Hi - I have a few questions about what to choose?

Woosh

Trade Member
May 19, 2012
20,451
16,916
Southend on Sea
wooshbikes.co.uk
Do you think that the garage doing the certification is basing it on the inscriptions on the engine and interfering with its software?
they are approved testing stations and there are not many around. There are about 40 testing stations for the whole of the UK. In Essex, there is only one in Chelmsford.
They know probably more about motors than most of us do, so don't expect to argue the toss with them.
The certificate that guerney attached to his post can be downloaded directly from bafang website, they also have UKCA approval for their BBS01B for download.
It's up to you to gauge how much risk you want to take, we can only give you the facts,
 

flecc

Member
Oct 25, 2006
53,262
30,649
Do you know how the engine power test is carried out?
Do you think that the garage doing the certification is basing it on the inscriptions on the engine and interfering with its software?
Do you think that the garage has the manufacturer's permission for such interference? You can always check this and ask about the relevant company's authorisations to interfere with its software.
That is how the law works! You must have the appropriate permits and certificates for everything.
If a garage does something on the basis of, because on YouTube there was how to go in and change the firmware - then all the decisions made by that garage have the same value as you write on a piece of paper.
If you give an engine for certification, with unknown parameters (the inscriptions are only a hint that may help). An examination of it is carried out.
And we are back to point 1.
How do you test to find the power of an engine? Do you know? Because I know:)
You are being very stubborn, despite having absolutely no knowledge of this law.

It doesn't matter how engine power is tested since this is nothing to do with actual power. This EU and UK wide law is only for the maximum continuous rated power. The EN15194 test for that is is only to ensure the motor can perform at that level without overheating. There is no test whatsoever for maximum power.

Furthermore, these tests are only ever carried out on complete pedelecs, since EN151094 only applies to complete pedelec bicycles, so independently manufactured motors such as those from Bosch can have no rating until they are fitted to bicycles and certified by an accredited laboratory to conformity. That costs the manufacturer several thousands of euros/pounds for each model type so equipped. Once done, each model type is certified to be either an EPAC/ EAPC (pedelec), by virtue of meeting the exemption (h) requirements of EU law 168-2013, or if failing, an L1e motor vehicle in that Two and Three Wheel Motor Vehicle Type Approval Law.

Kit motors like the BBS ones from Bafang can never be tested to EN15195 since they are not subject to 168-2013 Type Approval. Instead they have a Single Vehicle Approval law system. Once a bicycle has had a kit motor added is should be submitted to a government approved testing station for MSVA (Motor Cycle Single Approval) vehicle inspection and test to gain an MAC (Ministers Approval Certificate), certifying it as a pedelec. That is the £55 test that you mention, not carried out by any garage as you seem to think.

The many owners who convert a bicycle and do not do that submission and have no MAC are technically riding illegal machines, entitling the police to seize their machines if they choose to. Fortunately in Great Britain at least that isn't common practice, so as long as only a 250 watt rated motor is used and the bike is limited to 15.5mph assist speed they get nodded through.

You see, I do know the law, every last tiny detail of it to perfection, so please show a little humility and stop trying to correct those who do know.
.
 
Last edited:

lenny

Esteemed Pedelecer
May 3, 2023
2,810
841
The certificate that guerney attached to his post can be downloaded directly from bafang website
EN15194:2017 CLAUSE 4.2.15

4.2.15 Electromagnetic compatibility: Operation of the device must be unaffected in the normal electromagnetic compatibility environment in which it is intended to work, taking into account disturbance generated by adjacent apparatus which is compliant with relevant ISO, EN, or other Internationally recognized standards. Information required to ensure uninterrupted use of the device must be contained in the user instructions.

https://extranet.who.int/prequal/sites/default/files/document_files/PQS_E006_TH01.1.pdf
 
  • Like
Reactions: Woosh

flecc

Member
Oct 25, 2006
53,262
30,649
Which is most of us on this forum :D
Fortunately in Great Britain at least that isn't common practice, so as long as only a 250 watt rated motor is used and the bike is limited to 15.5mph assist speed they get nodded through.

