There is a great deal of confusion in the industry about the battery standard EN 50604. LEVA-EU witnessed this first-hand at Eurobike, where many visitors came to the LEVA-EU stand with questions. During LEVA-EU’s information meeting at Eurobike —partly dedicated to EN 50604—it became clear once again just how widespread the confusion is.

Wild claims are circulating, such as:
• All batteries must comply with EN 50604 retroactively.
• EN 50604 has been postponed.
• It is legally mandatory to comply with EN 50604.

All above statements are incorrect.

The situation shows that legislation for electric bicycles—and by extension for all light electric vehicles (LEVs)—is becoming increasingly complex and difficult for companies to navigate. LEVA-EU is one of the very few, if not the only, organisation consistently guiding and advising its members on this legislation, thanks to a unique position:

• LEVA-EU experts are directly involved in European technical committees that develop relevant standards, such as CEN TC333 (electric and cargo bicycles) and CENELEC TC21X (batteries, including EN 50604).
• This allows LEVA-EU to understand both the content of the standards and their relationship to legislation—providing members with valuable, practical expertise.

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Common Misunderstandings About EN 50604

Here is what EN 50604 is not:
• ❌ There is no legal obligation to comply with this standard.
• ❌ The standard has not been postponed.
• ❌ It is not true that all batteries must comply with EN 50604 retroactively.

Batteries that do not meet EN 50604 may still be imported, distributed, and sold.

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How EN 15194 Fits Into the Picture

• All EPACs must comply with the Machinery Directive’s Essential Safety and Health Requirements (ESHRs). These are general rules for all machinery, not specifically for e-(cargo)cycles, so the sector translated them into specific standards like EN 15194.
• EN 15194:2017 is the European standard for EPACs—electric bicycles (2 wheels only) with pedal assistance up to 25 km/h and a maximum continuous rated power of 250 W.
• When the European Commission determines that a standard covers all relevant ESHRs, it publishes a reference in the Official Journal of the EU (OJEU)—this is called harmonisation.
• Harmonisation gives presumption of conformity: if there’s a legal dispute, the manufacturer can rely on the standard as proof of compliance with the Machinery Directive, and it is up to the opposing party to prove otherwise.
• In 2019, EN 15194:2017 was harmonised under the Machinery Directive.
Using a harmonised standard is not legally required—manufacturers may use alternative solutions to prove the “state of the art”, but in that case they lose presumption of conformity and must document their compliance in detail.

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The Battery Requirements Change

In 2023, the European Commission withdrew harmonisation of EN 15194:2017 only for battery requirements, after the Dutch government raised concerns that the existing battery requirements were too weak.

• In the old EN 15194:2017, battery safety was only covered by a note, not be a requirement, suggesting testing according to EN 62133 or EN 50604-1 was sufficient. These standards were not specific to EPACs and offered limited safety guarantees.
• The CEN/TC333 EPAC working group revised the battery section, resulting in EN 15194:2017+A1:2023, which requires testing according to EN 50604-1+A1 (a stricter version).

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Transition Periods

• Normally, amendments get a 12-month transition period.
• For the battery update of the EN 15194, the sector was given 24 months—until 23 August 2025—to allow adaptation.
• During the transition, manufacturers can still use the old standard, but without presumption of conformity for battery requirements. Alternatively, they can use the new standard in which case their batteries must comply with EN 50604-1+A1

In 2024, the European Commission extended this transition from 23 August 2025 to 15 May 2026.

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What This Means for You

If you hear that “EN 50604 is postponed”, that’s incorrect. What was postponed is the full replacement of the old EN 15194:2017 by EN 15194:2017+A1:2023.

After 15 May 2026, only EN 15194:2017+A1:2023 will give presumption of conformity for EPACs and their batteries—and compliance with EN 50604-1+A1 will be mandatory within that standard. Compliance with EN 50604-1+A1 will never become mandatory to comply with the Machinery Directive/Regulation

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Harmonisation Challenges for LEVs

EN 15194 is currently the only harmonised standard for e-(cargo)cycles under the Machinery Directive.
• Standards for e-MTBs, e-cargocycles, and EN 17128 (e-scooters, self-balancing vehicles, etc.) are not harmonised.
• Harmonising LEV standards is becoming more difficult. The upcoming Machinery Regulation (replacing the Machinery Directive on 1 January 2027) may include even more requirements irrelevant to LEVs, but compliance may still be demanded for harmonisation.
• This raises doubts whether EN 15194 will be harmonised under the new Regulation.

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Other Battery Standards and Legal Requirements

• EN 17860-5 includes compliance with EN 50604-1+A1 for e-cargocycles.
• EN 50604-1+A1 itself is under systematic review, with LEVA-EU actively participating.
• The EU Battery Regulation imposes legally binding requirements on batteries in EPACs, e-cargocycles, and other LEVs—separate from battery requirements in existing standards.

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How LEVA-EU Supports You

LEVA-EU keeps track of all developments in standards and legislation to provide accurate, up-to-date guidance to companies. We actively participate in both standards development and legislation drafting, defending our members’ interests and advocating for clear, proportionate rules—especially for SMEs.

A dedicated battery working group is open to all members, where questions are discussed. If necessary, LEVA-EU takes unresolved issues directly to the European Commission.

Questions or need expert guidance?
Email: info@leva-eu.com
Call: Annick Roetynck, LEVA-EU Managing Director — +32 475 500 588