Statement by LEVA-EU on the review of the Motor Insurance Directive
Dear Members of the European Parliament,
Gent, 17 January 2019
LEVA-EU represents the strategic interests of light electric vehicle (LEV) retailers, dealers, distributors, manufacturers and suppliers to promote the development, sale, and use of LEVs in the EU. LEVA-EU is the only trade association in Europe that works exclusively for light electric vehicles.
Light, electric vehicles are all electric vehicles that come under Regulation 168/2013, as well as those electric vehicles excluded from the Regulation such as electric bicycles, electric scooters, electric hoverboards, etc.
We write to you in anticipation of the IMCO Committee vote on the amending of the Motor Insurance Directive, due next Tuesday, 23 January 2019.
The scope of the Directive is extremely important to the businesses we represent. Electric Power
Assisted Cycles (EPACs) as well as other light, electric vehicles excluded from Regulation 168/2013, must be excluded from the Directive. The current Commission text as well as some amendments tabled by IMCO members constitute an existential threat to the continued market uptake of these vehicles, and would cause major damage to the LEV sector in general.
Therefore, we kindly but strongly request you to:
- Vote for amendment 3 and 14 in MEP Charanzova’s report, but to add the following amendment 14:
Amendment
(1 a) In Article 2, the following paragraphs are added:
"This Directive shall only apply to vehicles covered by Regulation (EU) 2018/858*, Regulation (EU) No 167/2013** or Regulation (EU) No 168/2013**
Vote against amendments 56 and 83
We request the explicit exclusion of L1e-A vehicles from the Directive because these are electric bicycles with a motor that can assist up to a maximum speed of 25 km/h and a maximum continuous power of < 1 Kw. These vehicles are electric bicycles, which are very similar to EPACs. Their inclusion in Regulation (EU) No 168/2013 is a legal aberration which already severely hampers their market deployment. If, on top of inadequate technical regulations, these electric bicycles would also become subject to a Motor Vehicle Insurance, this will mean that all future perspectives for this category will be wiped out.
with the exceptioin of L1e-A vehicle (powered cycles); Belgium, for one, has given these vehicles the same status in the Belgian traffic code as conventional bicycles and EPACs. These vehicles do not constitute any more or other risks on the road than conventional bicycles and EPACs and therefore, need to be able to rely on the same status with reference to insurance legislation. That is why they need explicit exclusion from the scope of this Directive.
As for EPACs, they are currently absolutely essential for the growth of the LEV-sector. In 2017, an estimated 2 million EPACs were sold in the EU and that figure increases by 15 to 20% every year. The inclusion of EPACs in the scope of the Directive would directly threaten a thriving sector that mainly consists of SMEs, which provide a considerable number of green jobs, contribute overall to greening the economy and invest large sums in research, innovation and development across the EU. This sector contributes in a major way to achieving the goals set out be the EU in several fields, such as sustainable mobility, combatting climate change, energy-saving and -efficiency, greening the economy, public health, etc.
Furthermore, we would like to state the following;
The speed of electric bicycles and other light electric vehicles excluded from Regulation 168/2013 as well as L1e-A vehicles is not significantly different than the speed of a conventional bicycle
These LEVs do not cause major financial or personal damage, they have a completely different third-party liability risk than motor vehicles
Inclusion in the Motor Vehicle Insurance Directive of LEVs excluded from Regulation 168/2013 as well as L1e-A vehicles would result in unnecessary new regulatory burdens and would above all cause confusion among millions of road users throughout the EU.
Keeping light, electric vehicles that are excluded from Regulation 168/2013 as well as L1e-A vehicles out of the Directive will ensure their continued contribution to making mobility in Europe more sustainable.
We are at your disposal for any further details and we thank you in advance for your support.
Annick Roetynck, LEVA-EU Manager