I said Great Britain and not UK for a good reason, since the police in Northern Ireland have a previous history of seizing pedelecs as being illegal. That's because N.I. has devolved Road Traffic law and haven't necessarily followed UK law, but are subject to EU law.
.
 

saneagle

Esteemed Pedelecer
Oct 10, 2010
7,007
3,241
Telford
And the police, on seeing such a card say:
"ok, we have no more questions and that's it"?
Nobody from the police verifies this, checks it, contacts the German certification office to confirm this document?
Hmmm interesting...
Thanks for sharing this!
This is very helpful.


Do you know how the engine power test is carried out?
Do you think that the garage doing the certification is basing it on the inscriptions on the engine and interfering with its software?
Do you think that the garage has the manufacturer's permission for such interference? You can always check this and ask about the relevant company's authorisations to interfere with its software.
That is how the law works! You must have the appropriate permits and certificates for everything.
If a garage does something on the basis of, because on YouTube there was how to go in and change the firmware - then all the decisions made by that garage have the same value as you write on a piece of paper.
If you give an engine for certification, with unknown parameters (the inscriptions are only a hint that may help). An examination of it is carried out.
And we are back to point 1.
How do you test to find the power of an engine? Do you know? Because I know:)

ps.
And a small point - we haven't even mentioned one problem yet: the battery!
Therefore, the legislator has limited itself to the laconic - it must not exceed 250W when pedalling.
It seems you're not listening to what people are telling you. Power is not limited to 250w and there is no test for motor power other than to prove that the motor is not over-rated. The limit applies to the RATING of the motor. If it has a manufacturer's label on it saying 250w, it's legal. If it doesn't have the label or other markings, it's not legal. That's all the police have to look for - no test, no special equipment.

The battery must be 48v or lower, so a 52v one (14S) is not legal.
 
Last edited:
  • Like
  • Agree
Reactions: chris667 and Woosh

chris667

Pedelecer
Apr 7, 2009
164
108
An examination of it is carried out.
No.

What will happen to you is what will happen to all the other owners of illegal ebikes that have had their bikes confiscated by the police when they were stopped by the police:
  1. The police will pull you over.
  2. The bike will be impounded until you can produce documenation proving it is UK legal as a pedelec (which it won't be) and insurance (which you will not be able to get).
  3. When you can't produce a valid insurance certificate, it will be destroyed and you'll be fined, typically £300.
Here's another angle to look at, which as someone with legal training I thought about long and hard before buying a bike.

As a homeowner, I would not want to ride any bike without insurance. I don't care if my bike gets stolen (it will be annoying, but it's paid for itself several times over now so I'll happily get another), but I don't want to be sued and lose my home if I'm involved in an accident. I have third party liability cover with Laika, it's £1.50 a month.

Don't imagine for a second that you would have any sort of insurance cover if you were riding a bike with a BBSHD. You might try and argue that your bike was somehow magically restricted, but the insurance company would have other ideas like the police will.

Don't waste your money. You'll be annoyed and out of pocket if you have your bike crushed.
 

AGS

Esteemed Pedelecer
Feb 12, 2023
608
190
Interesting that a couple of Talaria’s and Surrons are being auctioned off at the direction of the Police. So it looks like they aren’t crushing everything.


These will probably get seized again and re-auctioned.
 
  • :D
Reactions: Az.

flecc

Member
Oct 25, 2006
53,262
30,649
Interesting that a couple of Talaria’s and Surrons are being auctioned off at the direction of the Police. So it looks like they aren’t crushing everything.


These will probably get seized again and re-auctioned.
Given how broke Britain is now, it's perhaps a new way to fund police forces? ;)
 

thelarkbox

Esteemed Pedelecer
Aug 23, 2023
1,252
385
oxon
Interesting that a couple of Talaria’s and Surrons are being auctioned off at the direction of the Police. So it looks like they aren’t crushing everything.


