Twist and Go 15.5mph DIY Ebikes are legal

[RollingChunder]

From Government website that we've all seen before:

An EAPC must have pedals that can be used to propel it.
It must show either:

• the power output
• the manufacturer of the motor

It must also show either:

• the battery’s voltage
• the maximum speed of the bike

Its electric motor:

• must have a maximum power output of 250 watts
• should not be able to propel the bike when it’s travelling more than 15.5mph

At the bottom of the page there is this exclusion:

An electric bike must be type approved if either:

• it can be propelled without pedalling (a ‘twist and go’ EAPC)
• it does not meet the EAPC rules

This should have been done by the manufacturer or importer before you bought it. If it’s been type approved, it will have a plate showing its type approval number.

The last line is key, it only refers to bikes sold by a manufacturer or importer. The Department for Transport was contacted to clarify the position for DIY conversions and their response can be found on this forum and many other places online. DfT: Pedal cycles converted to ‘twist and go’ exempt from type approval – Pedelecs – Electric Bike Community | Pedelecs - Electric Bike Community

An extract:

Therefore if you convert a pedal cycle which has already been ridden on the road to “twist and go” operation, it does not become subject to type approval.

They also confirm type approval only applies to manufacturers.

Therefore, a fully functional throttle up to 15.5mph (without pedalling) is legal as long as the conversion meets the three main points on the government website.

Maybe many of those Deliveroo riders are legal after all. This is my understanding of it, I welcome any opinions if I've missed something.

 

[flecc]

They also confirm type approval only applies to manufacturers.

Therefore, a fully functional throttle up to 15.5mph (without pedalling) is legal as long as the conversion meets the three main points on the government website.

Maybe many of those Deliveroo riders are legal after all. This is my understanding of it, I welcome any opinions if I've missed something.

Correct, but unfortunately many of the Deliveroo and other fast food deliverers go further with excess wattage rating motors and or higher assist speeds.

Not a problem in my London area, they all seem to riding registered i.c. mopeds with L plates where necessary, with not a pedelec in sight.
.

 

[lenny]

A Cardiff Council spokesperson said: “Any electric bike that exceeds 15.5mph or has a throttle on the bike is classed as a motorcycle and not a bicycle.
On the 17 bikes which were seized by the police, the council spokesperson added: “All the vehicles had a throttle

Council and police crack down on illegal e-bikes riding through city centre

A NUMBER of illegal e-bikes were seized in a joint police-council operation - and the majority had defective brakes.

www.southwalesargus.co.uk

 

[RollingChunder]

A Cardiff Council spokesperson said: “Any electric bike that exceeds 15.5mph or has a throttle on the bike is classed as a motorcycle and not a bicycle.
On the 17 bikes which were seized by the police, the council spokesperson added: “All the vehicles had a throttle

Council and police crack down on illegal e-bikes riding through city centre

A NUMBER of illegal e-bikes were seized in a joint police-council operation - and the majority had defective brakes.

www.southwalesargus.co.uk

Yes it does seem many people in society assume throttle=illegal including police and councils. It would be interesting to see how local plod would react to the DfT letter at the roadside.

 

[flecc]

Yes it does seem many people in society assume throttle=illegal including police and councils. It would be interesting to see how local plod would react to the DfT letter at the roadside.

The police and councils are not necessarily wrong. Although I and and the DfT have said you are correct, that is only according to common current practice. It's strictly speaking not true in either British or EU law. Technically only those kit created machines certified as EAPCs qualify, as I've explained in my treatise on pedelec law:

"Kit Motors
Be aware that hardly any of the above applies to kits or any home construction, the regulations only being for manufactured pedelecs. So both individuals and suppliers operate in a legal vacuum in which all try to supply and/or use as closely conforming to the complete e-bike law as they can, trusting that is acceptable. That has always worked throughout all of Europe and the UK without any mention of a possible prosecution, providing the three main points of the law are adhered to, i.e. 250 watts maximum assist, 15.5 mph maximum assist speed and power only when pedalling.

However, I can tell you the legal way of dealing with a kit, athough almost no-one has ever done it:

1) Buy and fit the motor kit.
2) Make an appointment at an approved vehicle testing station, paying the £55 test fee.
3) Most often the purpose of this is to get an SVA (Single Vehicle Approval), entitling it for use as a type approved motor vehicle. However your intention will be to get the inspector to agree that it meets the pedelec requirements so is exempt from being a motor vehicle and is approved as a pedelec.

However, if you get and accept SVA approval as well at the same time, as specified earlier in getting legal permission, in Britain you will be able to have a fully acting throttle on a post December 2015 pedelec with it still considered a bureaucracy free pedelec, a bonus. I repeat though, no-one to my knowledge has ever done this to create a kit pedelec so it's never been necessary, but it is the DfT specified correct way when creating any motorised vehicle from more than one vehicle or from parts."
.

 

[Az.]

I want to believe twist and go throttles on converted e-bikes are legal. One of my bikes has such throttle. I find it very useful and safe, so I bookmarked letter from DfT in case of any troubles, but I have my doubts. A letter from DfT is what it is - a letter - an opinion of a single person. It might be right or not, but for definitive answer one must grind through relevant legislation.

