Tag Archive: type approval

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

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    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

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    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. UK allows E-Scooters and E-Mopeds without Type-Approval

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    Since 4 July, the UK allows for trials with e-scooters on public roads. However, their change in national legislation is such that not only e-scooters but also light electric mopeds without type-approval are allowed. This is in breach of current EU legislation but fully in line with LEVA-EU’s proposals to the European Commission. LEVA-EU works for an exclusion of all electric vehicles up to a certain speed and weight limit from type-approval.

    Despite the fact that e-scooters were booming in Europe, the Netherlands and the UK continued to deny these vehicles access to public roads. Due to the accident with the Stint, the Dutch government ended up in a permanent cramp with regard to regulations for e-scooters and other light electric vehicles (LEVs). The ban in the UK seemed primarily inspired by fear of the risks that e-scooters would pose to pedestrians.

    U-turn

    Ultimately, it was COVID-19 that convinced the British government. During the lockdown, numerous British cities took single-handed measures to facilitate and even encourage so-called active travel. Although the lockdown is over, COVID-19 continues to cause serious problems for public transport. E-scooters are a sustainable solution for shorter trips in the city, whilst observing social distancing.

    The British government made a U-turn by allowing trials with e-scooters since July 4. These large-scale projects must allow for a final decision on the legalization of the vehicles. Tests may be launched until August 20, 2020 and will run for 12 months. Meanwhile, the British Department for Transport (DfT) has published a guide with all the technical requirements and terms of use for e-scooters. It contains some remarkable elements.

    According to DfT, e-scooters have a road presence that is largely comparable to bicycles and electric bicycles up to 25 km/h (EPACs). They have similar dimensions and visibility for other road users. Although, for the time being, the e-scooters should be categorized as motor vehicles, the trial period will be used to investigate whether they should have the same legal status as EPACs. So, for now, users must have a motor vehicle insurance and at least an AM driving license. However, that could ultimately lapse, as is already the case in Belgium, for instance.

    With or without saddle

    And then there are the technical requirements for which the UK has decided to put aside European legislation and set its own course. The e-scooters may have a motor with a maximum continuous rated power of 500W. They must not weigh more than 55 kg, battery included, and not exceed 15.5 mph (+ 25 km / h). The biggest surprise, however, is the provision that the e-scooters may have a saddle.

    In the EU, e-scooters with saddle are in the scope of the L category and must therefore be type-approved as L1e-B “moped”. As a result of the British decision, not only e-scooters with a saddle without type approval are allowed on the road, but also all other two-wheeled vehicles that need to be type-approved in the EU, insofar as their speed, power and weight are limited and they don’t have pedals. It is striking that the power limit is set at 500 W, while for the time being EPACs are limited to 250 W in both the UK and Europe.

    Legal bottlenecks

    The UK has done exactly what LEVA-EU has been advocating vis-à-vis the European Commission. All LEVs up to a certain speed and weight, regardless of their technology, must be removed from the L-category. This will automatically bring the LEVs in the scope of the Machinery Directive and further technical requirements can be developed through harmonized standards, as is already the case for EPACs. The fact that this constitutes an efficient and safe legal framework is proven by the millions of EPACs now already on European roads without exceptional risks.

    On the other hand, LEVs that fall under the L-category hardly get off the ground. In L1e-A “powered cycles”, for example, the number of homologations is virtually non-existent. And the fact that everything above 250W belongs to the L-category also weighs heavily on the development of electric cargo bikes. Still, COVID-19 has also proved that these vehicles urgently need further development, all the more since they are a godsend to help decarbonise the logistics sector.

    On the other hand, there are currently a lot of e-scooters with saddles in the EU that are not type-approved and therefore illegal (see https://bit.ly/3gHVSQU) LEVA-EU is eagerly awaiting the results of the British trials, but continues in the meantime to urge the European Commission to quickly resolve the legal bottlenecks in European legislation.

    Below are the main requirements for e-scooters as listed in the DfT guide. The full version of the guide is here.

    Vehicle design: current position (art. 3.1.)

    An e-scooter will continue to fall within the statutory definition of a motor vehicle. DfT define the sub-category of an e-scooter as being a motor vehicle that:

    • Is fitted with no motor other than an electric motor with a maximum continuous power rating of 500W and is not fitted with pedals that are capable of propelling the vehicle.
    • Is designed to carry no more than one person.
    • Has a maximum speed not exceeding 15.5 mph.
    • Has 2 wheels, 1 front and 1 rear, aligned along the direction of travel.
    • Has a mass including the battery, but excluding the rider, not exceeding 55kg.
    • Has means of directional control via the use of handlebars that are mechanically linked to the steered wheel.
    • Has means of controlling the speed via hand controls and a power control that defaults to the ‘off’ position.

