DIY Mechanical Dongle

[flecc]

Lets say that the password for Bafang LCD is 0512.

My point is, the act of changing the settings breaks the law, not the complexity of the sequence of key presses.

The password is the difference, it is an addition to the machine to get access to possible illegality and therefore a modification. So without the password the bike complies. It baffles me why you are not understanding this difference.

Of course changing the settings break the law, but what has the complexity to do with anything. The question is only whether the change is available to the rider without a modification. Sequences of button presses are irrelevant , even cheap cycle computers have those, showing that they are rider controls.

Illegality is the norm in this business, the great majority of all supposed pedelecs supplied since 1999 in this country alone have been illegal as supplied. As someone in this business you surely know that.

From 1999 it was the illegal 250 watts rating. Then from November 2003 not having to pedal to get power was added to that illegality. As those two were being corrected between 2013 and 2015, a new ruling on Off Road buttons confirmed another post 2003 illegality for many machines as I've been showing.

And now, not for the first time, the DfT itself is extensively breaking the law in respect of its ruling on having throttles. They attempt to circumvent the law with SVA to L1e-A, but say they will consider the bikes are still EAPCs without bureaucracy.

But the law says that is absolutely not true, the throttle equipped L1e-A bikes as motor vehicles should be registered, number plated and third party insured and the rider should wear a m/c approved helmet. So it's turning a blind eye, but still illegal and why they cannot be used legally beyond that blind eye across the channel.

These are all technical breaches which will never trouble anyone, but they have all existed and some still do.
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[Woosh]

The password is the difference, it is an addition to the machine to get access to possible illegality and therefore a modification. So without the password the bike complies. It baffles me why you are not understanding this difference.

the password is difficult to crack without inside knowledge (eg from support people), same with the special key sequences. There is an easy defeat: buy a new LCD, the password comes with the LCD.
Your argument passes a blanket of blame on suppliers who do not try harder to stop people messing with speed reading or changing the speed limiter. My point is, there is no law to say that you have to stop customers messing up their bike. I made it quite clear on my website: don't change the settings, your warranty will be voided if you do. Don't take me wrong, I am at the opposite end of vfr on derestriction.
if the law is clear cut on this, suppliers would have fitted gyro or GPS chip to their controllers.

 

[flecc]

There is an easy defeat: buy a new LCD, the password comes with the LCD.

Which of course breaches the exemption.

I'm not trying to place any blame onto suppliers, just observing the technical breaches of pedelec law that have long existed and still do.

This all started with my correctly answering someone's academic question, an answer which the DfT's definition I've quoted confirms was correct.

There was no necessity for it to have been challenged nor any grounds for that to happen, as the total absence of any posted opposing legal evidence from my challenger shows.

Both the fact and the spirit of the law are absolutely clear and why you are able to definitively support that legality in your customer guidance.
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[Woosh]

I'm not trying to place any blame onto suppliers, just observing the technical breaches of pedelec law that have long existed and still do.

but yes you do. If a supplier forces those who want to derestrict their bike to buy a dongle then that's alright. If customers can derestrict their bikes without buying a dongle then it's that supplier's fault.

 

[Woosh]

about technical breaches:

if the specifications of EN15194 include measures to stop tampering with the speed measurement, the dongles will disappear.

There is a white paper at present, but not yet approved by the Commission.

RVFSR – Annex XVIII Maximum continuous rated and/or vehicle speed limitation by design L1e-A & B Specific anti-tampering requirements for electric motors in the Regulation

RVFSR – Annex XIX Vehicle structure integrity L1e-A & B Requirements in the Regulation + vehicles L1e-A and cycles designed to pedal in L1e-B must conform with ISO 4210:2014. Definition of cycles designed to pedal in Annex XIX: pedelecs up to 45 km/h + factor 4


