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

mike killay

Esteemed Pedelecer
Feb 17, 2011
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Seems to me that the Civil Service were embarrassed by their inability to simply permit throttles.
All the issues re the disabled, the handicapped, the war wounded soldiers were obviously a pressure point, together with that Minister inferring that throttles will be kept.
My guess is that they want to put this to bed now and forget about it. This vague compromise will do nicely.
 
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flecc

Member
Oct 25, 2006
53,216
30,617
Seems to me that the Civil Service were embarrassed by their inability to simply permit throttles.
All the issues re the disabled, the handicapped, the war wounded soldiers were obviously a pressure point, together with that Minister inferring that throttles will be kept.
My guess is that they want to put this to bed now and forget about it. This vague compromise will do nicely.
This has been true since the consultation in 2011, when the January 2012 report on that revealed the strength of desire for throttles on UK pedelecs. But the DfT knew then that the requirement for harmonisation with the EU regulations made that impossible for new pedelecs.

It still is of course, the fudge of type approval for new ones with full throttles makes them motor vehicles in the mainland EU, so the UK fudge only works here. We can't take to the ferry with those e-bikes.
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shemozzle999

Esteemed Pedelecer
Sep 28, 2009
2,826
686
Yes shemozzle,a EAPCC or EAPCHB.I would say its the EAPC letters that need to be omited.I think i will follow what it says on Gov.UK.a EAPC needs power output or name of manufacture of motor, and the battery voltage or max speed.And leave out the letters EAPC.Is it in the legislation that pedelecs need the letters EAPC ?

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Your suggestion of use of EAPCC or EAPCHB for the description of manufacturer on the label would be quickly identifiable by Police and Trading Standards for monitoring purposes.
 

craiggor

Esteemed Pedelecer
Jan 9, 2015
498
171
I'm thinking HBEAPC has more of a ring to it now.I got followed in to Morrison's car park by a PCO on a mountain bike.He was locking up next to me.I said have they not bought you one of these yet,I saw 3 in the local bike shop with police markings.He said no,eyed up my bike and asked are they any good.He knew nothing about the law.

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flecc

Member
Oct 25, 2006
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Is it in the legislation that pedelecs need the letters EAPC ?
Not on the label, but our legal e-bikes are EAPCs and since 1983 always have been in the UK. Our domestic laws don't recognise the term pedelec, it's a European expression.
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craiggor

Esteemed Pedelecer
Jan 9, 2015
498
171
Not on the label, but our legal e-bikes are EAPCs and since 1983 always have been in the UK. Our domestic laws don't recognise the term pedelec, it's a European expression.
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So would you say mark up as on gov.UK leaving the EAPC off ? I just used the word pedelec because a EAPC is PAS.
 

flecc

Member
Oct 25, 2006
53,216
30,617
So would you say mark up as on gov.UK leaving the EAPC off ? I just used the word pedelec because a EAPC is PAS.
I'd say EAPC is ok, since the DfT have clearly stated that they will consider an e-bike with a throttle which otherwise accords with the law to be an EAPC.
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craiggor

Esteemed Pedelecer
Jan 9, 2015
498
171
I'd say EAPC is ok, since the DfT have clearly stated that they will consider an e-bike with a throttle which otherwise accords with the law to be an EAPC.
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But by law it doesn't need the letters EAPC on the label ?

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trex

Esteemed Pedelecer
May 15, 2011
7,703
2,671
...
We can't take to the ferry with those e-bikes.
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do you mean we can't take home build bikes with throttle or shop bought bikes with throttle?
People have been taken their bikes on holiday in Europe with the throttle switched off or disconnected for years without trouble with the police though.
 

flecc

Member
Oct 25, 2006
53,216
30,617
But by law it doesn't need the letters EAPC on the label ?

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No it doesn't. I think the first label option is the best for self builds:

(a) the name of the manufacturer of the vehicle,

(b) the nominal voltage of the battery (as defined in the 1971 British Standard) of the vehicle, and

(c) the continuous rated output (as defined in the1971 British Standard) of the motor of the vehicle;


since (b) is what the battery maker says it is and (c) is what the motor maker says it is, both already being correct in accordance with the law.

That just leaves the question of who is the manufacturer. I'd think that could be your name, but I would just use the motor manufacturer's name, since that is at the core of what the bike is.
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flecc

Member
Oct 25, 2006
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do you mean we can't take home build bikes with throttle or shop bought bikes with throttle?
People have been taken their bikes on holiday in Europe with the throttle switched off or disconnected for years without trouble with the police though.
I meant with throttles fully operating in the way we use them here.

Of course if disconnected there should be no problem in mainland Europe.
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mike killay

Esteemed Pedelecer
Feb 17, 2011
3,012
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Mine, complete with throttle activated has been ridden by a Belgian Police Officer, who did not seem to find anything objectionable about the throttle.
Most things have some sort of twist and go to vary the power, my electric toaster has a twist knob, the sewing machine has a foot pedal, my electric fan has a series of push buttons, the fridge, the central heating .....the list goes on.
Just why the Euros object to a throttle is not clear,.but smacks of protectionism.
 
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flecc

Member
Oct 25, 2006
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Mine, complete with throttle activated has been ridden by a Belgian Police Officer, who did not seem to find anything objectionable about the throttle.
Most things have some sort of twist and go to vary the power, my electric toaster has a twist knob, the sewing machine has a foot pedal, my electric fan has a series of push buttons, the fridge, the central heating .....the list goes on.
Just why the Euros object to a throttle is not clear,.but smacks of protectionism.
It originated from adopting the essence of Japanese pedelec law decades ago, but throttle introduction has since then always been vigorously opposed by the moped makers, claiming a safety issue involved since the riders not tested, licenced and insured. In truth they just fear loss of sales.

