Electric Cargo Bikes:

Technical Rules & Regulations

ANNICK ROETYNCK, LEVA-EU MANAGER

ECLF CONFERENCE, VIENNA, 20 MARCH 2017

Regulation 168/2013

Regulation (EU) No 168/2013 of the European Parliament and of the

Council of 15 January 2013 on the approval and market surveillance of

two- or three-wheel vehicles and quadricycles

Applies to all 2-, 3- and 4-wheeled electric cargo bicycles except:

➢ Bicycles with pedal assistance up to 25 km/h and maximum continuous

rated power of 250 W

➢ Bicycles with a saddle height under 540 mm in L1e and 400 mm in L2e and L6e

Regulation 168/2013

Assistance up to 32 km/h =

in type-approval

350 W = in type-approval

Categorization in Regulation 168/2013

L-category Technical specifications Number of wheels

L1e-A – “powered cycles” Max. power: > 250 W – < 1 kW

Max. speed: 25 km/h

Pedal assistance + Motor only

2, 3 and 4 wheels

L1e-B – “mopeds” Max. power: < 4kW

Max. speed: 45 km/h

Pedal assistance + Motor only

2 wheels

L2e – “three-wheel moped” Max. power: < 4kW

Max. speed: 45 km/h

Pedal assistance + Motor only

Max. mass: <270 kg

Max. 2 seats

3 wheels

L6e – “light quadricycle” Max. speed: 45 km/h

Pedal assistance + Motor only

Max. mass: <450 kg

Max. 2 seats

4 wheels

Type-approval following Regulation 168/2013

Legislativebasis:

EU Regulation168/2013

=

Type-approvalfor mopeds & motorcycles

Any electric cargo cycle other than

pedal assisted cycles < 25 km/h – < 250 W:

Included in Type-approval legislation

Categorisation as L1E-A, L1E-B, L2 or

L6

Type-approvalof vehicle and

of largenumber of

components

Specific bicycle requirements

for certain components

only in L1

Type-approvalto be carried

out by technical

service accredited by MS approval

authority

At sales, vehicle to be

accompanied by Certificate of Conformity

L-category vehicle

driver’slicence, helmet,

insurance, numberplate, …

Type-approval following Regulation 168/2013

Component/Characteristic Excluded Adapted requirement

Audible warning device X

Braking X

Endurance testing X

Driver operated controls X

Lighting & light signalling devices X

Rearward visibility X

Type-approved saddle X

Type-approved tyres X

Vehicle structural integrity X

Devices unauthorised use X

Passenger handholds & footrests X

Registration plate space X

Propulsion Unit Performance X

Measurement of electric range X

Adapted requirements for L1e-A:

Adapted requirements for L1e-B:

Component/Characteristic Excluded Adapted

Braking X

Endurance testing X

Driver operated controls X

Lighting & light signalling devices X

Type-approved saddle X

Type-approved tyres X

Vehicle structural integrity X

Devices unauthorised use X

Passenger handholds & footrests X

Registration plate space X

Propulsion Unit Performance X

Electric range measurement X

Type-approval following Regulation 168/2013

Type-Approval following Regulation 168/2013

For L1e-A and for pedal assisted cycles in L1e-B, type-approval has adapted requirements.

No adapted requirements for “open throttle” bikes in L1e-B and for any bikes in L2 and L6. Therefore, type-approval probably technically not feasible for electric cargo bikes with speed exceeding 25 km/h.

Dimension limits in Regulation 168/2013:

➢ Width: 1 m for L1, 2 m for L2 & enclosed L6

➢ Length: 4 m for L1 & L2, 3 m for enclosed L6

➢ Height: 2.5 m

Potential solutions to type-approval problems

National type-approval for small series

➢ Member states may waive requirements and lay down relevant, alternative requirements

➢ Type-approval only valid on MS territory but other MS may also accept

➢ Limits: L1 & L2 : 50 vehicles per year per MS, L6 : 150

► Exemptions for new technologies or new concepts

➢ EU type-approval for a vehicle/component, which is incompatible with T.A. requirements

➢ Valid for at least 36 months

➢ Authorisation by European Commission, only valid in territory MS applicant

➢ Commission must amend T.A.