Unfortunately one can't be looing for answers on government pages either. Hand up who still thinks UK government is competent. Is there a single person who would believe that?
They wrote:

• must have a maximum power output of 250 watts

They probably wanted to write: auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, but they wrote what they wrote.

 

[flecc]

I want to believe twist and go throttles on converted e-bikes are legal. One of my bikes has such throttle. I find it very useful and safe, so I bookmarked letter from DfT in case of any troubles, but I have my doubts. A letter from DfT is what it is - a letter - an opinion of a single person. It might be right or not, but for definitive answer one must grind through relevant legislation.

And that person's opinion is stretching the law beyond truth. Here's the true position:

The law is that only a manufactured EAPCs can be type approved to have a throttle. That is because individual machines cannot, they can only have Single Vehicle Approval, so, being individual are not a Type.

So that DfT person's opinion, like that of kit suppliers, has assumed that the whole of the independent throttle law for individually created machines does not apply.

That is very clearly completely wrong, due to the exemption conditions for a pedelc to be excused from being a motor vehicle on the roads. Note the passage in the law that I've highlighted:

"Exemption (h) pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km"

When the power does not cut off when pedalling stops, the machine is a de facto motor vehicle in EU and UK law and must be submitted either:

1) for approval as such and registered as such.

Or

2) in Britain alone, to qualify for the Wisper style throttle only, an option open to all individuals or companies.
.

 

[RollingChunder]

And that person's opinion is stretching the law beyond truth. Here's the true position:

The law is that only a manufactured EAPCs can be type approved to have a throttle. That is because individual machines cannot, they can only have Single Vehicle Approval, so, being individual are not a Type.

So that DfT person's opinion, like that of kit suppliers, has assumed that the whole of the independent throttle law for individually created machines does not apply.

That is very clearly completely wrong, due to the exemption conditions for a pedelc to be excused from being a motor vehicle on the roads. Note the passage in the law that I've highlighted:

"Exemption (h) pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and
finally cut off before the vehicle speed reaches 25 km"

When the power does not cut off when pedalling stops, the machine is a de facto motor vehicle in EU and UK law and must be submitted either:

1) for approval as such and registered as such.

Or

2) in Britain alone, to qualify for the Wisper style throttle only, an option open to all individuals or companies.
.

Sorry for the ignorance, what is a Wisper style throttle?

 

[flecc]

Sorry for the ignorance, what is a Wisper style throttle?

It's Britain only local law concession that so far only Wisper have taken advantage of:

Getting legal permission to have a fully acting "Twist and Go" throttle on a pedelec:

The Motorcycle Single Vehicle Approval test now includes a sub-category for "Twist and go" electric bikes, which require type approval as Single Vehicle Approval (SVA), but which can otherwise be used like other normal pedelecs. Fewer modifications will now be needed for these machines to pass the test and gain type approval. The MSVA test costs £55 per individual vehicle.

Each individual bike must pass the Single Vehicle Approval (MSVA**) test. This provides UK-specific type approval (i.e. it is not valid in other EU countries) and the DfT regard these as legal bureaucracy free pedelecs.

The new class for Twist & Go EAPCs is called "250W LPM", a sub-category of the standard "Low Powered Moped", which is the L1e-A category which T&G EAPCs fell into before. The new edition of the test manual reduces the requirements somewhat for this new sub-category. For example, a kickstand is still required, but it does not have to auto-retract. Moped-like mirrors are now not required, etc., etc.

** MSVA = Minister's Single Vehicle Approval.
.

 

[Nealh]

Most of the Deliveroo's I see where I live to my eyes aren't eapc or legal, most have a front or rear D/D hub and an independent twist & go throttle. The speeds of these riders is certainly not 15.5 mph.

 

[Az.]

"An EAPC must have pedals that can be used to propel it.
It must show either:

• the power output
• the manufacturer of the motor

It must also show either:

• the battery’s voltage
• the maximum speed of the bike"

This is funny. Do you guys know what is the maximum speed of your bike?
I have no idea to be honest.

There is a method to determine this value which is coming to my mind, but I am not willing to do that as it would result in serious injury or death.

 

[flecc]

"An EAPC must have pedals that can be used to propel it.
It must show either:

• the power output
• the manufacturer of the motor

It must also show either:

• the battery’s voltage
• the maximum speed of the bike

You are quoting from a government guide document which you should never do, since extracts are invariably inaccurate. In this instance it indicates a choice, but there is none.

Only the actual law is accurate and there is no choice, what should be on the plate is according to the pedelec's age.

Below is what the law says, but without the explanation for what appears to be a choice:

“(a) it is—
(i) fitted with a plate securely fixed in a conspicuous and readily accessible position showing—

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

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

(cc) the continuous rated output (as defined in the 1971 British Standard) of
the motor of the vehicle;

OR

(ii) visibly and durably marked with—

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

(bb) the maximum speed at which the motor can propel the vehicle specified in miles per hour or kilometres per hour, and

(cc) the maximum continuous rated power (as defined in the Electrically Assisted Pedal Cycles Regulations 1983)(d) of the motor of the vehiclespecified in watts or kilowatts;”

That is the actual wording of the law, very different.

