Has anyone sought single vehicle approval and insurance, for a 250-1000w 15.5mph ebike?

[jonathan75]

I mean an ebike (perhaps including throttle) with pedals, per page 8 of this MSVA pdf guide ("[a] low powered moped is a 2 or 3 wheeled vehicle with pedals, auxiliary propulsion not exceeding 1kW and a maximum design speed of not more than 25 km/h.")

-) How easy was getting single vehicle approval, what hoops did you have to jump through?

-) How much did it cost you in total?

-) How much did insurance cost you?

-) Were you told that a helmet was required? Plates? Etc?

-) Did you have to take some sort of motorcycle basic training (for those white-knuckle 15mph uphills....)?

-) Did you discover whether it was permissible to use the bike in any other countries, and where and where not, e.g. on bike paths? What did you find was the case?

-) Were there any other unexpected (or expected) obstacles or hassles you encountered?

Thank you!

 

[flecc]

It's been done twice to our knowledge, but with considerable difficulty in meeting all the requirements. It is a motorcycle class so needing registration, full size rear number plate, VED disc (free), third party insurance, and a motor cycle BS approved helmet. An appropriate driving licence is also necessary, class P or better for two wheelers, but car drivers who passed their driving test before 1st February 2001 are pre-qualified. They can only be used on the roads, not on shared footpaths, cyclepaths etc.

Those without the right licence will have to undertake the usual basic training first (CBT) and then take a group P driving test.

The Low Powered Moped class is a pan EU class so is good for all member countries.

None of this is worth it at present since we are on the brink of getting the new EU class L1e-A which replaces the Low Powered Moped class and there are indications that there may be much easier requirements for that.

This link is to the current single vehicle requirements manual for motorcycles and mopeds.
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[jonathan75]

It's been done twice to our knowledge, but with considerable difficulty in meeting all the requirements. It is a motorcycle class so needing registration, full size rear number plate, VED disc (free), third party insurance, and a motor cycle BS approved helmet. An appropriate driving licence is also necessary, class P or better for two wheelers, but car drivers who passed their driving test before 1st February 2001 are pre-qualified. They can only be used on the roads, not on shared footpaths, cyclepaths etc.

Those without the right licence will have to undertake the usual basic training first (CBT) and then take a group P driving test.

The Low Powered Moped class is a pan EU class so is good for all member countries.

None of this is worth it at present since we are on the brink of getting the new EU class L1e-A which replaces the Low Powered Moped class and there are indications that there may be much easier requirements for that.

This link is to the current single vehicle requirements manual for motorcycles and mopeds.
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Thanks Flecc. Do you know where I might be able to read up more about the L1e-A category please? Do you know what kind of permission we will have to use L1e-A bikes abroad, extra requirements etc?

 

[flecc]

Thanks Flecc. Do you know where I might be able to read up more about the L1e-A category please? Do you know what kind of permission we will have to use L1e-A bikes abroad, extra requirements etc?

Still in the air at the moment I'm afraid, the DfT are not forthcoming with any information yet. L1e-A replaces the low powered moped and L1e-B replaces the 45kph moped class and these are pan EU regulations.

All I've seen is the draft type approval regulation some while ago, but it holds promise. For example:

Lighting was a big bugbear for getting an e-bike approved as a low powered moped since only a proper moped headlight would do, but the L1e-A type approval draft permits this:

White headlight, red rear light, amber cycle reflectors, amber pedal reflectors, red rear reflector, all to be to the standards for normal pedal cycles, ISO 6742-1 and 6742-2.

However, elsewhere I've also found a 500watt hurdle, anything over that requiring a brake light, so that may have to be overcome if it's still in place when the law is finalised.

Another promising item in the type approval draft is that space for a rear number plate is not required for L1e-A. That carries all sorts of implications, with no means of identification would registration, driving licence and insurance be possible? In opposition to that is that a new class Q driving licence has been announced for L1e-A, so the position is very confused and far from clear at present.

And of course the UK can impose additional usage requirements anyway, so I fear we will have to wait until very close to January 2016 which is the next implementation stage before learning the position for L1e-A.

The full type approval legislation for classes L1e-A and L1e-B two and three wheeled motor vehicles won't be completed until 1st January 2017, but most of what we need for L1e-A should be in place at 1st January 2016.

