E-Bike Safety Standards in the European Union: An Overview

Planning to import and sell e-bikes to the European Union? In this guide, we cover the basics of product regulations, safety standards, labeling, documentation and testing requirements for electric bikes in the EU.

Mentioned Products

• Pedal-assisted electric bike
• Throttle electric bike
• Speed pedelec electric bike
• Hub motor electric bike

E-Bikes: Machinery Directive

The EU machinery directive applies to most energy-powered machinery products placed on the EU market. It sets mandatory health and safety requirements and harmonized standards. Importers shall comply with those requirements before importing to the EU.

E-bikes importers shall ensure that the product design satisfies the relevant provisions of the Machinery Directive. Further, importers shall also prepare other required documents such as technical files, quality assurance, test reports, and certifications.

EN 15194

EN 15194 has been harmonized specifically for E-bike products under the EU Machinery Directive. Most of the E-bikes safety requirements can be found in EN 15194. Here are some examples:

1. The serial number must be permanently and visibly marked on the E-bikes frame;

2. The battery of E-bikes shall comply with relevant regulations such as the EU battery directive;

3. E-bikes must bear a warning against the hazards of incorrect use;

4. E-bikes shall comply with the permissible total weight of the rider and luggage.

CE Mark

E-bikes fall into the scope of the Machinery Directive, which is a CE directive. As such, E-bikes products must be CE marked before entering the EU market.

Lab Testing

Importers must either request test reports from the supplier or book a lab testing for your E-bikes, such as pedal-assisted e-bike. Reputable testing companies such as Intertek, SGS, and TUV offer E-bikes compliance services including lab testing, conformity assessment, and product certification.

Risks

E-bikes manufactured in China, and other countries outside the EU, are not necessarily designed to comply with EN 15194. It’s therefore essential to request EN 15194 and other relevant lab test reports before buying ODM e-bikes from overseas factories. Further, you must also ensure that the e-bike is correctly labeled (e.g. serial number and CE mark). Further, the battery must also comply with all applicable EU regulations.

RoHS

RoHS regulates certain hazardous substances (e.g. heavy metals) in electronic products including E-bikes. There are many metallic parts that can be found in E-bikes, such as the battery, chainrings, sprockets, and crankset. Therefore, importers shall ensure that all parts of E-bikes contain an acceptable level of restricted substances before entering the EU market.

The restricted substances under RoHS include:

• Lead
• Mercury
• Cadmium
• Hexavalent chromium
• Bis(2-Ethylhexyl) phthalate
• Butyl benzyl phthalate
• Diisobutyl phthalate

RoHS Components

RoHS applies to every single electrical or electronic component of your E-bikes. With that said, you shall ensure only using RoHS-compliant components when manufacturing your products. Further, you shall instruct your supplier with RoHS at an early stage.

RoHS Lab Testing

If your supplier failed to provide RoHS test reports, you may need to book a third-party lab testing for your E-bikes product. RoHS quotation is done on a per-component basis and the cost is relatively lower than other compliance tests, which often starts at $10 per component.

Here are some companies offering RoHS testing:

• QIMA
• Bureau Veritas
• SGS
• Intertek
• TUV

CE Mark

RoHS Directive is also a CE directive, which means you must get your electronic product (e.g. E-bikes) CE marked.

RoHS Symbol

RoHS does not require compliance mark to show compliance, and the symbol has no legal meaning by itself. However, many suppliers choose to label the use of the symbol to help identify RoHS compliant products.

Risks

Some electronic components used in the e-bike industry may contain excessive amounts of heavy-metals. Instruct your supplier to only procure RoHS compliant components and materials prior to entering production.

EMC Directive

E-bikes with an electric motor at 0.25 kW or lower continuous rated power that can speed up to a maximum of 25km/h, must comply with the EMC Directive when imported and sold in the EU market. The EMC Directive sets requirements to limit electromagnetic interference and ensuring that electronic devices will not interfere with each other.

EMC Test Reports

Some E-bikes suppliers can provide an EMC test report for compliance requirements in the EU. Otherwise, importers will need to book a testing service from EMC testing companies such as SGS, QIMA, and TUV.

EMC Directive Testing Costs

In general, the EMC test cost starts from a few hundreds of dollars, and it will increase due to the complexity of your E-bike product.

CE Mark

The EMC Directive is a CE directive which means you must attach with the CE mark label on the product and its packaging.

Low Voltage Directive (LVD)

The LVD applies to electronics devices with the input/output range of 50 to 1000V AC or 75 to 1500V DC. This directive applies to E-bike accessories such as chargers and AC adapters. Importers shall also ensure the LVD compliance for the AC adapters before importation.

You can learn more about AC adapters safety standards in the EU in this article.

LVD Test Reports

The AC adapters used for E-bikes must be tested according to the requirements of the LVD. Not many E-bikes suppliers can provide LVD test reports or certificates, therefore, we suggest that importers shall conduct lab testing for the AC adapters according to the LVD.

CE Mark

The E-bike’s charger must be CE marked as it falls into the scope of the LVD, which is also a CE directive. Further, importers shall prepare other required documents such as DoC, technical files and test reports.