    Terms of use (art. 3.2.)

    • E-scooters in trials need to be covered by a motor vehicle insurance policy. Rental operators must ensure a policy is in place that covers users of the vehicles.
    • E-scooter users need to have at least a valid AM driving license.
    • Wearing a helmet is not mandatory but recommended.

    Use on the Road (art. 3.3.)

    • E-scooters are allowed to use the same road space as cycles and EAPCs.

     

  4. Light Electric Vehicle trade association LEVA-EU urges European Commission to match green transport rhetoric with action on LEVs

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    LEVA-EU, the sole trade association for the light electric vehicle sector, says the European Commission cannot continue to ignore a key barrier to growth for the LEV market following its decision to carry out yet another study into LEVs.

    LEVA-EU wrote to the European Commissiion calling for urgent legislative change for LEVs, centring on the technical legislation for L-category vehicles – mopeds and motorcycles.  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 this L-category. So, all other electric bicycles are included in technical legislation, which was originally written for internal combustion engine mopeds and motorcycles. This leaves manufacturers forced to navigate complicated, costly and inaccurate procedures. Moreover LEVA-EU said classing LEVs in the same category as mopeds presents considerable safety issues for riders.

    In a reply to LEVA-EU, Joanna Szychowska, head of the Automotive and Mobility Industries Unit at the Commission’s DG Grow, said the EC would shortly launch a study on the safety of personal mobility devices that would also look at the relevance of requirements for certain vehicle categories of the legislation in question, Regulation (EU) No 168/2013.

    But LEVA-EU manager Annick Roetynck said the organisation found the response ‘deeply frustrating’ saying it was ‘more procrastination’ and ‘more costly delays’ for the highly innovative LEV sector which is desperate to break free from the ill-fitting regulation.

    In the letter, Ms Szychowska said the EC was working to provide effective measures to facilitate the ramping up of production after the end of the COVID-19 confinement phase, while at the same time looking for ways to promote cleaner ways of transport.( see notes to editors)

    Earlier in June, the EC’s executive vice-president, Frans Timmermans, spoke at a major press conference on green transport and addressed the EU’s pledge of 20 billion euros for sustainable infrastructure transport projects, including electric mobility and bike lane schemes, saying: “When it comes to public investment to relaunch the transport sector more sustainable mobility will be key… funds can support the financing of one million electric vehicle charging points, clean fleet renewals, sustainable transport infrastructure especially looking at modalities of rail and electric mobility and bike lanes in cities.

    But Ms Roetynck said rhetoric is not being matched with action. “The current 250W limit handcuffs the e-cargo-bike-industry so that it cannot meet the current demand from consumers,” she said. “The inaccurate type approval is creating a huge legal bottleneck for ebikes, nipping development in the bud before it has had time to flourish. By not changing LEV legislation, the EU Commission is doing harm to its own climate ambitions and we need change now. Moreover, as a result of these rules, riders are often forced to ride in dangerous conditions because the speed difference between them and other means of transport is often life-threatening.

    Ms Roetynck said LEVA-EU had written to Mr Timmermans and the three EU Commission presidents. The group had already received a response from the cabinet of President Charles Michel stating: “On 23 April, President Charles Michel together with the President of the European Commission, Ursula von der Leyen presented to the Heads of State and Government the Roadmap for recovery. It was agreed that the green transition will play a central and priority role in relaunching and modernising the EU economy. Further action to decarbonise the transport sector, which should also improve air quality, is necessary to succeed in the green transition. The Council of the European Union will thoroughly examine any proposal in this regard brought forward by the European Commission.

    But Ms Roetynck said the response was ‘warm words’ but left the problem of reforming Regulation 168/2013 still firmly at the door of the European Commission.

    Ms Roetynck  also pointed to a recent study in Belgium called project 365SNEL  which examined the benefits of commuting by speed pedelec. The study found that workers highlighted punctuality and improved mental health as their main motivations for choosing a light electric vehicle over a car.  The research followed 106 employees from ten companies commuting on a speed pedelec for three weeks and involved people who had never ridden a speed pedelec before, and who lived between 15km and 35km from their workplace.

    The predictability of journey time was an important factor for many, as traffic considerations did not need to be made. Many enjoyed the exercise element, which meant they arrived at work with a clear head, said the study. The main hurdle for many consumers was the price.

    This study again shows the key role speed pedelecs can make to the future of commuting,” she said. “But it is critical we encourage the growth of the sector and remove barriers quickly as solutions to the future of green transport are needed urgently now as cities across Europe and the world are scrambling to find safe and sustainable forms of transport and commuting. It is worrying that the study found consumers are being put off by price as price is a direct result of extremely complicated, inaccurate European technical rules.

