Legal Pitfalls

[Bogmonster666]

Are TSDZ2s illegal? All TSDZ2 motors are rated 750W... It appears that the motors are all the same and use the same controller, with the only difference between 36V 250W, 36V 350W, 36V 500W, 48V 500W, 48V 750W being the firmware parameters on that controller.

My laypersons understanding on this point is that if the manufacturer has rated and marked the motor as 250w then you are ok. The statement all TSDZ2 motors are rated at 750w is not true.

Not that it is particularly relevant as per the legal rating, I did see that replacement internal motors for tsdz2 kits did have different versions for 250w, 500w and 750w so although I have heard many times it's just firmware, I'm still not sure.

Interestingly, the label in my tsdz2 states 48v and 250w and 'Whoosh'. I took that to understand this was a label applied by Tongseng for a variant of the motor they supply to Whoosh rather than a label Whoosh have stuck on themselves...and I believe this to be the case. The label on the whoosh kits is shown in a photo on this page: https://wooshbikes.co.uk/?tsdz2

If your tsdz2 has a label stating 500w or 750w or anything other than 250w then it is not legal for use on roads.

 

[Ocsid]

My take on this;

Should the user of a doctored e-bike, on public access areas be facing litigation for causing life altering injuries to another party, I have my suspicions being able to outsmart the intent of e-bike laws, would be something of a secondary issue in the scale of things. But, one not exactly helping to portray a cyclist as a responsible rider, an aspect that would be critical, just the opposite, an intent to ride aggressively?


Life changing civil injury claims can readily amount to cost that are also “life changing” to the guilty party.

 

[I893469365902345609348566]

My laypersons understanding on this point is that if the manufacturer has rated and marked the motor as 250w then you are ok.

They appear to be rated 250W/350W at 36V

tsdz2 tongsheng 36V 250W/350W TSDZ2 electric bicycle central mid motor torque sensor with coast/foot brake function

tsdz2 tongsheng 36V 250W/350W TSDZ2 electric bicycle central mid motor torque sensor with coast/foot brake function

www.pswpower.com

and 500W/750W at 48V

TSDZ2B tongsheng 48V 500W 350W 15A tsdz2 electric bicycle mid motor with torque sensor VLCD5 VLCD6 XH18 VLCD13 VLCD10

TSDZ2B tongsheng 48V 500W 350W 15A tsdz2 electric bicycle mid motor with torque sensor VLCD5 VLCD6 XH18 VLCD13 VLCD10

www.pswpower.com

Interestingly, the label in my tsdz2 states 48v and 250w and 'Whoosh'.

They are all exactly the same motor with the same controller, rated at 750W

I can't see TSDZ2 labels for sale which state anything other than "250W"

 

[matthewslack]

My laypersons understanding on this point is that if the manufacturer has rated and marked the motor as 250w then you are ok.

Interestingly, the label in my tsdz2 states 48v and 250w and 'Whoosh'. I took that to understand this was a label applied by Tongseng for a variant of the motor they supply to Whoosh rather than a label Whoosh have stuck on themselves...

@flecc's writings on legal questions (a) have the benefit of very long experience (b) have the tone of someone with a legal background, so I take great comfort from them.

When I get around to a conversion I will keep myself happy by staying below 25kph assisted, keeping motor parameters to no more than I have observed on my Shimano system, and never becoming the less vulnerable party in any incident.

Insurance I expect to be an issue with a conversion, so I probably won't bother with it.

The only way to true peace of mind is an off the shelf, undongled bike.

 

[I893469365902345609348566]

The only way to true peace of mind is an off the shelf, undongled bike.

There's more peace of mind with Bafangs which leave the factory engraved 250W. It seems all TSDZ2s are rated 750W and labelled by others. I'll avoid getting one, because I'd hate to get badgered by the law and insurance companies too.

 

[I893469365902345609348566]

The label on the whoosh kits is shown in a photo on this page: https://wooshbikes.co.uk/?tsdz2

Is that the manufacturer's label? It's got "WOOSH" printed on it.

 

[Bogmonster666]

Is that the manufacturer's label? It's got "WOOSH" printed on it.

Let's ask @Woosh, is the label on the Woosh kits a label applied by the manufacturer or is it a label applied by yourselves?

 

[I893469365902345609348566]

Let's ask @Woosh, is the label on the Woosh kits a label applied by the manufacturer or is it a label applied by yourselves?

It doesn't matter, all TSDZ2 motors are rated 750W.

The motor must be "RATED" at no more than 250w.

 

[Bogmonster666]

It doesn't matter, all TSDZ2 motors are rated 750W.

I am not trying to be argumentative and I genuinely want to get the correct understanding, so if my understanding is wrong, I want to be corrected, but I think it does matter. My understanding is the relevant 'rating' is what the manufacturer specifies and marks the motor up as. An engraved 250w bafang can clearly deliver more than 250w but Bafang have rated it at 250w. Obviously, if a motor leaves the factory marked up as 750w and a supplier sticks a 250w label on it then I can see that being an issue.

Tbh, I am less concerned about the 250w thing as I feel it is reasonably clear, I can see the configurable assistance speed being more open to challenge. But this clearly isn't my area of knowledge. I suspect this really comes down to is the assistance speed setting a config setting or a rider setting, this was my original doubt?

 

[Woosh]

Let's ask @Woosh, is the label on the Woosh kits a label applied by the manufacturer or is it a label applied by yourselves?

