News - DfT: Pedal cycles converted to ‘twist and go’ exempt from type approval

trex

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May 15, 2011
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why then post purchase modifications of the push bike are any different from those of a legal EAPC?
 

shemozzle999

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The Department for Transport has today confirmed to Pedelecs that an ordinary cycle, already ridden on public roads as such and subsequently converted to a ‘twist and go’ electric bike, will not require type approval.

The DfT further clarified that type approval ‘only applies to new vehicles, not converted ones’.

The latest guidance on conversions follows on from news that electric bikes manufactured as a ‘twist and go’ from January 2016 will require type approval.

Their response reiterates that ‘twist and go’ type approval requirements are directed at the manufacturers, meaning that ‘riders making conversions are not committing an offence’ (with regard to type approval requirements).

It is also our understanding that, since not all cyclists are technically proficient in fitting conversion kits to a bike, that conversion can also be carried out by a business, so long as the bike in question has been ridden on public roads before conversion (i.e. the bike is not considered ‘new’).

Full story:
http://www.pedelecs.co.uk/news/dft-pedal-cycles-converted-twist-go-exempt-type-approval/

Hi Helen,

Thank you again for your continuing effort.

I wonder if you could confirm a couple of points.

1.Did the DfT email contain any disclaimer.

2. Regarding home builds would the DfT accept the home builders name for the purposes of the manufacturers information that has to be placed on the EAPC name plate.
 
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flecc

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Oct 25, 2006
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why then post purchase modifications of the push bike are any different from those of a legal EAPC?
That's because the manufactured EAPC only escaped being type approved as a motor vehicle because it fully complied with the 168/2013 exemption (h).

Post conversion into non-compliance nullifies the exemption and would be seen as a deliberate attempt to avoid the law.

Since a converted bicycle is not subject to type approval and there is no law saying it has to be SVA'd, it avoids breaching any exemption. It's just fallen though a hole in the law and only has to comply with the UK's EAPC usage laws, the limits on assist speed and power.
.
 

trex

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May 15, 2011
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I understood your previous explanation. My understanding is that there is no law or regulation against the individual who connects a twist and go throttle or derestricts a starting aid throttle. If the importer did this, he/she would need to put that bike through MSVA and pay £55 fee.
But if the purchaser does this, does he/she have to put the bike through MSVA and pay £55?
 

flecc

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Oct 25, 2006
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But if the purchaser does this, does he/she have to put the bike through MSVA and pay £55?
For a manufactured pedelec I would say yes, since it only gained approval for road use without type approval by compliance with the the exemption.

So post fitting a throttle is avoidance unless SVA is sought to approve it.
.
 

craiggor

Esteemed Pedelecer
Jan 9, 2015
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Hi Helen,

Thank you again for your continuing effort.

I wonder if you could confirm a couple of points.

1.Did the DfT email contain any disclaimer.

2. Regarding home builds would the DfT accept the home builders name for the purposes of the manufacturers information that has to be placed on the EPAC name plate.
No rude words,the guy who tried to register his trike made from truck components was told big ******* was not allowed.Do we have a name for this new class ?
 

craiggor

Esteemed Pedelecer
Jan 9, 2015
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To rude for pedelecs too.The sex pistols proved in court ******* is not a swear word.just a rude word .

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craiggor

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Jan 9, 2015
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It's not seen as a new class, the DfT say that throttle pedelecs are still considered to be EAPCs, i.e. pedelecs.
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So when a EAPC needs a daytime light so will a homebuild.

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trex

Esteemed Pedelecer
May 15, 2011
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As you may well know, suppliers cannot yet get type approval at the moment. Suppose 6 months from now, quite a few manufactured bikes will be type approved with twist and go throttle.
If the purchasers of the same bike, but bought pre-TA, buy a throttle on ebay and fit it themselves, do they have to get MSVA and pay £55 each? Same question if the throttle comes from the supplier of the TAed bike.
 

flecc

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Oct 25, 2006
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So when a EAPC needs a daytime light so will a homebuild.
No, because it's not a usage law as far as I can see, it's a law applying to manufactured pedelecs as supplied. It was originally only a German law and applied there to all bicycles.