These will probably get seized again and re-auctioned.
effectively a real stupid tax
 
  • Like
Reactions: flecc

Az.

Esteemed Pedelecer
Apr 27, 2022
2,093
932
Plymouth
Kit motors like the BBS ones from Bafang can never be tested to EN15195 since they are not subject to 168-2013 Type Approval. Instead they have a Single Vehicle Approval law system. Once a bicycle has had a kit motor added is should be submitted to a government approved testing station for MSVA (Motor Cycle Single Approval) vehicle inspection and test to gain an MAC (Ministers Approval Certificate), certifying it as a pedelec. That is the £55 test that you mention, not carried out by any garage as you seem to think.

The many owners who convert a bicycle and do not do that submission and have no MAC are technically riding illegal machines, entitling the police to seize their machines if they choose to. Fortunately in Great Britain at least that isn't common practice, so as long as only a 250 watt rated motor is used and the bike is limited to 15.5mph assist speed they get nodded through.
So technically all converted bikes are illegal until owner get MAC?
 

flecc

Member
Oct 25, 2006
53,262
30,649
So technically all converted bikes are illegal until owners get MAC?
Yes, technically they need SVA in the rest of the EU as well, as I explained at length in my pedelecs legal thread , repeated below, but it's widely ignored law:

Kit Motors
Be aware that hardly any of the above applies to kits or any home construction, the regulations only being for manufactured pedelecs. So both individuals and suppliers operate in a legal vacuum in which all try to supply and/or use as closely conforming to the complete e-bike law as they can, trusting that is acceptable. That has always worked throughout all of Europe and the UK without any mention of a possible prosecution, providing the three main points of the law are adhered to, i.e. 250 watts maximum assist, 15.5 mph maximum assist speed and power only when pedalling.

However, I can tell you the legal way of dealing with a kit, athough no-one has ever done it:

1) Buy and fit the motor kit.
2) Make an appointment at an approved vehicle testing station, paying the £55 test fee.
3) Most often the purpose of this is to get an SVA (Single Vehicle Approval), entitling it for use as a type approved motor vehicle. However your intention will be to get the inspector to agree that it meets the pedelec requirements so is exempt from being a motor vehicle and is approved as a pedelec.

However, if you get and accept SVA approval as well at the same time, as specified earlier in getting legal permission, you will be able to have a fully acting throttle on a post December 2015 pedelec with it still considered a bureaucracy free pedelec, a bonus. I repeat though, no-one to my knowedge has ever done this to create a kit pedelec so it's never been necessary, but it is the DfT specified correct way when creating any motorised vehicle from more than one vehicle or from parts.

N.B. The DfT is increasingly referring to SVA as IVA (Individual Vehicle Approval), so you might need this for online linking in future.
In summary, legislators don't like kits, too many variables, so avoid their mention like the plague. Mainland Europe killed the kit car industry long ago and our laws have damaged it here too, so we are perhaps lucky that the lawyers don't pay attention to our little pedelec kit niche.
.
 

Az.

Esteemed Pedelecer
Apr 27, 2022
2,093
932
Plymouth
So both individuals and suppliers operate in a legal vacuum in which all try to supply and/or use as closely conforming to the complete e-bike law as they can, trusting that is acceptable.
OK... so what can be done to change this situation (apart from getting SVA)? I don't like an idea of being in legal vacuum. I also have an impression there is no such thing as legal vacuum. Bike is either legal or not.

