Ebike still legal if I run 36V motor at 48V and limit speed to 15mph?

[vfr400]

nobody tests the LCD. You don't have 'EN15194 compatible LCDs' nor 'Non EN15194 compliant LCDs' . Manufacturers can password protect the settings but customers have also the right to access some settings. Responsibility lies entirely with those who alter the settings to go faster.

The LCDs are on the bike when they test the bike for compliance!

 

[Woosh]

they only require the speed limiter to work, not how tamperproof it is.
That's why there are discussions to make it tamperproof.

 

[peter.c]

Is it still a case of self certification with EN15194 if you assemble or manufacture ?

 

[soundwave]

BX Legacy

BX Legacy

www.bx-legacy.com

if i remember these were one of the only few hub motor systems that was software locked so the user could not change any motor settings.

 

[Woosh]

Early samples at the factory need to be properly certified before going into production but OEM variations are certified by similarity to share the cost out to several thousand units.

 

[Gavin]

"The Department of Transport say that electric bikes fitted with off-road switches or modes, that enable a bike’s motor to continue assisting to speeds beyond 15.5mph, do not comply with UK EAPC law"

I can't see how any kit (even if it is only 250w) that allows the end user to remove the speed limit can comply with the above.

N.B. I should add that I'm not asking this just to be pedantic. I get the impression the OP wants to be sure they are on the right side of the law here....

 

[vulcanears]

Tampering with the label is also covered by perverting the course of justice [...]

What specificly regarding my question would you call "Tampering with the label"?

 

[Woosh]

BX Legacy

BX Legacy

www.bx-legacy.com

if i remember these were one of the only few hub motor systems that was software locked so the user could not change any motor settings.

it's very easy to 'lock' the speed limit to the wheels RPM but customers can force manufacturers to let them have access to the settings unless the norms specify the protected settings.

 

[Woosh]

"The Department of Transport say that electric bikes fitted with off-road switches or modes, that enable a bike’s motor to continue assisting to speeds beyond 15.5mph, do not comply with UK EAPC law"

I can't see how any kit (even if it is only 250w) that allows the end user to remove the speed limit can comply with the above.

N.B. I should add that I'm not asking this just to be pedantic. I get the impression the OP wants to be sure they are on the right side of the law here....

I think there is a degree of confusion here.
It is not the responsibility of the manufacturers of LCDs to lock their LCD.
It's not the responsibility of the kit vendor to prevent his customers breaking the law.
It's not in the EN15194 test specifications that the LCD could not be altered by customers.
When the kit is delivered, it complies with all the norms.
When someone is caught speeding, the bike no longer complies.
So whose fault is it to render the bike non-compliant?

Would you say, it's the LCD manufacturers', or the kit vendor's?

 

[vulcanears]

@Woosh
The argument ist that it might *NOT* be compliant with all the norms, since the ability to change the maximum speed could be considered an offroad-switch.

One of the definitions of 'switch' is: "a program variable which activates or deactivates a certain function of a program"

 

[Gavin]

I think there is a degree of confusion here.
It is not the responsibility of the manufacturers of LCDs to lock their LCD.
It's not the responsibility of the vendor to prevent his customers breaking the law.
It's not in the EN15194 test specifications that the LCD could not be altered by customers.
When the kit is delivered, it complies with all the norms.
When someone is caught speeding, the bike no longer complies.
So whose fault is it to render the bike non-compliant?

Would you say, it's the LCD manufacturers', or the kit vendor's?

In the event of an accident it's the end user's fault without any doubt, because we're all responsible for our own actions.

My point is that in the case of any ebike (regardless of whether it's a kit or shop-bought), the very fact that the speed limit can be increased by the end user (even if it hasn't been) renders it illegal based on my quote above.

 

[Nealh]

Revos in Bristol sell a wholly legal kit no display and not option to change the assist limit.

