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EU Regulations for e-Bikes
2011-5-29  
The battery and the motor in an e-Bike result in a number of risks that do not exist in a conventional bicycle. In five chapters you can find information on the set of European rules and regulations that apply in all 27 member states regarding e-Bikes.

Companies active in producing, distributing and selling electric bicycles or components of electric bicycles need to be aware of these rules and regulations and should observe them.

The legal status of electric bicycles is slightly complicated. The word ‘electric bicycle’ covers two different concepts of vehicles with an auxiliary electric motor:

  • cycles equipped with an auxiliary motor that cannot be exclusively propelled by that motor. Only when the cyclist pedals, does the motor assist. These vehicles are generally called ‘pedelecs’ and they are today the most popular in the EU;
  • cycles equipped with an auxiliary electric motor that can be exclusively propelled by that motor. The cyclist is not necessarily required to pedal. These vehicles are generally called ‘E-bikes’.

Pedelecs with a maximum continuous rated power of 0.25 kW and assistance of the motor up to 25 km/h are classified as bicycles. They fall under the European standard EN 15194 and must comply with the Machinery and EMC Directive. Most EU member states allow for self-certification. This means that the manufacturer himself can ensure that the pedelec complies with EN 15194 and the Directives mentioned or he can ask a test lab of his choice to do the necessary tests.

EN 15194 only concerns the electric part of the vehicle, whereas for the bicycle part EN 14764 applies. As a result of these standards pedelecs have to be accompanied by a whole list of instructions for the user of the vehicle. This list is in the text of EN 15194. Furthermore, the pedelec has to be marked with a serial number, with the name of the manufacturer or his representative, with EN 14764 and with the words “EPAC according to EN 15194”.

Pedelecs with a maximum continuous rated power of more than 0.25 kW and/or assistance above 25 km/h and E-bikes that can be exclusively propelled by the motor are classified as mopeds. They fall under the European type-approval legislation for two- or three-wheel motor vehicles, governed by Directive 2002/24/EC. Compliance must be certified by an accredited test lab, but type-approval in 1 European member state is valid in all member states.

The difference between classification as bicycle or as moped is very important. Whereas bicycles can be ridden without any further obligations, there are many constraints to the use of a moped. There is mandatory wear of a helmet, insurance, a number plate, a driver’s license and an age limit. For a lot of people, these are too many obligations. This explains why pedelecs with a motor output of 0.25 kW and assistance up to 25 km/h are the most popular type in Europe.

Review type-approval legislation

The European Commission is currently reviewing the type-approval legislation in Directive 2002/24/EC. In close consultation with a large number of manufacturers, The European Two-Wheeler Retailers Association (ETRA) has developed a proposal for the European Commission, aimed at improving the rules for electric bicycles in this Directive. The proposal holds two important elements.

For pedelecs classified as bicycles, ETRA suggests to increase the motor output limit from 0.25 kW to 0.50 kW. The current limit of 0.25 kW proves to be insufficient for instance for pedelecs used in hilly areas, for obese people, for three-wheelers, cargo bikes, etc.

If people in these cases need a more powerful pedelec, it is today classified as a moped, so it has to be type-approved and the driver must wear a helmet, have an insurance, etc. If these pedelecs are classified as bicycles, people will be able to use the vehicle without all these obligations and that will open up the market.

Secondly, the type-approval procedure has originally been developed for traditional mopeds, long before pedelecs and E-bikes were on the market. As a result, the technical procedure is not well adapted to pedelecs and E-bikes. Therefore, ETRA proposes to the European Commission a type-approval procedure that is more suitable for electric bicycles. The European Commission is expected to present a proposal for the review in the second half of 2010.


Early 2010, the European Commission has officially confirmed that pedelecs with a maximum continuous rated power of 0.25 kW and assistance up to 25 km/h must comply with Directive 2006/42/EC on Machinery. This Directive contains a list of essential health and safety requirements for the design and construction of machinery, including pedelecs. Manufacturers may only sell pedelecs in the EU if they comply with these requirements.

Most of the requirements are covered by EN 15194. However, CEN TC333 needs to review EN 15194 to ensure that all obligations imposed by the Directive are covered by the standard. Upon this procedure, a reference to the EN 15194 will be published in the Official Journal of the EU. This will turn EN 15194 into a harmonised standard under the Machinery Directive. As a result, a pedelec that complies with EN 15194 will be presumed to comply with Directive 2006/42/EC.

The Machinery Directive holds a few additional administrative obligations for manufacturers. They have to have a complete technical file on the product available and they have to supply the pedelec with an EC Declaration of Conformity. The vehicle must have a CE conformity marking that consists of the initials ‘CE’ as shown below.

The CE marking shall be fixed next to the name of the manufacturer or his representative. However, this marking can only be affixed if the pedelec also conforms to Directive 2004/108/EC relating to electromagnetic compatibility.


Directive 2004/108/EC limits electromagnetic emissions of equipment in order to make sure that this equipment does not disturb other equipment such as radio, television, mobiles, washing machines, electrical power lines, ….

The Directive is also intended to ensure that the equipment itself is not disturbed by radio emissions of other equipment. Pedelecs with a maximum continous rated motor output of 0.25 kW and assistance up to 25 km/h must comply with Directive 2004/108/EC. For other pedelecs and E-bikes there are electromagnetic compatibility requirements in the type-approval procedure.

