Help! How do they enforce legal max power?

vfr400

Esteemed Pedelecer
Jun 12, 2011
9,822
3,993
Basildon
As explained a few months back EN15194 doesn't quite work like that, it is a directive. The motor needs to be labelled as 250W, the battery needs to be labelled as 48v max with a CE mark and the frame needs a conformity sticker where the manufacturer (you?) states:

EPAC According to EN15194
25 km/h
250W

The documentation is a requirement that the seller of the bike must respect, you don't need to carry it with you. And as you made the bike(s) for yourself there is no sales transaction requiring you to write one for yourself.

Both of my pedelecs are illegal - no sticker, home made battery with no marking. But they are restricted to 25 km/h assist and the motors are both marked correctly so if I mow down a phone zombie I am reasonably confident that if the judge isn't having a bad day the missing markings would not be a major offence.

PS there is nothing to stop you from getting a 72v controller and plugging in 2 x 36v batteries in series. As long as you have a 250 W motor...
I already said that I don't believe that it's a legal requirement for your bike to comply with EN15194. If it is, all of us that don't have a certificate of compliance are in trouble. Flecc says that it's been adopted into UK law, but what does that mean? I believe that it has more to do with trading than riding bikes, but what if you sell your used converted bike on Ebay? If compliance is indeed a legal requirement for all of us, then one could be prosecuted for no tax, insurance and MOT for not having a charging instruction somewhere.

If there is no obligation to comply with EN15194, then you are not limited to 48v. The 48v is just one of the requirements, and the charging instruction is another. There is no ranking of requirements into mandatory and optional. In fact the charging instruction is a stated requirement, while as the 48v isn't. Instead it's implied from the scope, which is why nobody knows what it means.
 
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flecc

Member
Oct 25, 2006
53,213
30,613
Flecc says that it's been adopted into UK law, but what does that mean?
All I know is that it is compulsory, whatever that means:

Scope of EN 15194
Pedelecs are classified in the EU as bicycles, and so they are exempt from type approval (2002 / 24 / EG). For them, EN 15194 applies and it should be available in the various national languages.

Most EU member states have not yet adopted EN 15194 into their national legislation as compulsory, with the exceptions being France and the UK. So most EU countries permit “self certification”

That means that if a manufacturer has their own test facilities or just believes that their pedelec complies with all standards, they can simply apply a CE mark and release it to the shops. Nonetheless many manufacturers today do have their products tested independently. Anyone wanting to err on the side of caution should ask for the test reports to be made available.


Information Link

In the UK suppliers do commonly have the pedelecs they supply tested to conform with the law, I can remember Wisper saying it cost around £10k per model.
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vfr400

Esteemed Pedelecer
Jun 12, 2011
9,822
3,993
Basildon
All I know is that it is compulsory, whatever that means:

Scope of EN 15194
Pedelecs are classified in the EU as bicycles, and so they are exempt from type approval (2002 / 24 / EG). For them, EN 15194 applies and it should be available in the various national languages.

Most EU member states have not yet adopted EN 15194 into their national legislation as compulsory, with the exceptions being France and the UK. So most EU countries permit “self certification”

That means that if a manufacturer has their own test facilities or just believes that their pedelec complies with all standards, they can simply apply a CE mark and release it to the shops. Nonetheless many manufacturers today do have their products tested independently. Anyone wanting to err on the side of caution should ask for the test reports to be made available.


Information Link

In the UK suppliers do commonly have the pedelecs they supply tested to conform with the law, I can remember Wisper saying it cost around £10k per model.
.
That's all in relation to CE marking and bringing your product to market. I don't believe that it applies to what you do with your own bike.

Thinking about it, if it was a legal requirement to comply with EN15194, surely that would be mentioned on the government website guidelines, but it isn't.

I think we can all relax and forget about what's written in EN15194 as long as your bike meets the definition of an EAPC, i.e. 25 km/h max, power stops when you stop pedalling, and motor rated at no more than 250w. It just doesn't make sense that somebody could lose their driving licence because they were riding their electric bike without a written instruction telling them that it would take longer to stop in the wet than the dry when braking.
 

flecc

Member
Oct 25, 2006
53,213
30,613
That's all in relation to CE marking and bringing your product to market. I don't believe that it applies to what you do with your own bike.

Thinking about it, if it was a legal requirement to comply with EN15194, surely that would be mentioned on the government website guidelines, but it isn't.

I think we can all relax and forget about what's written in EN15194 as long as your bike meets the definition of an EAPC, i.e. 25 km/h max, power stops when you stop pedalling, and motor rated at no more than 250w. It just doesn't make sense that somebody could lose their driving licence because they were riding their electric bike without a written instruction telling them that it would take longer to stop in the wet than the dry when braking.
I agree, for all normal purposes we should forget about it, it's only a concern for French and UK suppliers to conform to the law.

The only time it might intrude on a UK pedelecer's life is in the one in a billion chance of their turning someone hit into a cabbage. Then the insurance company lawyers who stop at nothing to try to escape or reduce a multi millions reward can get involved.

Then as you've acknowledged yourself, if as a cyclist you've hurt someone, the courts can still act nasty, regardless of the law's strict interpretation.

Certainly not something for us to worry about though.
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