Of course EU pedelecs often do have throttles, just in a different form. They have switchable power levels, often four, five or more of those, so what is that but a throttle by a different means?
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craiggor

Esteemed Pedelecer
Jan 9, 2015
498
171
No it doesn't. I think the first label option is the best for self builds:

(a) the name of the manufacturer of the vehicle,

(b) the nominal voltage of the battery (as defined in the 1971 British Standard) of the vehicle, and

(c) the continuous rated output (as defined in the1971 British Standard) of the motor of the vehicle;


since (b) is what the battery maker says it is and (c) is what the notor maker says it is, both already being correct in accordance with the law.

That just leaves the question of who is the manufacturer. I'd think that could be your name, but I would just use the motor manufacturer's name, since that is at the core of what the bike is.
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Yes but I think manufacturer of motor as on gov.uk not bike.This identifies the motor.Can the name be on the motor? And battery info on the battery ? But you can mark up with as much info as you like nothing to stop that.Thinking sticker bomb the whole bike with electric bike law.
 

flecc

Member
Oct 25, 2006
53,216
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Yes but I think manufacturer of motor as on gov.uk not bike.This identifies the motor.Can the name be on the motor? And battery info on the battery ? But you can mark up with as much info as you like nothing to stop that.Thinking sticker bomb the whole bike with electric bike law.
No, the full original 1983 law that still applies specifies that the label containing the prescribed information must be on the bicycle in a clearly visible and easily read position. The rule is similar to that for tax discs when they existed, that a police officer or other official shouldn't have any difficulty accessing and reading it.

So best just stick to that exact law, on the downtube or seat tube probably best, depending on which was possible on the conversion.
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Kudoscycles

Official Trade Member
Apr 15, 2011
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www.kudoscycles.com
My understanding is that type approval is only applicable to newly manufactured items. So an e-bike coming off the production process complete with twist and go is a complete, new 'vehicle' is subject to type approval.

However an ordinary pedal cycle, which is considered 'second-hand' (by virtue of the fact that it has been ridden on the road it would seem) can then subsequently be fitted with a conversion kit that includes twist and go power delivery, because it's a conversion it isn't then subject to TA; essentially therefore getting to the point of it being a twist and go has been in two stages.
But what is the difference between an importer converting a bike to an EPAC to a bike shop converting a bike to EPAC. Most of these bikes had their pedigree in non assisted bikes.The moment that bike goes out onto the road it will be secondhand and thus the owner is free to fit a 15 mph 'twist and go' throttle,is that correct?
KudosDave
 
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trex

Esteemed Pedelecer
May 15, 2011
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I do accept flecc's explanation though. The imported bikes are essentially motorbikes benefiting from an exemption/concession. Fitting a throttle loses that concession. I ride a converted bike, so glad it does not matter.
 

flecc

Member
Oct 25, 2006
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But what is the difference between an importer converting a bike to an EPAC to a bike shop converting a bike to EPAC. Most of these bikes had their pedigree in non assisted bikes.The moment that bike goes out onto the road it will be secondhand and thus the owner is free to fit a 15 mph 'twist and go' throttle,is that correct?
KudosDave
No, that's not correct Dave. An existing pedelec from the moment it arrives here is only legal due to the exemption (h) in 168/2013.

Fitting a throttle immediately breaches the exemption, making the bike illegal with no possible path to legality with type approval not possible at present.

The loophole allowing throttles is simply that there is no law covering conversion of existing unpowered bicycles into pedelecs. Individually created pedelecs are not subject to type approval so do not come under the exemption in the type approval regulations. They do however meet the UK's EAPC requirements, so do not need SVA and can be on the road unregistered.

So it's not an acceptance of throttles, just an acceptance of self-builds which can coincidentally have throttles since no law says they can't.
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shemozzle999

Esteemed Pedelecer
Sep 28, 2009
2,826
686
No it doesn't. I think the first label option is the best for self builds:

(a) the name of the manufacturer of the vehicle,

(b) the nominal voltage of the battery (as defined in the 1971 British Standard) of the vehicle, and

(c) the continuous rated output (as defined in the1971 British Standard) of the motor of the vehicle;


since (b) is what the battery maker says it is and (c) is what the motor maker says it is, both already being correct in accordance with the law.

That just leaves the question of who is the manufacturer. I'd think that could be your name, but I would just use the motor manufacturer's name, since that is at the core of what the bike is.
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Confirmed by Claire Perry to to the Parliament Committee prior to the vote on the 2015 amendments:

"There is one more point to respond to. The twist and go classifications will be permitted up to 15.5 mph. A vehicle under that limit will be designated as an EAPC, because it is considered to be a benefit to elderly and less able people. Any twist and go vehicle that can achieve a speed above that will be classified as a moped. Also, an information plate defining what an EAPC is will be fitted on vehicles, so hopefully there will be no doubt about that"

House of Commons General Committee : Electrically Assisted Pedal Cycles (Amendment) Regulations 2015 (24 February 2015)

Note: this is law in Great Britain only, our Northern Ireland members would have to pursue there own regulatory body for an exemption.

edit: correction Claire Perry not Claire Rees as originally stated.
 
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flecc

Member
Oct 25, 2006
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Note: this is law in Great Britain only, our Northern Ireland members would have to pursue there own regulatory body for an exemption.
Yes, it's a pity that Northern Ireland is still bound by the EU type approval exemption and doesn't benefit from these GB changes.

Our Crown Protectorates such as The Isle of Man and the Channel Islands also have to make their own provisions for e-bikes since neither the GB or EU regulations apply there.
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