 

[peter.c]

Any modification from standard factory kit or bike can be considered not to conform, if the label states 250w 36v and you fit a 48v battery , it is not as tested at the time of manufacture
It is user / rider beware

 

[Gavin]

Revos in Bristol sell a wholly legal kit no display and not option to change the assist limit.

Thanks @Nealh. So (in my world anyway), that's an example of a fully legal kit that couldn't fall foul of the law

 

[Woosh]

The EN15194 test schedule has no provision concerning how tamperproof the LCD must be.
Although we all understand what a computer software switch is, the idea that a piece of computer software which can be modified is therefore a switch has never been successfully tested in Court as far as I am aware.

You either accept one way or the other, that's why I said there is a degree of confusion.

 

[Gavin]

The EN15194 test schedule has no provision concerning how tamperproof the LCD must be.
The idea that a piece of computer software which can be modified therefore it's a switch has never been successfully tested in Court as far as I am aware.

You either accept one way or the other, that's why I said there is a degree of confusion.

Agreed. We all need to start crashing a bit more to get some cases through the courts! (Bit of an innapropriate joke I know).

In all seriousness though (and based on the differing opinions represented here), I think the Hanlon case could be a get out of jail free card for anyone caught using an illegal bike....

 

[WheezyRider]

"The Department of Transport say that electric bikes fitted with off-road switches or modes, that enable a bike’s motor to continue assisting to speeds beyond 15.5mph, do not comply with UK EAPC law"

I can't see how any kit (even if it is only 250w) that allows the end user to remove the speed limit can comply with the above.

N.B. I should add that I'm not asking this just to be pedantic. I get the impression the OP wants to be sure they are on the right side of the law here....

I've made this point before. I agree, the law strictly speaking says almost all e-bikes on the market are basically illegal, as it's possible to set them up to go faster than 25 kph. However, the law relating to e-bikes is a total mess, made up by people who don't seem to live in the real world and certainly can't keep up with rapidly changing technology.

It seems as if there is a law, it says nothing is legal, but we'll turn a blind eye if you don't make a nuisance of yourself.

At the end of the day, I think it comes down to what I call "plausible deniability of wrong doing".

If you fit a motor greater than 250W, your bike doesn't have pedals or it doesn't at least pay lip service to the 25kph limit, then you are clearly putting yourself in a bad legal position.

If you can show that you have tried to do everything reasonable to keep within the law, such as it is, I think you are more likely to get a sympathetic hearing.

 

[Gavin]

However, the law relating to e-bikes is a total mess

I've made this point before. I agree, the law strictly speaking says almost all e-bikes on the market are basically illegal, as it's possible to set them up to go faster than 25 kph. However, the law relating to e-bikes is a total mess, made up by people who don't seem to live in the real world and certainly can't keep up with rapidly changing technology.

It seems as if there is a law, it says nothing is legal, but we'll turn a blind eye if you don't make a nuisance of yourself.

At the end of the day, I think it comes down to what I call "plausible deniability of wrong doing".

If you fit a motor greater than 250W, your bike doesn't have pedals or it doesn't at least pay lip service to the 25kph limit, then you are clearly putting yourself in a bad legal position.

If you can show that you have tried to do everything reasonable to keep within the law, such as it is, I think you are more likely to get a sympathetic hearing.

Thanks @WheezyRider, you said it far more eloquently than I managed!

I should add, I'm well aware of my sins (750w motor, thumb throttle etc) and I'm perfectly comfortable with my choices and the risks I take. But I think this thread might be depressing reading for the OP who seems very keen to be "totally legal"...

 

[WheezyRider]

Thanks @Nealh. So (in my world anyway), that's an example of a fully legal kit that couldn't fall foul of the law

I bet someone will hack one before long. Any measure that gets put in the way will be defeated by hackers eventually.

 

[WheezyRider]

Any modification from standard factory kit or bike can be considered not to conform, if the label states 250w 36v and you fit a 48v battery , it is not as tested at the time of manufacture
It is user / rider beware

Hmmm, but at what point does a "modification" to a factory bike become a "kit bike" which is then not covered by the legislation?