E-bikes are subject to various regulations and safety standards in the European Union. These cover everything mechanical safety of the bike frame to battery safety and electrical compliance requirements.
In this guide, we explain what importers and manufacturers must know about the Machinery Directive, EN 15194, CE marking, documentation, and lab testing requirements applicable to e-bikes.
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The Machinery Directive applies to most energy-powered machinery products placed on the EU market. It sets mandatory health and safety requirements and harmonised standards.
Importers and manufacturers should comply with these requirements before importing e-bikes to the EU. Further, they should also prepare required label files and documents such as a technical file, and test reports.
The Machinery Directive covers:
a. A set of parts that can be put together and includes a drive system with at least one movable component
b. A set of parts that are already assembled and may have moving components, to lift heavy items via human-assisted efforts
- Interchangeable equipment
- Safety components
EN 15194 – Cycles – Electrically power assisted cycles – EPAC Bicycles
EN 15194 has been harmonised under the Machinery Directive, which means that it provides a presumption of conformity with the technical requirements of the directive.
The standard includes requirements and test methods to cover common significant dangers that might be caused by e-bikes, including for:
- The engine power management systems
- The electrical circuits
- The charging system
Finally, EN 15194 applies to e-bikes that have a saddle height of 635 mm or more, and are thought to be used on public roads.
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 labelled (e.g. serial number and CE mark). The battery must also comply with all applicable EU regulations.
The RoHS Directive regulates certain hazardous substances (e.g. heavy metals and phthalates) in electronic products and components, including e-bikes. Many electronic components can be found in e-bikes, such as the battery, circuits, and wires.
Therefore, importers and manufacturers should ensure that all parts of E-bikes contain an acceptable level of restricted substances before entering the EU market.
The manufacture and importation of e-bikes and their components and accessories are subject to RoHS restrictions. The RoHS Directive covers categories of products such as:
- Sports and leisure equipment
- Lighting equipment
- Telecommunications equipment
As such, products covered by the RoHS and relevant to e-bikes include examples such as:
- LED lighting and fluorescent lamps
- Electric motors
- Electrical wires
- Wifi or Bluetooth devices
The RoHS Directive provides a list of substances and their restriction limits concerning their maximum concentration values:
- Lead < 0.1%
- Mercury < 0.1%
- Cadmium < 0.01%
- Hexavalent chromium < 0.1%
- Polybrominated biphenyls (PBB) < 0.1%
- Polybrominated diphenyl ethers (PBDE) < 0.1%
- Bis(2-Ethylhexyl) phthalate (DEHP) < 0.1%
- Benzyl butyl phthalate (BBP) < 0.1%
- Dibutyl phthalate (DBP) < 0.1%
- Diisobutyl phthalate (DIBP) < 0.1%
RoHS applies to every single electrical or electronic component of your e-bikes. With that said, you should ensure that you only use RoHS-compliant components when manufacturing your products.
This in turn requires that you instruct your supplier to only procure components that are RoHS compliant.
RoHS does not require the “RoHS symbol” to show compliance, and the symbol has no legal meaning by itself. However, many suppliers choose to use the symbol to help identify RoHS-compliant products.
Some electronic components used in the e-bike industry may contain excessive amounts of heavy metals or other restricted substances. Instruct your supplier to only procure RoHS-compliant components and materials before entering production.
The EMC Directive sets requirements to limit electromagnetic interference among products and ensure that electronic devices do not interfere with each other. This includes requirements for e-bikes and their chargers.
The EMC Directive covers a wide range of electronic products, and includes e-bikes such as the following:
- Pedal-assisted electric bikes
- Speed pedelec electric bikes
- Throttle electric bikes
Products that may be used in conjunction with e-bikes are also covered by the EMC Directive and include items such as:
- Lighting products (e.g., LED lighting)
- LED displays
- Lithium batteries
- Electrical motors (e.g. DC brushed motors)
Low Voltage Directive (LVD)
The Low Voltage Directive (LVD) applies to electronic devices with the input/output range of 50 to 1000 V in alternating current or 75 to 1500 V in direct current. This directive applies to e-bike accessories such as AC adapters.
The Low Voltage Directive covers many electronic products that can be plugged into a power socket, so long as their input or output voltage parameters fall between 50 and 1000 V for alternating current, and 75 and 1500 V for direct current.
