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

[flecc]

The legislation I have read on here says 15.5mph,250w and weight limit removed.No mention of a plate just the bike needs to be marked.And Twist and go got changed to needing type approval.

There's no confusion. The law does include that the plate has to be fitted to all EAPCs.

Only new manufactured EAPCs have to be type approved, and the approval excludes them having a throttle. A conversion cannot be type approved and there is no need for a single vehicle approval. That means it can have a throttle, since no law says it can't.

That's the crucial difference that enables this advice from the DfT.
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[craiggor]

There's no confusion. The law does include that the plate has to be fitted to all EAPCs.

Only new manufactured EAPCs have to be type approved, and the approval excludes them having a throttle. A conversion cannot be type approved and there is no need for a single vehicle approval. That means it can have a throttle, since no law says it can't.

That's the crucial difference that enables this advice from the DfT.
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Read my post again .I said they debated and agreed on twist and go and a plate.I went on to say what happens next.Because the legislation said mark not plate and Twist and go needs to be type approved. I know a converted bicycle does not need to be type approved .I was just asking what happened in bettweeen the debate and the legislation ?

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[flecc]

Read my post again .I said they debated and agreed on twist and go and a plate.I went on to say what happens next.Because the legislation said mark not plate and Twist and go needs to be type approved. I know a converted bicycle does not need to be type approved .I was just asking what happened in bettweeen the debate and the legislation ?

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I did read your post and found it difficult to understand. It doesn't matter what language they used in the discussion, much of which was very informal and jokey anyway.

It's the law that counts and that doesn't mention "mark". In the original 1983 law it refers to plate, and in the 2015 amendments it still says plate, so nothing happened in between in that respect.

The law clearly says what should be on the plate and as I pointed out for you earlier, how the plate should be mounted, so I just don't know why these queries.
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[craiggor]

The main point of my post was they debated and agreed on twist and go. My question was what happened between the debate and the legislation ? I will have to read the legislation again I was sure I read mark.Do all shop bikes have plates ? I 'm sure I have seen some with stickers.

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[flecc]

The main point of my post was they debated and agreed on twist and go. My question was what happened between the debate and the legislation ? I will have to read the legislation again I was sure I read mark.Do all shop bikes have plates ? I 'm sure I have seen some with stickers.

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This where you saw marked in a guidance sheet on the law. It referred to manufactured bikes constructed to current EU legislation, presumably marked as part of the manufactured finish. Our conversions fit the second case needing a plate added:

The vehicle must be:

either marked with the following information

the manufacturer;

the maximum speed at which the motor can propel the vehicle in m.p.h. or km/h;

the maximum continuous rated power of the motor.
(This mainly covers vehicles constructed to current European standards and legislation).

or

fitted with a plate showing:

the manufacturer;

the nominal voltage of the battery;

the maximum continuous rated output of the motor

(This mainly covers vehicles in use prior to April 2015).

The reason for this wording is that at the time of the discussion, conversions hadn't been contemplated. Now conversions are possible, clearly they'll need the plate to comply with the law.

Very few e-bikes ever complied with the original plate law, and I don't know one that ever had the correct information.
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[craiggor]

This where you saw marked in a guidance sheet on the law. It referred to manufatured bikes constructed to current EU legislation, presumably marked as part of the manufactured finish. Our conversions fit the second case needing a plate added:

The vehicle must be:

either marked with the following information

the manufacturer;

the maximum speed at which the motor can propel the vehicle in m.p.h. or km/h;

the maximum continuous rated power of the motor.
(This mainly covers vehicles constructed to current European standards and legislation).

or

fitted with a plate showing:

the manufacturer;
•
the nominal voltage of the battery;
•
the maximum continuous rated output of the motor
(This mainly covers vehicles in use prior to April 2015).

The reason for this wording is that at the time of the discussion, conversions hadn't been contemplated. Now conversions are possible, clearly they'll need the plate to comply with the law.
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Sorted,plate for homebuild,sticker for mass produced.My main point was they debated and agreed on Twist and go for EAPC,but in the legislation T&G needs approval. What happened in between the debate and the legislation ? Is it that they could not or did not want to overrule EU law ?

 

[flecc]

What happened in between the debate and the legislation ? Is it that they could not or did not want to overrule EU law ?

Yes, they cannot overrule the EU law, and were to some extent bound by the fact that the 1983 law is still in force, just amended to fit the current EU law.

These official group discussions are all very well, but it's only when back in the office that the details can be looked into in depth and the conflicts and problems dealt with to try to fit with the discussion.
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[craiggor]

This where you saw marked in a guidance sheet on the law. It referred to manufactured bikes constructed to current EU legislation, presumably marked as part of the manufactured finish. Our conversions fit the second case needing a plate added:

The vehicle must be:

either marked with the following information

the manufacturer;

the maximum speed at which the motor can propel the vehicle in m.p.h. or km/h;

the maximum continuous rated power of the motor.
(This mainly covers vehicles constructed to current European standards and legislation).

or

fitted with a plate showing:

the manufacturer;

the nominal voltage of the battery;

the maximum continuous rated output of the motor

(This mainly covers vehicles in use prior to April 2015).

The reason for this wording is that at the time of the discussion, conversions hadn't been contemplated. Now conversions are possible, clearly they'll need the plate to comply with the law.

Very few e-bikes ever complied with the original plate law, and I don't know one that ever had the correct information.
.

Just re read this and due to it saying mainly and or,I would say either mark or plate is acceptable for shop bought or homebuilt.Gov.UK says must display.

