycles, excluded from the L-category are totally unclear and uncertain.

   E-scooters with saddles or very light mopeds, which are technically very similar if not identical to e-scooters without saddles are not excluded from the L-category. They are therefore subject to an extremely complicated, expensive though inaccurate type-approval, upon which they are subject to the terms of use for conventional mopeds including the wear of a motorcycle helmet.

   The only LEV to enjoy a much better regulatory framework is the electric bicycle with pedal assistance up to 25 km/h and 250W. This vehicle has been excluded from the L-category, as a result of which it became subject to the Machinery Directive. This has allowed for the harmonised standard EN 15194, whilst all member states have given this e-bike the same legal status as conventional bicycles. As a result, this market has been growing very steadily for several decades now.

   But to make mobility more sustainable and green, the EU needs a wider variety of LEVs. Markets, other than e-bikes 25 km/h-250W, such as speed pedelecs have only enjoyed a limited growth even though there is a clear potential. Or, the vehicles are under threat of very sudden and arbitrary changes in national rules that could suddenly destroy the market. The response of the Dutch government to the Stint accident is the best example of such threat. The insane penalties decreed by France for LEVs exceeding their speed limitation by construction is yet another sword of Damocles for the sector.

   LEVA-EU has been pleading and working for a fundamental change of the rules ever since its foundation. Without such change, the EU will never be able to achieve its Green Deal’s objectives, which include a 90% GHG emission reduction by 2050.

   At the February symposium, the EC representative announced the Commission’s intention to order a study on how LEVs, such as e-scooters and self-balancing vehicles (PMDs) could be included in the type-approval. This study has very recently been initiated by TRL and its scope appears to be broader than what the Commission announced in February.

   TRL is calling on all LEV stakeholders for their input. TRL is interested “to hear about the effects of national and regional regulations on the safety of, and market for, PMDs. We are also interested to hear any ideas that stakeholders might have for the best ways in which new and existing PMDs could be regulated in order to safely and efficiently integrate them into road use. We understand that the scope of this project includes vehicles that might already be type approved in the L category, e.g. cycles designed to pedal and cargo bikes and we are therefore open to suggestions regarding any improvements that could be made to that system.”

   LEVA-EU is extremely pleased with this widened scope that allows for research into the accuracy of the rules, not only for PMDs such as e-scooters and self-balancing vehicles but also speed pedelecs, electric cargo-bikes, electric bikes with more than 250W (L1e-A), etc. Further good news is the fact that TRL is not only going to consider technical regulations but also road circulation measures to ensure the safe deployment of these machines in the EU and the effect of regulation on the PMD market in the EU. Current problems are to a large part resulting from the fact that Regulation 168/2013 was designed without any consideration as to the effect of the technical categorisation on the terms of use for the vehicles.

   LEVA-EU herewith calls upon ALL stakeholders concerned to state their views on current LEV-regulations as well as their proposals for improving the rules. TRL is currently collecting input and plans a webinar some time in September.

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

3. LEVA-EU sends open letter to EU Commission, Council & EP Presidents

   14/05/2020 16:09 Leave a Comment

   Gent, 12 May 2020

   Open Letter to:
   – the President of the European Commission, Mrs von der Leyen
   – the President of the European Council, Mr Michel
   – the President of the European Parliament, Mr Sassoli

   Dear Mrs von der Leyen, Mr Michel and Mr Sassoli,

   LEVA-EU is the European trade association for businesses in the light electric vehicle (LEV)-sector. The term  LEV covers all electric vehicles in and excluded from the L-category, i.e. e-scooters, e-bikes, speed pedelecs, electric mopeds and motorcycles, etc..

   LEVA-EU herewith officially requests the Presidents of the European Commission, Council and Parliament to eliminate legal bottlenecks and to put LEVs at the heart of Green Deal, with a view to encouraging sustainable mobility as we are coming out of the Corona crisis.

   Almost 300,000 lives have been lost to COVID-19. We all agree that each one of those deaths is one too many. And yet, every year, we allow for 4.2 million people to die from air pollution. There appears to be a worldwide consensus that this is a price worth paying to preserve our economies and living standards. It took COVID-19 to show how life can be without that pollution: not only cleaner and healthier (in a way) but also quieter, more safe, greener, brighter, … The share of transport in that turnaround can hardly be underestimated.

   At all levels, policymakers are now faced with the choice between going back to “business as usual” or a fundamental change. It is once again the cities that are the pioneers in encouraging their citizens and businesses to make that fundamental change. A growing peloton of European cities decides to safeguard and sometimes even further expand the freed up space to allow pedestrians, cyclists and users of light, electric vehicles (LEVs) such as e-bikes, electric cargo bikes, e-scooters, etc. to keep a safe distance.