Weight limitations in type-approval

Category Max. mass in running order Max. pay-mass

L1 As declared by manufacturer As declared by manufacturer but < 250 kg

L2P < 270 kg As declared by manufacturer but < 250 kg

L2U <270 kg As declared by manufacturer but < 300 kg

L6P <425 kg As declared by manufacturer but <250 kg

L6U <425 kg As declared by manufacturer but < 300 kg

Type-Approval following Regulation 168/2013

Definitions:

➢ Mass in running order = standard vehicle + liquids + tools + spare wheels

➢ Actual mass = mass in running order + driver mass (75 kg) + optional equipment

➢ Pay-mass = technically permissible laden mass – actual mass

Type-Approval following Regulation 168/2013

Exclusion from Type-approval

Legislativebasis:

EU Regulation168/2013

=

Type-approvalfor mopeds & motorcycles

Pedal assisted cargo cycles

< 25 km/h – < 250 W:

Excluded from type-approval

legislation

Member states allowed to

categorise as bicycle

Excluded from ISO 4210

Included in revised EN 15194

= confusion

Subject to GPSD + Machinery, EMC &

Low Voltage

Self-certification

If categorized as bicycle

no driver’s licence, no helmet,

no insurance, no number plate,

bicycle traffic regulations, …

If not categorized as bicycle

? ? ?

Which terms of use?

Which traffic code rules?

1. If excluded from Regulation 168/2013, included in EN 15194 – EPACs but as delivery bicycles excluded from ISO 4210, therefore technical regulation

very unclear

2. If excluded from Regulation 168/2013 subject to:

➢ General Product Safety Directive

➢ Machinery Directive

➢ EMC Directive

➢ Low Voltage Directive

Exclusion from Regulation 168/2013

Exclusion from Regulation 168/2013

Allows member states to classify as “bicycles” but depends on member state’s

definition of “bicycles”

If not in scope of national bicycle definition, legal uncertainty

about vehicle category and therefore terms of use such as:

- helmet obligation

- insurance

- number plate

- age limit

- … and especially traffic code rules

Exclusion from Regulation 168/2013

Belgian example: cargo bicycle with pedal assistance up to 25 km/h and max. power < 250 W is in the scope of bicycle definition. Consequently:

➢ Obligatory use of/allowed on cycle paths

➢ Allowed on cycling motorways

➢ Allowed in both directions in one way streets

➢ Allowed in pedestrian zones

➢ Allowed to go right through red traffic lights

➢ No helmet, no insurance, no age limit, …

➢ Belgian example: cargo bicycle with pedal assistance up to 25 km/h and max. power < 250 W is in the scope of bicycle definition.

➢ Dimension limitations:

➢ 2 wheels: max. 0.75 m wide

➢ 3 & 4 wheels: max. 2.5 m wide

➢ Trailer: max. 1 m wide (2wheels) or same width as vehicle (3 & 4 wheels)max. 80 kg including cargo & passengers, if more separate braking system

Exclusion from Regulation 168/2013

Conclusion: remaining issues

Type-approval for electric (cargo) bikes = inaccurate, complicated,

expensive especially for SME’s

Type-approval hampers technological development electric (cargo)

bikes

Research required into need/potential advantage of power > 250 W

and/or speed > 25 km/h

Huge need for bringing technical rules and terms of use into line with

each other

Need for better, more accurate, more accessible technical regulatory

framework for electric (cargo)bikes

Annick Roetynck, LEVA-EU ManagerEmail a.roetynck@pandora.beTel. +32 9 233 60 05 – Mobile +32 475 500 588

Thank you for your attention!