    LEVA-EU acts on behalf of around 50 members across Europe and estimates about three million E-bikes alone were sold in the European Union during 2019. About 98 per cent of these were E-bikes with pedal assistance up to 25 km/h and 250W, which shows the extent the technical legislation for L-category obstructs the development of new types of E-bikes.

     

  5. LEVA-EU says ‘blanket’ EU regulation ‘choking’ light electric vehicle sector

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    The European trade association LEVA-EU is calling for an urgent change in EU regulations, it says are seriously hindering manufacturers at a time when cities are encouraging use of light, electric vehicles (LEV) as an alternative form of transport during the coronavirus crisis.

    LEVA-EU, the only trade association in Europe that works exclusively to represent light electric vehicle businesses, has presented proposals to the European Commission to revise rules it believes are inaccurate and can put users in danger.  It says the Covid-19 crisis has brought its proposals into sharp focus and is urging the EC to schedule changing the ruling as a matter of urgency.

    The advocacy group, whose work concerns a wide range of one, two, three and four wheel LEVs including E-bikes, speed pedelecs (E-bikes that can achieve speeds of up to 45km/h), E-cargo bikes  and E-scooters, says the central issue is that the Regulation class light electric vehicles (LEVs) in the same category as mopeds and motorbikes and as a result isvery seriously hampering the industry at ‘absolutely the wrong time’.

    Annick Roetynck, LEVA-EU manager, said the EC only has to look at all the cities across Europe opening up cycle lanes as the public scrambles to find safe alternative forms of transport. She called for ‘root and branch’ change to further unleash innovation and enterprise in the LEV sector much of which is made of up dynamic small to medium size firms.

    Our concern centres on Regulation 168/2013 which establishes the technical legislation for L-category vehicles, in other words mopeds and motorcycles. 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 this L-category. So, all other electric bicycles 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 electric bicycles. Manufacturers have to 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 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.

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

    Annick Roetynck says that classing LEVs in the same category as mopeds also presents considerable safety issues for riders. Most light electric vehicles in the L-category are able to achieve a maximum cruising speed of 30-35kmh, yet classing them as mopeds forces them off cycle lanes and onto roads among traffic achieving speeds of at least 50kmh. That difference in speed results in very dangerous and unpleasant riding conditions.

    In its proposals to the EC, LEVA-EU cites the Belgian project 365SNEL, carried out in the past 18 months where 106 people tested a speed pedelec for commuting for three weeks. After the test, 20 per cent of participants effectively swapped their car for a speed pedelec LEV.

    The research showed that price was putting off some consumers from investing in a speed pedelec, but LEVA-EU says inflated prices are the result of the complicated regulations facing manufacturers.

    Annick Roetynck said the organisation is campaigning to protect the industry as more people move to LEVs in the future. LEVA-EU acts on behalf of around 50 members across Europe and estimates about three million E-bikes alone were sold in the European Union during 2019. About 98 per cent of these were E-bikes with pedal assistance up to 25 km/h and 250W, which shows the extent the technical legislation for L-category obstructs the development of new types of E-bikes.

    She said: “It has become very clear to LEVA-EU that the European technical rules for LEVs are hampering their market development. 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. As a result of these rules, riders are often forced to ride in dangerous conditions because the speed difference between them and other means of transport is often life-threatening.

    In an open letter to the Presidents of the European Commission, Parliament and Council, LEVA-EU also calls for an amendment to the EU Green Deal. Even though the European Environment Agency has argued that shifting to walking, cycling and public transport is crucial for Europe to meet long-term sustainability goals and policy objective under the EU Green Deal, the Commission’s Communication has no reference to such a shift. LEVA-EU therefore calls upon the Commission to include the shift to walking, cycling, public transport and using light, electric vehicles (LEVs) as a key element in the Green Deal and consequently put that shift at the centre of the forthcoming strategy for sustainable and smart mobility.

    In the letter, LEVA-U has rephrased 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.

    The LEV market represents an exciting future for cities and towns across Europe, but this potential will be lost if we do not make urgent alterations to current legislation. We will continue to act as a voice for our members to ensure we remove any barriers to trade and get more people to do their bit for the environment by choosing an LEV.

    LEVA-EU Member Rad Power Bikes testifies:

    LEVA – EU member Arno Saladin, European business manager of Rad Power Bikes in the Netherlands, says the combination of technical legislation and traffic codes is stifling an industry that has great potential. The business has focused on manufacturing e-bikes with a speed of up to 25kmh and maximum power above 250W (L1e-A), but he says that while a business has the time to navigate legislation in different countries, it is often confusing for the consumer.

    He said: “We haven’t expanded our line-up because our customers are facing so much uncertainty when they purchase a product in some countries, so we decided it would be much easier and clearer to produce 250W e-bikes.