D. TYPE-APPROVAL FACTOR FOUR 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 to 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 with a maximum continuous rated power of 4000 W. This category only includes two-wheel vehicles. Following 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 up to maximum 25 km/h will come under L1e-A. Electric cycles with a speed limit above 25 km/h and with three wheels belong to category L2e – “three-wheel moped”, whilst vehicles with four wheels belong to category L6e – “light quadricycle”. But since the requirements in these categories have not been adapted to electric cycles, it is virtually impossible for these electric cycles with three or four wheels to pass type-approval. As for pedelecs 45 km/h, manufacturers may decide to limit their vehicles with the so-called “factor four”. This means that the auxiliary propulsion power added to the driver’s pedal power is less than or equal to four times the actual pedal power. In that case, their vehicles become so-called “cycles designed to pedal of vehicle category L1e-B”. In the Regulation on Vehicle Functional Safety Requirements these are defined as: “cycles with a 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.” These “cycles designed to pedal” are not a separate type-approval category. Type-approval legislation does not hold a legal obligation to comply with factor four, it only holds a legal obligation to test the auxiliary propulsion power. This obligation also applies to all vehicles in L1e-A. If, however, the pedelec 45 km/h complies with factor four, then the requirement for vehicle structure integrity is that the pedelec must be designed and constructed to conform with all prescriptions regarding strength and construction of front forks and frames as stipulated in standard ISO 4210:2014. This, combined with the limitation of the weight to 35 kg, is the only practical consequence of the designation “cycles designed to pedal”. L1e-A vehicles must in any Rules & Regulations on Electric Cycles in European Union 10 case conform with the frame and fork requirements in ISO O 4210. Pedelecs 45km/h that do not comply with factor four are subject to more general requirements in the field of vehicle structure integrity. The legislative text stipulates: “Vehicles shall be so designed and constructed as to be sufficiently robust to withstand their intended use over their normal lifetime, taking into account regular and scheduled maintenance and specific equipment adjustments clearly and unambiguously set out in the instruction manual provided with the vehicle. The vehicle manufacturer shall provide a signed statement to this effect.” Moreover: “Vehicle assembly and construction in the assembly plant(s), in particular the processes relating to the vehicle frame, chassis and/or body and the drivetrain, shall be covered by a quality assurance system to ensure that essential mechanical connections such as welds and threaded connections, as well as other relevant material characteristics, are checked and verified as appropriate.” The assumption is that an electric cycle not complying with factor four, but which has passed the ISO 4210 tests, meets the more general requirements above. However, it should be noted that ISO 4210 does not apply to delivery and recumbent cycles. The Commission has confirmed that, probably in 2017, factor four will be examined based on scientific data and statistics on vehicles placed on the market. This examination may result in the review of factor four in a future revision of the Regulation.

 

[Deleted member 25121]

but yes you do. If a supplier forces those who want to derestrict their bike to buy a dongle then that's alright. If customers can derestrict their bikes without buying a dongle then it's that supplier's fault.

I could be wrong (often am) but I believe that it's not illegal to manufacture, supply or own ebikes that can exceed the 25kph assisted limit, but it is illegal to use them on public roads.
In that case if customers can derestrict their bikes without buying a dongle then it's the customer's fault. It might be a good idea for the supplier to point this out to the customer because I suspect that most won't be aware of the implications eg to their cycle insurance policy (voided) and driving license (points added).

 

[Woosh]

It might be a good idea for the supplier to point this out to the customer because I suspect that most won't be aware of the implications eg to their cycle insurance policy (voided) and driving license (points added).

it has always been explained on my website's home page for the last 10 years:
http://wooshbikes.co.uk/

Can I derestrict your electric bikes?

No, it will void your warranty.
Also, if you derestrict your bike, you need to get it registered as an electric moped, attach a number plate, get a free tax disc, have it MOT'd, only ride it on roads (not cycle lanes or paths) and also wear a helmet.
If someone decides to report you for riding a derestricted bike on the roads without it being registered or without insurance and helmet, you will most likely lose your driving licence.

 

[flecc]

but yes you do. If a supplier forces those who want to derestrict their bike to buy a dongle then that's alright. If customers can derestrict their bikes without buying a dongle then it's that supplier's fault.

Agreed, but that isn't my purpose and as I've observed, since the illegality is and always has been so widespread across both trade and consumers, I'm not targetting anyone.

My purpose as I clearly explained at the outset of this discussion was to prevent posts from confusing the issue, giving others the impression that somehow it was ok to defeat the pedelec exemptions. As your customer guidance shows, it isn't.
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[Woosh]

I could be wrong (often am) but I believe that it's not illegal to manufacture, supply or own ebikes that can exceed the 25kph assisted limit, but it is illegal to use them on public roads.

flecc made the point that if the bike is too easy to derestrict (ie without a dongle) then it's a technical breach.
My contention is that there is no such specifications in the EN15194. If there is, then the dongles will disappear.

 

[Deleted member 25121]

flecc made the point that if the bike is too easy to derestrict (ie without a dongle) then it's a technical breach.

Yes, the ebike would no longer conform to the regulatory requirements but I suggest that the offence would be in the operation of the bike, not its supply.

Very well done in showing those "Can I derestrict your electric bikes?" notes on your website, they show that you are a conscientious supplier and put you way ahead of people who simply import whatever they can from the Far East and sell on regardless of the regulations.

 

[flecc]

flecc made the point that if the bike is too easy to derestrict (ie without a dongle) then it's a technical breach.