Below is a much better simplification of it:

"As part of the GB EAPC amending legislation, that will come into force on 6 April 2015, the requirement for the marking identification has been amended. Previously a plate showing the manufacturer, maximum continuous rated power output and voltage was necessary, from April 6 2015 the requirement will be that the manufacturer, maximum continuous rated output and maximum assisted cutoff speed shall be marked on the cycle."

So what is on the plate is according to when the pedelec was made.
.

 

[Az.]

You are quoting from a government guide document which you should never do, since extracts are invariably inaccurate.

Well... I humbly disagree. Governments web sites should be the first choice for citizens to look for reliable and precise guidelines. Unfortunately quality and reliability of government web sites is very low, which I was pointing out.

 

[flecc]

Well... I humbly disagree. Governments web sites should be the first choice for citizens to look for reliable and precise guidelines. Unfortunately quality and reliability of government web sites is very low, which I was pointing out.

Whilst your sentiment is on their accuracy is often true, that guideline is not for your action, since there is no law for self created pedelecs. Both kit suppliers and those who create self build pedelecs operate in a legal vacuum, trying to do their best to fit in with the law. That guide is just a rough guide of what the labelling on your manufactured pedelec means. Creating a plate for a self build pedelec is rather like faking a VIN number for a kit built car, which of course is also illegal. The new VIN number has to be supplied by the DVLA.

By quoting from that guideline you inadvertantly mislead others and that is my objection. I've worked hard in here to ensure people do get accurate knowledge of the complexities of pedelec law, only to have them then get confused by inaccurate posting.

In this instance you obviously didn't have sufficient knowledge of this aspect of the law to point out what you did.

Pedelec Law, the details
.

 

[Az.]

By quoting from that guideline you inadvertantly mislead others and that is my objection.

Wow wow... hold on a minute... I quoted first post and highlighted fragment which I find funny. How is that misleading? It is not me who is creating guidelines on official sites.

 

[saneagle]

This is funny. Do you guys know what is the maximum speed of your bike?
I have no idea to be honest.

There is a method to determine this value which is coming to my mind, but I am not willing to do that as it would result in serious injury or death.

It's about 140 mph.

Easiest way to test it is to fit a GPS with data recording. Some cheap phones will do that to record the max speed. Wrap the GPS device in some foam rubber just to be sure, then chuck the bike off Beachy Head. It might be best to do it at low tide and make sure that you can collect the wreck before the tide comes back in. The guys that jump off there normally reach about 120 mph, but I think a bike might have a bit less resistance. That's how I estimate 140 mph.

In case you haven't figured it out, it's the bike's speed, not yours, so you don't have to be on it when it goes over the edge unless you want to.

 

[Az.]

Easiest way to test it is to fit a GPS with data recording. Some cheap phones will do that to record the max speed. Wrap the GPS device in some foam rubber just to be sure, then chuck the bike off Beachy Head.

To calculate speed of a falling object you don't need GPS. Pen and paper is enough.

I was thinking about steep hill, backpack and panniers filled with sand and down you go. Maximum speed would be a little less than speed recorded just before fatal crash.

 

[saneagle]

To calculate speed of a falling object you don't need GPS. Pen and paper is enough.

I was thinking about steep hill, backpack and panniers filled with sand and down you go. Maximum speed would be a little less than speed recorded just before fatal crash.

That reminds me of when I started my engineering degree at Glasgow University. The class tutor wanted a heads-up on who had the most potential as an engineer, so he set a task to test us. He gave everybody a barometer and told us for our homework we had to use the barometer to find out the height of the new 10 storey library building.

Most of the class measured the pressure at the top and bottom and calculated the height. None were anywhere near the actual height.

A couple of clever guys chucked theirs off and timed the drop to the ground. They got a bit closer but still a bit off.

I got the exact height. The Tutor asked me what method i used. I said, "I used the KISS technique. My method was a bit easier than what everybody else did. I found out who the architect was and told him that I'd give him a bloody good barometer if he told me the height"

 

[AndyBike]

Not a problem in my London area, they all seem to riding registered i.c. mopeds with L plates where necessary, with not a pedelec in sight.

Not surprising really. When they start off its going to be a case of you already have the moped, or you're saving up for one. Big investment. So they probably start off with a cheap import Ebike, up the battery pack to a 2nd, then as time progresses save up and get the better kit.

These delivery guys have really been the lifeblood of the city over the last 3 years, especially during and post pandemic.

It's just a shame none of them know wtf the highway code is lol.

 

[flecc]

Wow wow... hold on a minute... I quoted first post and highlighted fragment which I find funny. How is that misleading? It is not me who is creating guidelines on official sites.

I've told you why. You have interpreted that guide section you believe is funny as a choice. It isn't, there is no choice. I've further explained to BonzoBanana who also misinterpreted what that document is, so you may prefer that brief explanation on this link
.