I've extracted this part from a translation of German law:

Equipment on Bicycles sold as new, each bicycle must provide the following equipment:
  1. Lighting: Non-blinking front headlamp to illuminate the road of white or pale yellow color. A red rear taillight that stays lit when stationary.
  2. Reflectors: front with a white with a red rear reflectors that may be connected to the lights and/or connected to the pedals. At least two yellow reflectors on each wheel.
  3. In daylight and good visibility bicycles may be used without lights.
  4. Racing bike exceptions: Racing bikes are not required to meet the above rules. However, if riding at night, all bikes, including racing bikes are required to have lights and reflectors.
  5. A Racing bike is defined as less than 12 kg, with drop handlebars, a rim diameter at least 630 mm diameter, and a rim width not more than 23 mm. Mountain bikes are not road bikes so are exempted from certain requirements (unless ridden at night on the roads).
Note, when sold as new, that German law does not apply in the UK of course.

It seems like our bicycle bell law in some ways. Although widely ignored, every new bicycle sold must have a bell supplied with it, but it doesn't have to be fitted or used when on the road. That bell law isn't for usage, only for supply, and the Highway Code confirms that.
.
 
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flecc

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Oct 25, 2006
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As you may well know, suppliers cannot yet get type approval at the moment. Suppose 6 months from now, quite a few manufactured bikes will be type approved with twist and go throttle.
If the purchasers of the same bike, but bought pre-TA, buy a throttle on ebay and fit it themselves, do they have to get MSVA and pay £55 each? Same question if the throttle comes from the supplier of the TAed bike.
I would think a strict interpretation is that if a third party throttle is used, SVA would be necessary since the part is not what has been type approved.

If the original part that the maker used on type approved models is used, no, since it complies with the type approval specification.
.
 

craiggor

Esteemed Pedelecer
Jan 9, 2015
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I would think a strict interpretation is that if a third party throttle is used, SVA would be necessary since the part is not what has been type approved.

If the original part that the maker used on type approved models is used, no, since it complies with the type approval specification.
.
So if your shop bought EAPC breaks and you decided to get a different motor,controller or battery you would need MSVA ?

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trex

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May 15, 2011
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So if your shop bought EAPC breaks and you decided to get a different motor,controller or battery you would need MSVA ?

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if only you have a twist and go throttle.
 
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anotherkiwi

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Jan 26, 2015
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I think daytime running lights are very useful (helps motorists to think twice before refusing priority...) and will be fitting them before the winter. DIY bikes get 5% less tolerance in maximum speed - 5% instead of 10%.

The Germans are pushing forward a condition that most parts must be OEM when you change them on a bike. The Dutch seem to be behind it too. They go so far as to say you have to remount the same tyres...
 

craiggor

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Jan 9, 2015
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This does not make any sense.The hombuild rules needed clearing up this has done that sort of.But why a shop bought EAPC can't have one is beyond me.

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flecc

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Oct 25, 2006
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So if your shop bought EAPC breaks and you decided to get a different motor,controller or battery you would need MSVA ?
Technically yes, but this strict interpretation on requiring genuine original replacement parts is widely ignored. It's mainly in cars etc when accidents occur that involve the failure of non-standard parts that it can get serious.
.
 

flecc

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Oct 25, 2006
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The Germans are pushing forward a condition that most parts must be OEM when you change them on a bike. The Dutch seem to be behind it too. They go so far as to say you have to remount the same tyres...
Hmm.... EU protectionism at its very worst.
It's just extending what has always applied to motor vehicles, only OEM parts should be used. But that's been widely ignored so the same will happen with pedelecs.
.
 

trex

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May 15, 2011
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by admitting that home build with twist and go is legal, I think the DfT won't be able to punish anyone using a twist and go throttle on a shop bought bike.