Electronic devices covered by the LVD include products such as the following:
- LED lighting
- AC adaptors
- Electrical cables and wires
Radio Equipment Directive
The Radio Equipment Directive (RED) sets a regulatory framework for the placement on the market of radio equipment. It establishes requirements that aim to ensure that the radio spectrum is efficiently used and products are electromagnetically compatible, as well as making sure that the products are safe.
The RED covers radio equipment that can be used in conjunction with e-bikes, such as the following:
- GPS navigation devices
- Wireless devices
- Bluetooth devices
- RFID Devices
E-Bike Lab Testing
Lab testing is in practice mandatory when importing or manufacturing e-bikes in the EU. For starters, you need to arrange lab testing corresponding to the harmonised standards under the following directives:
- Machinery Directive
- Low Voltage Directive
- EMC Directive
- RoHS Directive
- Radio Equipment Directive
The test reports must also be included in the technical documentation, which is covered below in this guide. Other than that, battery testing is also important.
It’s also important to note that different tests apply to different parts of the bike. Here are some examples:
- Electrical safety: AC adapter
- Battery safety testing: Lithium battery
- Mechanical safety: Bike frame
E-bike products must be labelled with the CE mark on the product and its packaging, as they fall under several CE directives such as Low Voltage, EMC, and Machinery Directive.
It’s the importer’s responsibility to create the CE label file, and then submit it to the supplier. Further, importers should inform the supplier of the following information:
- Print type
E-bike importers and manufacturers should also provide a permanent traceability code to the product and its packaging. The traceability code should at least include the following information:
- Product type
- Batch or serial number
- Company name
- Company address
- Contact information
Before importing e-bikes to the EU, importers and manufacturers should prepare the required documents under CE directives such as the:
- Machinery Directive
- RoHS Directive
- Low Voltage Directive
- EMC Directive
- Radio Equipment Directive
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, marketplaces and market surveillants. Either the importer or manufacturer is responsible for issuing the DoC documents, which should include information such as:
- Product identification
- Product features
- Name and address of the manufacturer/importer
- List of EN standards or directives
- Responsible individual
The user manual should be provided with the product in the product package. In general, importers and manufacturers should include the following information in the user manual:
a. Instructions on how to install the product
b. An overview of the relevant parts and part names of the product
c. Safety instructions
d. Instructions on how to use the product
e. Instructions on how to recharge and/or refill the product and
f. Instructions on how to dispose of the product in an environmentally friendly manner
The technical file is somehow similar to the product specification, but it should include relevant test reports and other relevant 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
The Waste from Electrical and Electronic Equipment (WEEE) Directive aims to protect human health and the environment by reducing as much as possible the adverse effects of WEEE and the use of resources. It also aims to improve the usage efficiency of such resources by promoting the collection and recycling of EEE.
The WEEE Directive covers a wide range of electrical and electronic equipment, which include products that can be used in conjunction with e-bikes, such as the following:
a. Telecommunication equipment (e.g. GPS devices)
b. Video displays (e.g. LCDs)
c. Lighting equipment (e.g. LED lights)
d. Leisure and sports equipment
Importers and manufacturers must label and register their electrical and electronic equipment per the WEEE Directive.
The WEEE label, which importers and manufacturers are mandated to apply to their EEE products and packaging, is a crossed-out wheeled bin, which means that the product should be sent to a collection facility for recycling.
If importers and manufacturers have placed the product on the market after mid-2005, then they can add a bar beneath the bin label. Alternatively, they can provide the date on which the product was placed on the market.
Importers and manufacturers of EEE products are required to register their companies with the relevant national authorities, as well as provide information such as the following:
a. The producer’s name, address, contact details, and national identification code
b. Category, type, and brand name of the EEE
c. Information on individual or collective schemes and financial guarantees
d. Selling technique
e. Declaration stating that the provided information is true
The Battery Directive regulates most batteries imported and sold in the EU market, including lithium batteries used for e-bikes. Similarly to the RoHS Directive, it also sets limits for the use of harmful substances in lithium battery products, but more stringently.
Importers and manufacturers of batteries are required to properly label their products, as well as follow registration requirements and ensure that their batteries do not contain restricted substances above the limits.
Here are some examples of restricted substances under the EU battery directive:
- Mercury (less than 0.0005 % by weight)
- Cadmium (less than 0.002 % by weight)
Lithium batteries must be labelled with the crossed-out wheeled bin, to indicate that batteries shall be collected separately. As such, importers and manufacturers should provide the label file in .ai or .eps, and instruct the supplier about the Battery Directive requirements.