1) Buy and fit the motor kit.
2) Make an appointment at an approved vehicle testing station, paying the £55 test fee.
3) Most often the purpose of this is to get an SVA (Single Vehicle Approval), entitling it for use as a type approved motor vehicle. However your intention will be to get the inspector to agree that it meets the pedelec requirements so is exempt from being a motor vehicle and is approved as a pedelec.
It is quite an interesting option, but I find it inaccessible and discriminatory. Closest approved vehicle testing station is one hour drive away on motorway and I have no idea how to get there on e-bike unless one has a car.
 

flecc

Member
Oct 25, 2006
53,262
30,649
OK... so what can be done to change this situation (apart from getting SVA)? I don't like an idea of being in legal vacuum. I also have an impression there is no such thing as legal vacuum. Bike is either legal or not.
It's not necessary to change it. The whole of Europe have simply ignored this bit of legal minutiae and no action has been or ever will be taken against. The law is the first to admit that the law is an ass at times.

Some proofs of there being no need for action:

Despite there being a path for everything else, the authorities have never provided a path or fee to get a kit equipped pedelec approved at a testing station. So it can only be done by misusing the path to get L1e-A motor vehicle approval as a way to get the machine recognised as an EAPC by falling short of that due to the EAPC exemption, or by qualifying as a 250LPM moped treated as an EAPC in Great Britain.

The 250LPM treatment as EAPCs is an illegal permission to break a number of our motor vehicle laws. In law the police can prosecute, but they have been ordered not to.

Between 10th November 2003 and 25th April 2015, almost all EAPCs being used in the UK were illegal according to our law. We knew it, the police knew it, the DfT knew it, all Europe's governments knew it, but all ignored it for the sake of convenience, since there were bigger issues at stake.

Cycling on the pavements is illegal at all times in Great Britain with prescribed penalties, but all cyclists have ministerial permission to break that law, if at any time they do it out of fear of traffic. Those under 16 have permission to break it all the time.

These examples and others demonstrate that some issues are too unimportant or too much of a nuisance to be bothered with, so they are ignored.
.
 
Last edited:

Az.

Esteemed Pedelecer
Apr 27, 2022
2,093
932
Plymouth
It's not necessary to change it.
I humbly disagree. For many of us it is important to have legal bike and at this time it doesn't seem like it is the case.
For example my bike might be taken by police for whatever reason and I have no legal ground to challenge this decision.

These examples and others demonstrate that some issues are too unimportant or too much of a nuisance to be bothered with, so they are ignored.
For us it is important. I can easily imagine third party insurance claim rejected on this ground.
 

flecc

Member
Oct 25, 2006
53,262
30,649
I humbly disagree. For many of us it is important to have legal bike and at this time it doesn't seem like it is the case.
For example my bike might be taken by police for whatever reason and I have no legal ground to challenge this decision.
You do have grounds and a proven path. When the police have either seized or unfairly attempted prosecution ofan EAPC on legal grounds we have successfully opposed that, even making the DfT step down. Common practice is a legal ground. For example when any of the public have used a route across some privately owned ground unopposed for twenty years or more, it becomes a public footpath by common practice in law.

For us it is important. I can easily imagine third party insurance claim rejected on this ground.
That has never been done. Common practice, indeed universal practice applies again.

Basically you are unnecessarily nit-picking, since there are numerous neglected old laws we break all the time. For example, for nearly a century every London Taxi driver was always breaking the law since he didn't have the bale of hay on board (for his horse) that the law strictly required, regardless of him not having horse. Eventually an update of the Hackney Cab regulations for other reasons incidentally lost that requirement,

For much of the 19th and 20th centuries a woman's use of makeup was illegal !!
.
 
Last edited:
  • Informative
Reactions: Az.

thelarkbox

Esteemed Pedelecer
Aug 23, 2023
1,252
385
oxon
Whats important is having the ability to get insurance in the first place. Once covered and in need of cover keep the digits crossed they dont pick you to be the poster child / public enemy for the test case..

Chances of loosing the house are significantly diminished by having cover in the first place, especially if the 3rd party liability is backed up by legal experiences too. expenses i cant spell and auto correct bahh!
 
  • Like
Reactions: flecc