For clarity, in the following article pedelec means a bicycle with a motor that only functions on condition the cyclist pedals, whilst e-bike means a bicycle with a motor that functions by turning the throttle, so irrespective of the cyclist pedalling. The term electric bicycle is generic and includes pedelecs, e-bikes and combinations of these types. All electric bicycles, except pedelecs up to 25 km/h and a maximum continuous rated motor output of 250W, are subject to type-approval. The type-approval rules have been laid down in Regulation 168/2013. Electric bikes are classified in vehicle category L1e, which is subdivided in L1e-A for “powered cycles” and L1e-B for “mopeds”. The type approval rules come into force on January 1, 2017. L1e-A “powered cycles” are defined as cycles designed to pedal, equipped with an auxiliary propulsion with the primary aim to aid pedalling. The propulsion should be limited at a speed of 25 km/h and its maximum continuous rated power should not exceed 1000 W. L1e-A includes two-, three- and four-wheel vehicles, i.e. also electric cargo bikes with more than two wheels. L1e-B “mopeds” are defined as vehicles with a maximum design speed of more than 25 km/h and up to 45 km/h and a maximum continuous rated power of in between 1000 W and 4000 W. As a result of this categorisation, a pedelec 25 km/h with 750 W for instance will come under L1e-A, an e-bike 25 km/h with 500W as well, whilst a pedelec 45 km/h with 1000 W will come under L1e-B. A vehicle that combines pedal assistance with open throttle will come under L1e-A. Technically, this legislation, does not allow for e-bikes above 25 km/h. As for pedelecs 45 km/h, the regulations contain further technical specifications: “(…) mass in running order ? 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.” Furthermore, “the maximum peak power shall be < 1,6 X maximum continuous rated power, measured as mechanical power at the shaft of the motor unit.” Former trade association ETRA opposed the introduction of factor four in the above definition. The trade association argued that there was no scientific evidence to support the concept that this factor is necessary to guarantee the safety of the vehicles. Furthermore, the introduction of such a factor made it technically impossible for e-bikes to comply with type-approval. Therefore, they would be completely excluded from the market. ETRA also argued that the factor discriminates those riders who are not capable to put much power in the pedals themselves. Eventually, the Commission and ETRA reached an agreement. Factor four was left in the definition but the following preamble was added to the Regulation: “The limitation to ‘four’ of the ratio of auxiliary propulsion power and actual pedal power for cycles designed to pedal set out in Annex XIX should be subject to further scientific research and assessment. Upon availability of scientific data and statistics on vehicles placed on the market, the ratio ‘four’ referred to above may be revisited in a future revision of this Regulation.” The e-bike problem was solved by an agreement that, provided their speed is limited to 25 km/h, they may be type-approved as L1e-A vehicles. The type-approval legislation is made up of the framework Regulation 168/2013, which lays down the basis of the type-approval. The competence for this law was with the European Parliament and Council. All technical and administrative details however were in the hands of the European Commission, who laid these down in 4 Regulations: • Delegated Regulation on functional safety • Delegated Regulation on vehicle construction • Delegated Regulation on environmental and propulsion unit performance • Implementing Regulation on administrative provisions In the old system, all legal texts had to go through Parliament and Council, which made it a complicated and very time-consuming procedure. In the new procedure, Parliament and Council have only treated the basic text, whereas technical and administrative details are dealt with by the Commission. As a result, those details can be easily and quickly amended and corrected if necessary and/or adapted to technical progress. Originally, the draft legal texts were written exclusively in view of type-approving conventional mopeds and motorcycles. Yet, the scope of the type-approval also included most electric bicycles. It was the former dealer association, ETRA, that first drew the European institutions’ attention to the fact that technical requirements for mopeds and motorcycles are not necessarily best suited for electric bicycles. Eventually, the European Commission accepted to work together with the electric bicycle business to adapt the type-approval requirements to electric bicycles. At a later stage COLIBI/COLIPED also joined in the consultations and the final result was a type-approval system that is adapted to electric bicycles to a certain degree. The system is not perfect yet, so in the next couple of years, further updating and improving will be required. The list of components and characteristics subject to type-approval is in the framework Regulation 168/2013. The technical requirements and tests to which those components and characteristics have to comply are laid down in the three abovementioned delegated Regulations. Electric bicycles are excluded from type-approval for some components and characteristics, whereas for others specific requirements have been introduced. The tables in this document gives an overview of the relevant components and characteristics and the corresponding requirements. Those that do not feature in the table are excluded from electric bike type-approval. (Author/publisher)
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