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Electric Cargo Bikes: Technical Rules & Regulations ANNICK ROETYNCK, LEVA-EU MANAGER ECLF CONFERENCE, VIENNA, 20 MARCH 2017
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:
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
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 [email protected]. +32 9 233 60 05 – Mobile +32 475 500 588
Thank you for your attention!
mailto:[email protected]