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[flecc]

Just re read this and due to it saying mainly and or,I would say either mark or plate is acceptable for shop bought or homebuilt.Gov.UK says must display.

That's the trouble with these informal documents on guidance etc, they are often loosely worded or even incomplete. I only take notice of the actual legislation.

To enlarge on my previous answer, as far as the DfT were concerned, the discussion agreement for Twist and Go was an agreement that the DfT would treat type approved T & Gs as EAPCs and not as motor vehicles needing registration.

I doubt the DfT would have wanted to go into the complex nitty gritty of the EU's type approval conditions with the committee.
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[shemozzle999]

flecc, applying your logic:

If the manufacturers removed the battery and the name plate from their imported EAPC they could sell it as a pedal cycle as it does not have any means of assist.

The consumer can then buy or have fitted a conversion kit to bring it inline with what the DfT has proposed acceptable, how it is plated is a matter for the DfT to clarify.

I believe that Pedelecs has approached the DfT for an explanation of the plating requirement.
(Admin note: yes I have emailed, waiting for a reply - as part of the question if a conversion is therefore a completely new type of 'vehicle' which I think it is, or legally recognised as an EAPC & therefore plate question)

 

[craiggor]

I like this,but isn't it some form of ringing.I can't scratch the frame number and take the vin plate off my MZ and say its something else.

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[flecc]

flecc, applying your logic:

If the manufacturers removed the battery and the name plate from their imported EAPC they could sell it as a pedal cycle as it does not have any means of assist.

The consumer can then buy or have fitted a conversion kit to bring it inline with what the DfT has proposed acceptable, how it is plated is a matter for the DfT to clarify.

True, but it's an obvious attempt to circumvent the law which I think would be very foolish. The DfT have used the expression "normal bicycle" in their discussions on conversion.

I think even discussing this is unwise, it only needs the moped interests to get wind of this back door method to have new throttle EAPCs for them to complain and prompt the EU to close the loophole the DfT are using.
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[shemozzle999]

True, but it's an obvious attempt to circumvent the law which I think would be very foolish. The DfT have used the expression "normal bicycle" in their discussions on conversion.

I think even discussing this is unwise, it only needs the moped interests to get wind of this back door method to have new throttle EAPCs for them to complain and prompt the EU to close the loophole the DfT are using.
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What is a normal pedal cycle? I believe it is a cycle capable of being ridden by human pedal power alone.

I personally would welcome input from the MCIA on this open and transparent discussion.

I would like to hear what possible objections they might have.

 

[flecc]

What is a normal pedal cycle? I believe it is a cycle capable of being ridden by human pedal power alone.

I personally would welcome input from the MCIA on this open and transparent discussion.

I would like to hear what possible objections they might have.

The spirit of the DfT provision for conversions is very clear and doesn't provide for such dodges to circumvent both the law and what they've said. We all know what "normal bicycle" means.

Adding to my previous answer, we've got what we wanted as shown below:

Conversions of existing normal bicycles into legal EAPCs will not have to have official approval, even with throttles. That's now.

New EAPCs with throttles will need type approval, but that is done by maker or supplier. Therefore there is no discrimination, since anyone will be able to go to a supplier and buy a throttle EAPC in exactly the same way as buying a pedelec only EAPC. We just have to be a little patient since there is a delay to allow the necessary Type Approval class to be provided.

Therefore we should be satisfied and not look for dodges to circumvent the law on new EAPCs pending the new type approval class.

Attracting attention to such dodges risks the EU closing the loophole by adding an SVA class for bicycle conversions to pedelecs. That could mean all individual conversions, even those without throttles, would have to be submitted for Single Vehicle Approval.

Is it worth that risk in an attempt to avoid another year of patience? After all, we've lived for almost 13 years since November 10th 2003 without any permission for throttles on new pedelecs, so what's another year or so?
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[anotherkiwi]

This has pedals (violet ones!) but can not be pedalled anywhere. I have seen people try. The pedals are just there to conform with the law of the time, they aren't even used to start the motor except in case of a flat battery. OK so I guess used quite often to start the motor...

 

[flecc]

This has pedals (violet ones!) but can not be pedalled anywhere. I have seen people try. The pedals are just there to conform with the law of the time, they aren't even used to start the motor except in case of a flat battery. OK so I guess used quite often to start the motor...

View attachment 14371

It's what used to be called an Autocycle long ago, like the one below. They were pedal to start the 98cc engine but nearly impossible to pedal for more than a very few yards, due to the weight and drag:

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[shemozzle999]

The efforts of the DfT are commendable they just have to make the final step to allow the various suggestions aired regarding manufactured pedal cycles and they would have fully justified their impact assessment statement of having complied with Human rights.

That would only leave exemption (2h) outside compliance and that would be a matter for the EU to correct.

 

[flecc]

they just have to make the final step to allow the various suggestions aired regarding manufactured pedal cycles and they would have fully justified their impact assessment statement of having complied with Human rights.

But won't this be irrelevant when the type approval for EAPCs is in place? Then there will be no breach of rights, since all will be able to buy both throttle and pedelec EAPCs for identical bureacracy free use.

Pending that new type approval law, anyone can create or have created a legal new EAPC with throttle by buying a normal bike to start with. As we know, the variety, price and quality of commercial offerings are easily matched or bettered by conversions.

So in practice there isn't even any material breach of rights now.
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[craiggor]

It's what used to be called an Autocycle long ago, like the one below. They were pedal to start the 98cc engine but nearly impossible to pedal for more than a very few yards, due to the weight and drag:

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Going off topic but I like this derny.

 

[trex]

what are they (the VCA people) going to test for to TA an EAPC?