   When we now read the Green Deal, published before the Corona-crisis, the chapter on transport sounds very much overtaken by reality. Why should we wait until 2030 to cut greenhouse gas emissions by at least 50% and until 2050 to achieve climate neutrality? In October 2019, the European Environment Agency (EEA) stated: “Cutting air pollution in Europe would prevent early deaths, improve productivity and curb climate change.” How can a decision to wait until 2050, thus killing millions more, be justified, especially since the Corona crisis has shown that we are able to cut air pollution.

   That is why LEVA-EU calls upon the European Commission, Parliament and Council to support the European cities and their citizens by taking two simple, concrete measures.

   First, before the Corona crisis, the EEA already stated: “Shifting to walking, cycling and public transport is crucial for Europe to meet long-term sustainability goals and policy objectives under the EU Green Deal.” The Corona crisis has shown that the willingness to travel in a sustainable way is far beyond political expectations. In the European Green Deal, the Commission expresses “its intention to tackle all transport emission sources and explains that achieving sustainable transport means providing users with more affordable, accessible, healthier and cleaner alternatives to their current mobility habits.”

   Despite this statement, the Commission has not put forward shifting to walking, cycling, LEVs and public transport as a key element of the Green Deal. LEVA-EU calls upon the Commission and all European institutions to stop ignoring the invaluable EEA advice. We urge the Commission to include that shift as a key element in both the Green Deal Communication and in the announced strategy for sustainable and smart mobility.

   Second, the Commission has announced adaptations of existing legislation, i.e. the AFID and the TEN-T Regulation. We urge the Commission to add the revision of Regulation 168/2013 to this programme. A fast and fundamental revision of this Regulation on the type-approval for L-category vehicles is crucial to remove the many legal bottlenecks, which are currently severely obstructing the deployment of LEVs.

   Last February, at a symposium organized by LEVA-EU and the Belgian project 365SNEL, LEV-manufacturers presented the Commission with a large variety of legal and regulatory problems preventing them from fully exploiting the potential of LEVs. The 365SNEL project, funded by the Flemish Environmental Department, showed that after extensive test riding, 20% of the participants swapped their car for a speed pedelec for commuting.

   At the request of the Commission, the European Council and Parliament decided in 2013 to only exclude electric bicycles with pedal assistance up to 25 km/h and 250 W from the L-category. So, most other light electric vehicles are included in technical legislation, which has originally been written for internal combustion engine mopeds and motorcycles.

   The legislation has 1,036 pages of text, to a large extent dedicated to emissions, noise and other technical aspects which are totally irrelevant for light electric vehicles. Manufacturers must figure out which of these 1,036 pages are applicable to, for instance, their speed pedelecs or their E-cargo bikes with more than 250W. And if they manage that all, they then have to go through a totally inaccurate type-approval procedure, which costs at least four times more than what the Commission predicted in their impact assessment before drafting Regulation 168/2013.

   The 365SNEL research has shown that the biggest obstacle to getting more people to consider LEVs is still high prices, yet this price is a direct result of extremely complicated, inaccurate European technical rules.

   Regulation 168/2013 is a significant barrier to European SMEs and choking growth at a key time when the popularity and profile of LEVs as a sustainable form of transport, especially in these COVID-19 times, is set to soar. Europe must not hold back innovation and growth in this sector.

   Categorizing LEVs as mopeds also presents considerable safety issues for riders. Most speed pedelecs for instance are unable to achieve their maximum speed limit of 45 km/h, but rather achieve a maximum cruising speed of 30-35 km/h. Yet, classing them as mopeds forces them off cycle lanes and onto roads among traffic achieving speeds of at least 50km/h. As a result, riders are forced to ride in dangerous conditions, because the speed difference between them and other means of transport is often life-threatening. This is yet another reason for a fundamental review of Regulation 168/2013.

   Last year, an estimated three million e-bikes were sold in the European Union. About 98 per cent of these were e-bikes with pedal assistance up to 25 km/h and 250W, which shows the extent to which the technical legislation for L-category obstructs the development of new types of E-bikes and other LEVs.

   The LEV market holds an exciting future for cities and towns across Europe, but this potential will be lost if we do not make urgent and fundamental alterations to current legislation. LEVA-EU has presented the Commission with a well-founded proposal for legislative change. We would be very pleased to further explain and discuss this proposal.

   Finally, LEVA-EU wishes to rephrase the EEA statement: “Shifting to walking, cycling, light, electric vehicles and public transport is a duty for Europe to meet long-term sustainability goals and policy objectives under the EU Green Deal, in honour of all COVID-19 and air pollution victims.”

   Yours Sincerely,

   Annick Roetynck,
   LEVA-EU Manager

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