Here's some of the other draft easements and conditions:

No Horn or other audible warning device needed.

If weight under 35 kg:
a) No fluid checking for hydraulic brakes necessary
b) No checking of driver operated controls.
If over 35 kilos, conformity with the braking requirements of UNEC 78 is necessary.

The structural integrity must be that for normal City and Trekking bikes, defined in EN 14764.

Override facilities to increase the restricted speed or maximum power limit which are under the control of the rider are not permitted. N.B. Manufactured L1e-A e-bikes have to conform to specific anti-tampering regulations to prevent overrides. For SVA approval, hub motor and controller systems rated at up to 1000 watts and limiting to 25 kph maximum assist speed are acceptable. Crank motor systems driving through the transmission should have an anti-tampering system that prevents assist speed alteration by altering the gear ratios, e.g. magnetic sensor control of wheel speed etc.
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[jonathan75]

Still in the air at the moment I'm afraid, the DfT are not forthcoming with any information yet. L1e-A replaces the low powered moped and L1e-B replaces the 45kph moped class and these are pan EU regulations.

All I've seen is the draft type approval regulation some while ago, but it holds promise. For example:

Lighting was a big bugbear for getting an e-bike approved as a low powered moped since only a proper moped headlight would do, but the L1e-A type approval draft permits this:

White headlight, red rear light, amber cycle reflectors, amber pedal reflectors, red rear reflector, all to be to the standards for normal pedal cycles, ISO 6742-1 and 6742-2.

However, elsewhere I've also found a 500watt hurdle, anything over that requiring a brake light, so that may have to be overcome if it's still in place when the law is finalised.

Another promising item in the type approval draft is that space for a rear number plate is not required for L1e-A. That carries all sorts of implications, with no means of identification would registration, driving licence and insurance be possible? In opposition to that is that a new class Q driving licence has been announced for L1e-A, so the position is very confused and far from clear at present.

And of course the UK can impose additional usage requirements anyway, so I fear we will have to wait until very close to January 2016 which is the next implementation stage before learning the position for L1e-A.

The full type approval legislation for classes L1e-A and L1e-B two and three wheeled motor vehicles won't be completed until 1st January 2017, but most of what we need for L1e-A should be in place at 1st January 2016.
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Thanks - very helpful of you. Do you know where I could look at any of these draft documents, or any other info, please? I am really struggling to find anything on any of this on the web.

Do you know what bill the legislation is part of, or any other info so I can check the text and the parliamentary timetable etc?

 

[jonathan75]

It sounds like using a throttle abroad on a sub 250-watt bike then would require either low power moped single vehicle approval + insurance + the whole kaboodle, or after jan require... i don't know what. Is there a particular person in a govt agency who has been helpful over any of this who I could ask for guidance? I feel quite lost in legal uncertainty.

 

[flecc]

We are all a bit lost at the moment Jonathan, the DfT when I've tried asking for more information will only answer in terms of the current law and seem either very unprepared on the changes or unwilling to engage about them.

There's been no announcement about parliamentary bills on the subject that I know of, which doesn't surprise me since we have a record of doing these things at the last minute.

Here's a 2013 link to the Official Journal of the EU on the forthcoming type approval legislation and Annex II contains some details in accordance with what I've mentioned. Obviously there could be changes when the regulation comes into force January 2016, three years after this EU document.

The DfT only gives this link to their 2013 list of SVA guides which is obviously useless for finding current relevant information for L1e-A.

These items of information came from James Brown of the International Vehicle Standards (IVS) Department of the DfT following a query from our member Shemozzle999.
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[anotherkiwi]

I asked locally about approval for an electric moped and the guy kicked for touch telling me I would have to go to Paris to be controlled.

The French moped specifics that made me stop trying are:

Speed limited to 45 kph, even pedalling on the flat or downhill not just motor cut-out. Of course we already have kids on kitted mopeds which are completely illegal tooling around at 70+ kph we don't want elderly men (I joined that group this month...) mucking about on high powered electric bikes as well, the police have enough to do.

No trailer - the vehicle has to be type approved with trailer hitch, weight etc. defined by the constructor.

Moped approved horn - impossible to find other than at the wreckers yard, which has a different sound to a car or motorbike horn. A sort of very annoying electrical beeeeeep.