It's a tongsheng label.
I asked them to make for me a 48V 250W TSDZ2 with clear labelling.
I asked Bafang the same, make for me a BBS01B 48V 250W with clear labelling. Bafang label is more cryptic but clear enough.
They supplied it like it is. It's a lot simpler that way, everyone concerned knows where they stand legally.

 

[I893469365902345609348566]

It's a tongsheng label.
I asked them to make for me a 48V 250W TSDZ2 with clear labelling.
I asked Bafang the same, make for me a BBS01B 48V 250W with clear labelling. Bafang label is more cryptic but clear enough.
They supplied it like it is. It's a lot simpler that way, everyone concerned knows where they stand legally.

Aren't "Ratings" and "Labels" two different things? There's no mention of the importance of labels over ratings in any of the legislation I've ever seen, and TSDZ2s are all exactly the same containing the same controllers and rated 750W, simply programmed differently. It's curious to me why everyone piles in pointing fingers at the illegality of other motors rated higher than 250W, but endless threads about the UK illegal TSDZ2s are tolerated here, which seems against forum rules.

BTW if anyone wants to gift me their illegal TSDZ2, PM me for my address

 

[flecc]

It doesn't matter, all TSDZ2 motors are rated 750W.

But technical standard EN15194, Type Approval Exemption law and Pedelec law all only apply to complete pedelecs, so what a motor only maker says they are has no prescribed legal meaning.

If Woosh are nominating the specification of pedelecs made to their order, they are not just a retailer but arguably the manufacturer**. Thus they are able to specify the rating.

** There are examples in the motor industry. Vauxhall, Nissan, Suzuki and others have all marketed small car models entirely designed and manufactured in India. Simply having the single change of their brand logo on the car means they are the legal manufacturer.
.

 

[soundwave]

Derestriction, ‘off-road’ switches or modes and dongles

The Department of Transport say that electric bikes fitted with off-road switches or modes, that enable a bike’s motor to continue assisting to speeds beyond 15.5mph, do not comply with UK EAPC law. The term ‘off-road’ suggests that these bikes can be ridden on parkland, forests or other places away from main roads, which isn’t accurate. E-bikes with increased motor power (continuous rated power above 250w) or increased speed (with motor assistance not cutting out at 15.5mph) cannot be used legally as bicycles anywhere on land accessible by the public; when riding on private land you would need permission from the landowner.

if you have a controller you can adjust and not be totally locked out so you cant change anything it is not road legal simple as that.

the fact that you can change anything means is does not comply with uk law and if they went after this in a court of law will mean you will loose.

if i remove my dongle i can not change anything in the controller because it is a locked system.

so if i rip out my bosch controller and fit a phase runner and set it to 15mph it still wont be road legal because i have fitted a controller i can programme my self and i promise i wont be a bad boy and put a sticker on it.

 

[I893469365902345609348566]

But technical standard EN15194, Type Approval Exemption law and Pedelec law all only apply to complete pedelecs, so what a motor only maker says they are has no prescribed legal meaning.

Are you saying that a "dinner plate" 1500W hub motored bicycle is completely legal if it's limited to 250W by the controller, if bought as a complete unit?

 

[soundwave]

Are you saying that a "dinner plate" 1500W hub motored bicycle is completely legal if it's limited to 250W by the controller, if bought as a complete unit?

yes if the controller is locked out at 15mph and no way for the end user to change the speed or power limits.

a bosch controller is 20a and 250w wont get you up any hill under the 15mph limit a motor can use any amount of power under this speed.

 

[Bogmonster666]

The Department of Transport say that electric bikes fitted with off-road switches or modes, that enable a bike’s motor to continue assisting to speeds beyond 15.5mph

This is the crux of my question. Is there a difference between 'mode or switch' and a 'setup configuration parameter'? @soundwave would appear to think not, I would be interested in @flecc 's view.

Edit: and maybe @flecc has just answered it in a reply to another post 'and the limiting is not easily changed while riding'..of course his post was regarding a complete bike but I think we have already established kits are overlooked if they observe the same restrictions?

 

[flecc]

Are you saying that a "dinner plate" 1500W hub motored bicycle is completely legal if it's limited to 250W by the controller, if bought as a complete unit?

If a complete pedelec branded by the supplier as of their manufacture in law, and the limiting is not easily changed while riding, yes, entirely legal if compliant with all the other requirements of the law. It is a 250 watt machine.
.

 

[soundwave]

there was a few company's that made kits that was impossible to change the speed limits in the controllers but they all went bust.

 

[flecc]

This is the crux of my question. Is there a difference between 'mode or switch' and a 'setup configuration parameter'? @soundwave would appear to think not, I would be interested in @flecc 's view.

All that matters is being legally configured as supplied and not having a handy switch to boost power while out on the road.

What Soundwave means is that you cannot change anything and remain legal, but he is wrong in this statement:

"the fact that you can change anything means is does not comply with uk law and if they went after this in a court of law will mean you will loose."

That is simpy not true. You only break the law if you actually make the change or if the pedelec is fitted with an on-road simple switch that breaches legal use.
.

 

[I893469365902345609348566]

there was a few company's that made kits that was impossible to change the speed limits in the controllers but they all went bust.

The wheel size on your bike's display can be changed by a Bosch dealer, for faster speed.