Most of the electromagnetic compatibility requirements are covered by EN 15194. However, CEN TC333 should also review EN 15194 to ensure that all obligations resulting from the Directive are covered by the standard. Upon this procedure, a reference to EN 15194 will be published in the Official Journal of the EU.

This will turn EN 15194 into a harmonised standard under the Machinery Directive. Consequently, a pedelec that complies with EN 15194 will be presumed to comply with Directive 2004/108/EC.
In expectation of such a harmonised standard, the manufacturer has to apply his own methodology for the electromagnetic compatibility assessment. He has to have technical documentation available to prove compliance. He may involve a Notified Body for the conformity assessment procedure. These are organisations accredited by the EU to assess conformity with the Electromagnetic Compatibility Directive.

The manufacturer is required to supply the pedelec with an EC Declaration of Conformity. Also, the pedelec must be identified by type, batch, serial number or any other information allowing for the identification. It should be possible to trace the actual manufacturer; therefore he or his representative needs to be identified by name and address. This information has to accompany the pedelec. Finally the CE marking has to be affixed as shown above, but as explained, this cannot be done unless the product also complies with the Machinery Directive.


Companies active in producing, distributing and selling electric bicycles or components of electric bicycles need to be aware of these rules and regulations and should observe them.

One of the major risks involved in the transport of batteries and equipment with batteries is short-circuit as a result of battery terminals coming into contact with other batteries, metal objects, or conductive surfaces. Therefore, their transport has to comply with very strict rules, which have been internationally harmonised.

Any Lithium-Ion battery over 100 Wh is classified as CLASS 9 - MISCELLANEOUS DANGEROUS GOODS under the dangerous good regulations for transport by road (ADR) and by air (IATA & IACO). Lithium-Ion batteries for pedelecs and E-bikes are more than 100 Watt-hours. So, their transport has to comply with these regulations. The UN number for Lithium-Ion batteries is 3480, if the batteries are contained in or packed with equipment the UN number is 3481. These numbers identify hazardous substances and articles in the framework of international transport.

To ship goods in the CLASS 9 category means that the battery needs to be tested in accordance with the UN Manual of tests and criteria, Part III, subsection 38.3. Furthermore, specific procedures related to handling, packing, labelling and shipping have to be followed.

If a company handles and packs dangerous goods at its own premises, a trained “Dangerous Goods Advisor” is required onsite to oversee that the goods are packed in the correct materials and to declare the goods safe to travel. It is also possible to hire a specialist company to pack the goods and to fill out a ‘Dangerous Goods Note’. It is compulsory for Dangerous Goods shipments to be accompanied by this document.

The regulations regarding the road and airfreight of Lithium-Ion batteries are very similar. The same Wh ruling, documentation and labeling requirements that apply to airfreight also apply to goods transported via road freight. The regulations do not only concern transport of batteries from manufacturer to distributor, but all transport including for instance the return of a defective battery by the consumer to the dealer or by the dealer to his supplier.


Batteries may contain metals such as zinc, copper, manganese, lithium and nickel, which are a risk to the environment and to human health if they are not correctly treated and disposed of. That is why the European Union has set out rules on how to collect, recycle, treat and dispose batteries in Directive 2006/66/EC, also known as the Battery Directive.

The Battery Directive applies to all batteries and therefore also includes Lithium Ion (Li-ion) and Nickel Metal Hydride (Ni-M-H) batteries commonly used in electric bicycles. These are classified as “industrial batteries”.

The Battery Directive establishes one and the same framework for the collection and recycling of batteries in all Member States. It also sets out minimum rules for the functioning of national collection and recycling schemes, in particular for the financing of these schemes by the producers. It is up to the battery producers to finance the cost of the collection, treatment and recycling of waste batteries.

The catch however is in the definition of ‘producer’. It is the person in a Member State who supplies or makes available to a third party, batteries (including those incorporated into vehicles) in that same Member State for the first time on a professional basis.

The following examples are meant to clarify the definition. A battery manufacturer or a domestic importer in a Member State sells batteries to a retailer who in turn sells them to end-users in the same Member State. The battery manufacturer or the domestic importer is the producer. An electric bicycle manufacturer buys batteries outside a Member State, then incorporates them into the bicycle and sells this in the Member State. He is the battery producer in this Member State. A retailer sells batteries in a Member State, which he bought outside that Member State. The retailer is the producer.

The following specific measures apply to industrial batteries. The producers or third parties acting on their behalf have an obligation to take back waste industrial batteries. All collected industrial batteries must be recycled, they may not be disposed of in landfills or by incineration.  By 26 September 2011, battery recycling processes must meet minimum recycling efficiencies of 65% for lead-acid batteries, 75% for nickel-cadmium batteries and 50% for other batteries.

Industrial batteries have to be readily removable from electric bicycles. If the battery is integrated in the bicycle, it has to be accompanied by instructions showing how the batteries can be safely removed and who is the best person to do this. Batteries must be labelled with a crossed out wheeled bin and chemical symbols indicating the heavy metal content of the battery. Producers must be registered in the national register of all Member States where they place batteries on the market for the first time.

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