Importers and manufacturers are required to register their batteries with relevant registration bodies, and provide information such as the following:
a. Brand and company’s name and address
b. Contact details (phone number, email address, and contact person)
c. Type of battery (e.g. automotive, industrial, portable)
d. Details of product compliance with relevant requirements (e.g. test report)
e. Registration application date
f. Importer or manufacturer’s national identification code, including European or national tax number
g. A statement declaring the authenticity of the provided information
Bicycles, whether electronic or not, must comply with safety requirements before being imported and placed on 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 harmonised under different directives and regulations. Therefore, Importers and manufacturers can utilize them to ensure the safety of their products.
Examples of bicycle EN standards
Here are some examples of standards that apply to e-bikes and bicycles:
a. EN 15194 – Cycles – Electrically power assisted cycles – EPAC Bicycles
b. EN ISO 4210 – Cycles. Safety requirements for bicycles
c. EN 8098 – Cycles – Safety requirements for bicycles for young children
d. EN ISO 11243 – Cycles – Luggage carriers for bicycles – Requirements and test methods
While EN 15194 standard for EPAC bicycles has been harmonised under the Machinery Directive, the other three EN standards listed above are harmonised under the General Product Safety Directive (GPSD).
You can search for more applicable EN standards for e-bikes at www.cencenelec.eu.
Lithium Battery EN Standards
Lithium batteries can be used in conjunction with electronic bicycles – as the power source for the engine and the product’s components or accessories. As such, it is important to ensure that the batteries sold with the product are safe to handle, install, and use.
One way to assess if the lithium batteries are safe to use, is to send them for testing against relevant EN standards.
Here are some examples of EN standards that are relevant for e-bikes:
a. EN 60086-4 – Safety of lithium batteries
b. EN 62133 – Safety requirements for portable sealed secondary cells
c. EN 61960 – Secondary lithium cells and batteries for portable applications
d. EN IEC 62485-5 – Safe operation of stationary lithium ion batteries
National E-Bike Standards and Regulations in the EU
Many EU countries have specific laws for the use of electric bicycles. Therefore, importers and manufacturers must be aware of the bicycle law when deciding the EU market and make appropriate adjustments to the product specifications.
Below we list three examples of electric bicycle regulations in some EU countries.
250 Watts and a maximum speed of 25km/h e-bikes are allowed. Higher-watt electric motors can only be used with proper insurance.
The maximum nominal motor power output shall not exceed 250 watts and the performance speed shall not exceed 25 km/h.
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
Here we list some additional regulations that are relevant to e-bikes.
While RoHS only covers certain heavy metals and chemicals in electronic components, REACH regulates chemicals and heavy metals in consumer products sold in the EU. Some materials, such as plastic bike handles, paints and coatings may contain excessive amounts of restricted substances.
UN 38.3 provides requirements regarding the transportation of lithium metal batteries and lithium-ion batteries by air, such as documentation, labelling, and testing.
Compliance with UN 38.3 is necessary in the EU because the European Aviation Safety Agency (EASA) mandates that lithium batteries must respect UN 38.3 requirements before shipping the products by air.
Labelling requirements include items such as the following on the packaging:
- “Cargo Aircraft Only” label
- Lithium battery mark label
- Class 9 lithium battery hazard label
- “UN” and the Proper Shipping Name
- The UN Number
- The shipper’s and consignee’s address
- Net mass
Documentation might include:
- A test summary
- A Shipper’s Declaration
Finally, it might be necessary to test your batteries against one or more of the following standards:
- Test T.1: Altitude Simulation
- Test T.2: Thermal Test
- Test T.3: Vibration
- Test T.4: Shock
- Test T.5: External Short Circuit
- Test T.6: Impact/Crush
- Test T.7: Overcharge
- Test T.8: Forced Discharge
Directive on Packaging and Packaging Waste
The Packaging and Packaging Waste Directive aims to reduce the negative environmental impact of packaging waste by harmonizing how packaging and packaging waste is managed across the European Union.
The directive restricts the following heavy metals in packaging and packaging waste to 100 ppm:
- Hexavalent Chromium
Extended Product Responsibility
The directive also establishes requirements for the Extended Product Responsibility (EPR) scheme. It requires importers and manufacturers in the EU to be financially responsible for their products at the post-consumer stage, by paying an EPR organization to collect and recycle discarded packaging and packaging waste.
Examples of EPR organisations include, but are not limited to, the following:
- EcoEmbes (Spain)
- FTI (Sweden)
- FOST Plus (Belgium)