Brake lights are easy, we already have a switch in the brake lever it just needs to be wired to the lights as well as to motor cut out.

I think the best idea, as another forum member suggested, is to stick to a pedelec and print an official looking 250 Watt / 25 kph sticker for your 500-750 Watt motor and ride carefully.

 

[flecc]

Speed limited to 45 kph

No trailer - the vehicle has to be type approved with trailer hitch, weight etc. defined by the constructor.

Moped approved horn

These won't apply any more from January 2016 with the new pan EU L1e-A class though, speed limit is 25 kph as for pedelecs, no horn needed and cycle trailers permitted.
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[anotherkiwi]

For kits what we need basically to be legal is an LCD which does not give the user access to the set-up screens or to at least prevent from changing max speed and wheel diameter settings.

Do you think that our Chinese friends will catch on to that need someday soon? Of course hardcore hacker types will be busy reprogramming EPROMs and generally finding ways around the no tamper clause... And Bosch et al will have to figure out how to make a tamper proof speed detector.

I would be quite happy in any case with a 750 Watt L1e-A limited to 25 kph while all the same insisting that 30 kph is a much more reasonable/safer speed limit in urban traffic. I am sure the day will come when I am no longer strong enough to pedal to 45 kph and won't have the nerve to free wheel to 60 kph but I probably won't mind by then

 

[flecc]

For kits what we need basically to be legal is an LCD which does not give the user access to the set-up screens or to at least prevent from changing max speed and wheel diameter settings.

Do you think that our Chinese friends will catch on to that need someday soon?

Since this law affects EU wide sales, I think they will but maybe not soon. It will probably depend on pressure from this end.
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[jonathan75]

Thanks guys, much appreciated Very interesting and helpful.

Flecc glad you pointed me to Regulation 168/2013, I've been having a read. This bit is interesting.

"Article 2: Scope .... 2. This Regulation does not apply to the following vehicles.... (b) vehicles exclusively intended for use by the physically handicapped".

I remember from speaking with HMRC that things 'intended exclusively for use by the physically handicapped', are things that have been manufactured with that intention (although as it seems to be a legal term of art I think expert clarification is required here probably). As a builder of an ebike, I could put a throttle on (because I often need it) and the device be a self-built machine intended for such use. Of course the Regulations don't say what IS the procedure for approval of items intended for use by 'the physically handicapped' (such an insulting phrase).

I would cautiously suggest that perhaps it leaves the door open for self-builders and manufacturers selling within the EU to make/market a category of bog standard ebikes with a throttle for people who need that for physical reasons, without the l1e-a hoops to jump through.

I was a bit disturbed to read on page 54 that registration plate space will be required for l1e-a, also all the other arrangements like anti-tampering and 'lighting and light signalling devices' (which I don't find all that clear). I'm also confused about 'transitional' arrangements before 2016.

However I'm encouraged at the thought that maybe the Regulation is much more helpful than I previously supposed. It seems to leave an open door for the disability issue, and the L1e-A is encouraging too, although I don't like the fact it is silent on helmets, insurance, and fuzzy over the sort of physical additions to the bike which the test centre must approve.

Yet this disability issue is deeply fuzzy as well - time to contact the authorities for some clarification I think.

 

[jonathan75]

Oh - L1e-A has an annoying vague phrase - that the motor power (250w-1000w) should have its "primary" aim be to aid pedalling. Surely this cannot mean pedelec-only? I hope not. Mind you if I'm right about the "handicapped" bit then it shouldn't matter, touch wood. (edit - I'm not sure)

It differs from the earlier description of Article 2 (2) (h) on page 5 which refers to "pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling" - so I don't know if that means "primarily" can be read as "mostly but not always", as distinct from "where the output of the motor is cut off when the cyclist stops pedalling" (for the sub-250w). After all if they intended to describe pedelec-only for L1e-A, they had the linguistic tools to describe it and they didn't. So maybe they didn't intend pedelec-only (?)

Edit - the wording is quite worrying here because if throttle can't fall under L1e-A (or under a disability examption) then it means L1e-B which seems much more onerous (page 43).

 

[jonathan75]

Looks like the transitional EU law provision is Directive 2002/24/EC.

