L1e-A testing requirements

anotherkiwi · Dec 9, 2015

“Furthermore, the Commission explicitly stated that open throttle bicycles up to 25 km/h would be classified as L1e-A vehicles. Before this statement, the Commission had indicated that L1e-A was meant for pedal assisted cycles 25 km/h up to 1 kW only. Categorization of open throttle bicycles as L1e-A not only frees these vehicles from factor 4 but also results in additional benefits. The vehicles will enjoy all adapted requirements for electric cycles as well as exclusion from a few additional requirements, i.e. mirrors and driver-operated controls (including identification of controls, tell-tales and indicators).”

Which means the only difference is a throttle and that speed is limited to 25 kph and nominative power to 1 kW.

flecc · Dec 9, 2015

I don't think there's anything definitive yet on this issue. We still seem to only have the 2013 draft for the type approval of L1e-A and L1e-B and from some statements that also appears to have been changed in certain details.

The most important thing to note is the recent introduction of a group Q driving licence for L1e-A, and the fact that L1e-A is a motor vehicle. Those things indicate registration and insurance will be necessary, and for those to be administered a number plate will be necessary. That conflicts with the draft type approval which specified no number plate space required for L1e-A.

There's also the little matter of MOTs which apply to all motor vehicles. All in all I cannot see how a pedelec with throttle can be type approved as L1e-A and still avoid considerable bureaucracy. Therefore I doubt the DfT are correct in saying they can be treated equally as pedelecs without other changes in the laws being implemented.
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flecc · Dec 9, 2015

Thanks Shemozzle, their reaction to the EC reply seems similar to my disbelief at the DfT ruling. Statements are being made which simply cannot accord with current law or current type approval intentions.
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flecc · Dec 9, 2015

So what we need now is clarification on:

1) The L1e-A low powered moped type approval requirements.

2) Where twist and go pedelecs stand with regards to L1e-A type approval requirements,

3) Does there really have to be pedal input to have power in L1e-A mopeds? If so this is not the replacement class for the Low Powered Mopeds, since those did not have to have pedal input. Making those L1e-B if they have open throttles is surely too draconian for a 15.6 mph vehicle? A full moped licence to ride at that speed would be ridiculous and make the class just at redundant as the Low Powered Moped class has been, with no takers again.

I still think this whole issue is far from clear, with each piece of news the mess appears to grow.
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Ruadh495 · Dec 10, 2015

I think we need to watch this very carefully, because it's looking to me like L1e-A is our existing EAPC. I'm probably being paranoid, but this is how I see it: To be classed as a pedal cycle an EPAC will have to be Type Approved, that reduces the EPAC class to a whitelist of specific models which have been submitted for testing by the manufacturer. Anything else (kits, homebuilds, non-approved models) will not be road legal. The only process for making them road legal would be SVA, for which the minimum standard will be L1e-A. So the majority of electrically assisted cycles will become "motor vehicles", requiring registration, insurance, licensing etc. The provision of a new license group suggests they don't expect L1e-A to be the footnote "Low-Powered Mopeds" currently are. It's not just about throttles.

Don't expect them to approve any helmet standard other the current motorcycle one either. After all motorcycle helmets are required on mopeds which can't exceed 30mph, something which pedal cycles comfortably do given a downward slope.

Of course you can claim your EAPC was built before 2016, but with no registration or recording of frame numbers (might not even be a frame number), how do you prove it? "Innocent until proven guilty" has a habit of turning it "guilty unless you can prove you qualify for the exemption".

Ruadh495 · Dec 10, 2015

shemozzle999 said:
Here is the letter from AVERE to the Commission think I it confirms your suspicions regarding twist and go throttles:

https://circabc.europa.eu/sd/a/55b5d416-aa35-4edb-9a1c-6092af7ff57a/03.c.4 2015_04_13_Letter_Avere.pdf

By "without pedal assistance" do they perhaps mean, or think they mean, scooter type vehicles which lack pedals altogether?

anotherkiwi · Dec 10, 2015

I think you are being overly pessimistic despite my having a first hand experience of British bureaucracy, indigenous and exported variety. The EU regulation is predominant (for the moment, if my reading of the news is correct...) and would always hold up in court. You could argue that the bike is conform to EU regulations so you are able to ride it in any member state.

L1e-A is different only by motor nominative power limited to 1 kW. As long as you stay with 250 W nominative you are a bicycle not a moped.

Next year when you leave the EU I will burn a candle for you...

flecc · Dec 10, 2015

anotherkiwi said:
The EU regulation is predominant (for the moment, if my reading of the news is correct...) and would always hold up in court. You could argue that the bike is conform to EU regulations so you are able to ride it in any member state.

L1e-A is different only by motor nominative power limited to 1 kW. As long as you stay with 250 W nominative you are a bicycle not a moped.

The EU law is paramount of course and we know that. But you are misunderstanding the changes taking place that we are discussing, they are EU ones.

The L1e-A Type Approval measures will apply to 250 watt pedelecs with full throttles, and they are obviously not being considered as bicycles if they have to have motor vehicle type approval. If you read the letter in the link in this post you'll see the same concern expressed, type approval required but no means provided to get it. That's a ban in any other words.
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flecc · Dec 10, 2015

Ruadh495 said:
I think we need to watch this very carefully, because it's looking to me like L1e-A is our existing EAPC.current motorcycle

That is not so with pedelecs which are specifically excluded from Motor Vehicle Type Approval. It's the full throttle pedelecs whch are subject to that type approval with effect from January 1st 2016, but the DfT says they will still be consider them as EAPCs as long as all the other factors comply witn pedelec exemption conditions.

The problem for full throttle pedelecs is that there is no known way to type approve at present, and that is our concern.
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KirstinS · Dec 10, 2015

Gents, please don't take this then wrong way..... But I've been a member and ebike enthusiast for nearly 5 years......once I had a handle on legality but I'm lost now

And for most of that time I've been Technically illegal ( ie I was 250w when uk limit was 200w vs EU 250w) not dft said they wouldn't prosecute EU legal bikes

Now I'm 250w which is now legal in line with EU but i have a throttle , so probably illegal in 2016 (ignoring grandfather rights)

So what, for newbies as much as me, is the realty ?

Am I ok with 250w and throttle if I buy in 2016

Forget the detail- I'm a just a new buyer...... What is ok ?

flecc · Dec 10, 2015

KirstinS said:
So what, for newbies as much as me, is the realty ?

Am I ok with 250w and throttle if I buy in 2016

Forget the detail- I'm a just a new buyer...... What is ok ?

An new e-bike with an independent acting throttle will not be a pedelec in law in 2016, so is a motor vehicle.

The DfT have said that they will still consider one to be an EAPC in the UK, so long as all other aspects match pedelec law.

But their proviso is, since that conflicts with mandatory EU motor vehicle type approval law, it must be type approved. The problem now is that we don't appear to have any way of doing that, so this needs resolution.

Meanwhile, in 2016 only a true pedelec will be legal.
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flecc · Dec 11, 2015

Thanks for all this Shemozzle, the L1e-A type approval situation really is a last minute shambles.

I think COLEBI meant well with their amendments and it's good that they've included provision for the S class, but stating 250 watts and 1000 watts was not a good idea. At the very least it should be clearly stated as two separate classes, but I wonder if language difficulties came into this, them meaning or rather than and.
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L1e-A testing requirements

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