    Light electric vehicles are a very new sector of the market but we find that the legislation is not created at a basic level for the consumer to use the products with confidence. That’s why we see a lot of manufacturers not introducing new models even though there is a clear demand for these types of vehicles. It’s a chicken and egg situation where, if the regulations and traffic codes were clearer then more businesses would be interested and the sector would grow. However, the decision makers say that it’s too small a sector to give it attention, but I believe that as soon as the legislators understand what they need to do, this market will rocket.

  6. 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.

    Anomalies

    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

  7. LEVA-EU Briefing on Technical Rules for Batteries

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    LEVA-EU has a new briefing available  on the EU technical rules applying to batteries for light, electric vehicles, i.e. electric bicycles, electric scooters, self-balancing vehicles, electric monowheels, hoverboards, etc.

    In the briefing, we explain how battery rules depend on the legal framework that is applicable to the complete vehicle. The regulations for vehicles under type-approval are completely different from the regulations for vehicles under the Machine Directive.

    We provide a detailed overview of the requirements resulting from these two frameworks. We focus not only on electric bicycles up to 25 km/h and 250W, but also on electric bicycles in L1e-A and L1e-B (speed pedelecs), on electric mountain bikes, electric cargo bikes, electric scooters, self-balancing vehicles, etc.

    Further details on how to obtain this new briefing are here: http://leva-eu.com/rules-regulations-leva-eu-briefings-available/

  8. E-Scooters with Saddle = L1e-B Moped

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    We notice a growing number of e-scooters on the market with a saddle. In the majority of cases, these vehicles are being marketed as e-scooters, which would have the same legal status as their counterparts without saddles. This is undeniably incorrect and wrong. Companies that sell e-scooters in this manner are selling illegal products.

    Should their customers have an accident with such a vehicle, the company will without any doubt be held liable. However, it doesn’t even have to come to an accident. If the economic inspection knocks on the door, they will more than certainly confiscate the vehicles and take the company to court for their illegal trade practices. Moreover, through the RAPEX system all member states will be informed that the company is selling illegal vehicles, which have been impounded.

    E-scooters with a saddle are NOT excluded from Regulation 168/2013 and must therefore be type-approved as an L1e-B moped. As a result, in the national traffic codes, the vehicle will have the status of a moped. Some member states have in their traffic code a separate category for 25 km/h mopeds, for instance in Belgium, Germany and the Netherlands. In these countries, the vehicles will come under that category provided that their maximum speed is 25 km/h. This means that all the moped rules with reference to helmet use, position on the road, driver’s licence, insurance and minimum age must be complied with.

    Some countries have in their traffic code a special category for e-scooters without a saddle but also for self-balancing vehicles, electric hoverboards, electric monowheels, etc. In Belgium for instance, this category is called “propulsion vehicles” (voortbewegingstoestel – engins de déplacement). Their maximum speed should be 25 km/h and they have to follow the same terms of use as conventional bicycles. As a result, there is for instance no helmet obligation, no motor vehicle insurance, no driver’s licence, … The minute that same e-scooter is equipped with a seating position, it is a completely different ball game, since the vehicle comes under the traffic code category “mopeds” with its respective terms of use.

    With that it also appears, that a large number of companies who produce, export, import and market e-scooters (without a saddle) in the EU are not well informed about the technical regulations that apply to these vehicles. They, as well as self-balancing vehicles, monowheels, hoverboards, etc. come under the Machinery, RoHS and EMC Directives and this brings about a whole range of technical requirements and administrative obligations.

    LEVA-EU has all knowledge and expertise to provide companies who need further information on these rules and regulations with all necessary details. Furthermore, LEVA-EU is in the process of making an overview of national terms of use in the member states.

    Contact LEVA-EU Manager, Annick Roetynck, tel. +32 9 233 60 05, email annick@leva-eu.com

  9. End-of-Series L1e to End

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    Since the 1st January 2018, the homologation of unsold L1e vehicles (mopeds and  speed pedelecs) type-approved according to Directive 2002/24 has become invalid. As a result, these vehicles could no longer be sold, unless they had been registered for end-of-series in the member state where they were meant to be sold. This procedure be applied for a maximum of 100 vehicles or 10% of the number of vehicles the company had sold in 2016 and 2017 in that member state. Companies were entitled to make use of the highest number, whichever that was.

    The end-of-series vehicles had to be registered with the competent authority of the member state. Upon registration, companies were entitled to sell the 2002/24 type-approved vehicles until 31st December 2019.

    So, on the last day of this year the end-of-series measures expire and as of 1 January 2020 vehicles type-approved according to Directive 2002/24 may no longer be sold.

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