Just saw this useful guide to direct effect: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=URISERV:l14547&from=EN

 

[flecc]

Oh - L1e-A has an annoying vague phrase - that the motor power (250w-1000w) should have its "primary" aim be to aid pedalling. Surely this cannot mean pedelec-only? I hope not. Mind you if I'm right about the "handicapped" bit then it shouldn't matter, touch wood. (edit - I'm not sure)

It differs from the earlier description of Article 2 (2) (h) on page 5 which refers to "pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling" - so I don't know if that means "primarily" can be read as "mostly but not always", as distinct from "where the output of the motor is cut off when the cyclist stops pedalling" (for the sub-250w). After all if they intended to describe pedelec-only for L1e-A, they had the linguistic tools to describe it and they didn't. So maybe they didn't intend pedelec-only (?)

Edit - the wording is quite worrying here because if throttle can't fall under L1e-A (or under a disability examption) then it means L1e-B which seems much more onerous (page 43).

Throttle is permitted by L1e-A. As you note, the wording differs greatly from the pedelec one, but more importantly, the DfT's IVS has ruled that a throttle equipped pedelec has to be type approved to L1e-A. That inherently states throttle is permitted. There is also precedent in the S class e-bikes which have throttles, and that is spreading through the EU, currently in Germany and The Netherlands and coming to France in 2017.
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[jonathan75]

Throttle is permitted by L1e-A. As you note, the wording differs greatly from the pedelec one, but more importantly, the DfT's IVS has ruled that a throttle equipped pedelec has to be type approved to L1e-A. That inherently states throttle is permitted. There is also precedent in the S class e-bikes which have throttles, and that is spreading through the EU, currently in Germany and The Netherlands and coming to France in 2017.
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Wow. That's a big deal re the DFT requiring L1e-A approval for ordinary pedelecs. Would you have a link to anything where they state this, please, so I can have a look at what's happened?

 

[flecc]

Looks like the transitional EU law provision is Directive 2002/24/EC.

2002/24/EC is wholly incorpporated in 168/2013, so I'm no longer referring to it separately.

It was 2002/24/EC that resulted in the 200 watt / 250 watt confusion in the UK, due to it conflicting with the UK's EAPC legislation.

I'm as upset as you are about the vagueness of the correct position. Following 12 years of confusion i was hoping that these latest changes would bring clarity, but instead it seems the opposite is true.

For example, whether a number plate is required by L1e-A. I think it probably will be, now that we know there will be a Q driving licence for it.

But this highlights an illogicality. The much faster S class ebikes, legal to 45 kph (28mph), do not require a driving licence. How daft is that?
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[flecc]

Wow. That's a big deal re the DFT requiring L1e-A approval for ordinary pedelecs. Would you have a link to anything where they state this, please, so I can have a look at what's happened?

James Brown's reply to Shemozzle99 contained this:

Although ‘Twist and Go’ cycles will require Type Approval according to the dates in EU 168/2013 the decision has been taken that cycles that have ‘Twist and Go’ capabilities up to 15.5 mph will not be considered as motor vehicles and therefore will not require registration, tax, insurance and rider licensing. Any cycle with ‘Twist and Go’ capability above this speed will be classed as a motor vehicle.

Although he doesn't say L1e-A, clearly it cannot mean the full moped L1e-B class.

But this is another example of the confusion I refer to above, since L1e-A requires a new class Q driving licence!
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[flecc]

Flecc glad you pointed me to Regulation 168/2013, I've been having a read. This bit is interesting.

"Article 2: Scope .... 2. This Regulation does not apply to the following vehicles.... (b) vehicles exclusively intended for use by the physically handicapped".

Yes, I've noted that previously, but my thoughts are that any two wheeled vehicle that requires a rider to balance it is never going to be accepted as a vehicle suitable for the "physically handicapped". Insulting phrase as you rightly say, it does seem to imply a sufficient level of disability for the authorities have a narrow interpretation of suitability.
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[Stalkingcat]

I've just put an ebike through as a motorbike and it was indeed a PITA.

I started the process in December and am still waiting on the registration as the original MSVA certificate got lost. The DVLA are pretty disorganised at the moment with lots of test centres closing.

There are many requirements to make a standard bike road legal, mainly being m/c tyres and e-marked everything. It is possible to use none emarked equipment, however the test centre will then have to carry out their own testing on each non emarked component to make sure regs are met.