EU Battery Directive

The EU Battery Directive regulates all lithium batteries imported and sold in the EU market. Similarly to the RoHS Directive, it also sets limits for the use of harmful substances in lithium battery products, but in a more stringent way.

Here are some examples of restricted substances under the EU battery directive:

• Lead (less than 0.0004 % by weight)
• Mercury (less than 0.0005 % by weight)
• Cadmium (less than 0.002 % by weight)

Labeling requirements

All lithium batteries must be labeled with the crossed-out wheeled bin, to indicate that batteries shall be collected separately. As such, importers shall provide the label file in .ai or .eps, and instruct the supplier with the EU Battery Directive requirements.

Lab testing

Not many suppliers can provide compliance documents according to the directive. As such, third-party lab testing is the only possible way to verify the compliance of your lithium battery.

Established testing companies such as Intertek, SGS, and Bureau Veritas can offer Battery Directives related services including product lab testing, product labeling, product registration, implementation of collection and recycling system.

EN Standards

Imported bicycles, whether electronic or not, must comply with safety requirements before being imported and place to the market. EN standards provide safety guidelines for different types of bicycles including trekking bicycles, mountain bicycles, and racing bicycles.

EN standards are generally voluntary but they might also be harmonized under different directives and regulations. Therefore, Importers can utilize them to ensure the safety of their products.

Examples of bicycle EN standards

• EN 14764 – City and trekking bicycles safety requirements and test methods
• EN 14766 – Mountain bicycles – safety requirements and test methods
• EN 14781 – Racing bicycles – safety requirements and test methods
• EN 14872 – Bicycles accessories for bicycles(e.g luggage carriers)

You can search for more applicable EN standards for E-bikes on shop.bsigroup.com.

CE Marking

As mentioned above, e-bike products must be labeled with the CE mark on the product and its packaging, as they fall under the scope of several CE directives such as LVD, EMC, and Machinery.

CE label file

It’s the importer’s responsibility to create the CE label file, then submit it to the supplier. Further, importers shall inform the supplier with the following information:

• Dimensions
• Position
• Color
• Print type

Product Traceability

E-bike importers shall also provide a permanent traceability code to the product and its packaging. The traceability code shall at least include the following information:

• SKU
• Manufacturing date
• Production facility
• Country code

Example: SKU-0909-231-CN

CE Documentation

Before importing E-bike products to the EU, importers shall prepare all required documents under the CE directives. In this section, you find an overview of the required CE documentation.

Declaration of Conformity (DoC)

The Declaration of Conformity is a primary document that is often requested by retailers, governments and market surveillants. Either the importer or manufacturer is responsible for issuing the DoC documents, and it shall include information such as:

• Produce identification
• Product features
• Name and address of the manufacturer/importer
• List of EN standards or directives
• Location
• Responsible individual

User Manual

The user manual shall be provided with the product in the product package. In general, importers shall including the followings in the user manual:

1. Instructions on how to install the product

2. An overview of the relevant parts and part names of the product

3. Safety instructions

4. Instructions on how to use the product

5. Instructions on how to recharge and/or refill the product and

6. Instructions on how to dispose of the product in an environmentally friendly manner

Technical File

The technical file is somehow similar to the product specification, but it shall include all relevant test reports for identification. The technical file shall include information such as:

• Bill of materials
• Design drawings
• Label files
• Packaging files
• List of applied standards and directives (e.g. RoHS)
• Test reports
• QC reports
• Risk assessment

WEEE Symbol

The WEEE symbol indicates separate collection for electrical and electronic equipment including E-bikes. The symbol must be printed visibly and permanently on the E-bike product, its packaging and user manual.

WEEE label file

Importers shall create the WEEE label file preferably in .ai or .esp format, then instruct the supplier with information such as placement, size, and dimension.

National E-Bike Standards/Regulations in the EU

Many EU countries have their own laws for the use of electric bicycles. Therefore, importers must be aware of the bicycle law when deciding the EU market, then make appropriate adjustments to the product specifications.

Here are electric bicycle regulations in some EU countries:

Finland

250 Watt and a maximum speed of 25km/h e-bikes are allowed. Higher watt electric motors can only be used with proper insurance.

Sweden

The maximum nominal motor power output shall not exceed 250 watts and performance speed shall not exceed 25 km/h.

Belgium

Three types of e-bikes are allowed in Belgium:

• 250 Watt and a maximum speed of 25km/h e-bikes;
• 1000 Watt and a maximum speed of 25km/h e-bikes with conformity certificate;
• 4000 Watt and a maximum speed of 45km/h e-bikes with conformity certificate

Other Information

REACH

While RoHS only covers certain heavy metals in electronic components, REACH regulates chemicals and heavy metals in all consumer products sold in the EU. Some materials, such as plastic bike handles, paints and coatings may contain excessive amounts of restricted substances.

Product Packaging

E-bikes importers shall also comply with product packaging requirements in the EU. The EU sets limits on the heavy metals and other hazardous substances contained in the product packaging. For example, the packaging of E-bikes shall not contain an excessive amount of lead.

The only way to verify if your product packaging is to get a third-party lab testing. Reputable testing companies such as Intertek, SGS, and Bureau Veritas provide comprehensive compliance services for product packaging.