As already explained, I mean a legal technicality, breaching the pedelec exemption in the type approval legislation, thus rendering the machine a motor vehicle in law and no longer a pedelec.

Thre DfT definition on pedelecs with added full throttles proves that to be so, defining them as L1e-A motor vehicles.

In this context EN15194 is irrelevant, the law can be and is broken while in compliance with the current EN15194.
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[flecc]

Yes, the ebike would no longer conform to the regulatory requirements but I suggest that the offence would be in the operation of the bike, not its supply.

That's right, there is no such thing as supplying an illegal vehicle.

Is is however an offence to falsely describe the vehicle as an EAPC pedelec if it is not.
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[Woosh]

Thre DfT definition on pedelecs with added full throttles proves that to be so, defining them as L1e-A motor vehicles.

that's another point I disputed in some other threads. The 2016 law only bans twist and go throttle.
Although the police aren't interested, that opens the door to interpretation and discussion on this forum.
If the bike requires you to pedal first before the throttle is activated, it is not a twist and go although it can give you up to 100% power. It's useless for hill start but still useful for people with chronic fatigue or bad joint pain.
I don't think that many members argue against that, but you did.

 

[flecc]

If the bike requires you to pedal first before the throttle is activated, it is not a twist and go although it can give you up to 100% power. It's useless for hill start but still useful for people with chronic fatigue or bad joint pain.
I don't think that many members argue against that, but you did.

I have defined my meaning by saying full acting throttles, having the same meaning as twist and go.

My last post on this link showed that again.

So I'm not arguing against that, and anyway, it still breaches the no power without pedalling exemption requirement, so still illegal.
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[Woosh]

So I'm not arguing against that, and anyway, it still breaches the no power without pedalling exemption requirement, so still illegal.

anyone can get an SVA for the throttle if they feel wanting to pay the £55 fees.
So on what basis a bike is illegal before paying £55 fee?

 

[flecc]

anyone can get an SVA for the throttle if they feel wanting to pay the £55 fees.
So on what basis a bike is illegal before paying £55 fee?

If sold as an EAPC pedelec it is illegal, since it breached the exemption.

If a machine comes with readily available rider controls, such as on the handlebars, which can defeat any exemption conditions, it is not an EAPC pedelec, and the DfT throttle ruling proves that to be absolutely so.

For goodness sake give it up. You've tried every which way of ducking and diving with all manner of irrelevancies to try to disprove the illegality and failed every time.

The type approval exemption conditions are the law for pedelecs as supplied. There is nothing more to be said on that.
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[Gringo]

What a load of bill hooks, my simple post about a man in a shed and his little experiment has been totally corrupted.
Why don’t you guys wait until break time and sort it out in the playground
Can someone please close this thread or remove all of my posts, I think I’m loosing the will to live

 

[Laser Man]

What a load of bill hooks, my simple post about a man in a shed and his little experiment has been totally corrupted.

Agreed!

I enjoyed seeing your ingenious mod - very clever.

All the legal stuff not so much.
It has become clear from this thread that only Bosch is squeaky clean - even DfT are accused of acting illegally!
Non Bosch owners might as well give up trying to be legal and set the power and speed to whatever suits.

 

[vfr400]

What a load of bill hooks, my simple post about a man in a shed and his little experiment has been totally corrupted.
Why don’t you guys wait until break time and sort it out in the playground
Can someone please close this thread or remove all of my posts, I think I’m loosing the will to live

You can't do that. This is an open forum where anybody can discuss any relevant points in any thread. You opened the thread, but that doesn't mean that you own it. You have the right to delete your own posts, but IIRC there's a time limit on that.

What did you think was going to happen when you you showed a way to make a bike illegal? Did you expect that everybody was going to clap then go away and forget about it? It's natural that people are going to ask whether they should copy it, whether they're going to get away with it, what the alternatives might be and any discussion around those points.

Think yourself lucky. Look at what happened to Sargon of Akkad when he posted on Twitter that he wouldn't even do an illegal act. It's still all over the news channels and newspapers three years after.

 

[flecc]

What a load of bill hooks, my simple post about a man in a shed and his little experiment has been totally corrupted.
Why don’t you guys wait until break time and sort it out in the playground
Can someone please close this thread or remove all of my posts, I think I’m loosing the will to live

It's as vfr400 says on your post. I was tempted to suggest it would be more appropriate to delete all the posts other than yours on the modification, but it would be unfair to delete queries on its status since you'd raised the subject.

There's a parallel with the helmet wearing debate, often members daren't mention helmets!

Whoops! That's done it.
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