E-bikes are defined as bicycles with an electric motor that provides pedal assistance and allows riders to accelerate their pace. This guide is relevant to all companies indenting to import, manufacture, or sell e-bikes in the United States. It covers both regulations and standards for e-bikes, including 16 CFR Part 1512, FCC Title 47, CPSIA, and more.
16 CFR Part 1512 – Requirements for bicycles
The CPSC mandates importers and manufacturers of bicycles to refer to 16 CFR Part 1512 – Requirements for Bicycles to ensure that their products are safe for consumer use.
16 CFR Part 1512 defines bicycles (which includes e-bikes) as the following:
a. A vehicle with two wheels, with the back wheel being driven solely by human power
b. A motorized (up to 750 watts), pedaled, and single horse-powered vehicle with two or three wheels that, when ridden by a person weighing a maximum of 170 pounds on flat and paved surfaces, does not exceed a maximum speed of 20 mph
Importers and manufacturers are required to ensure that their e-bikes comply with safety requirements outlined in 16 CFR Part 1512, such as the following:
- Mechanical requirements
- Requirements for pedals
- Requirements for tires
- Requirements for front fork
- Requirements for reflectors
Fully-assembled bicycles should have permanent traceability markings or labels attached that list the following:
- The manufacturer
- The location
- The date the bicycle was made
The label or marking should be attached to the bicycle’s frame in such a way that attempts to remove it without destroying the bicycle is futile.
Bicycles and their components have to undergo various tests to ensure they can be used safely, such as the following:
- Protective cap and end-mounted devices test
- Handbrake loading and performance test
- Footbrake force and performance test
- Handlebar stem test
- Fork and frame test
- Reflector mount and alignment test
General Certificate of Conformity (GCC)
The General Certificate of Conformity (GCC) is used to certify that your imported e-bike products comply with applicable consumer product safety standards such as CPSC standards. Importers or manufacturers must issue the GCC with a list of applicable standards (e.g.16 CFR Part 1512) and support documents such as certificates and test reports.
Here is a GCC content overview for e-bikes:
a. Name and description of the e-bike
b. List of applicable standards
c. Identification of the importer or manufacturer
d. Contact information: Mailing address, e-mail address, phone number
e. Date (month, year) and place (city, country) of production
f. Date (month, year) and place (city, country) of product testing
g. Third-party testing company, contact person, e-mail, phone number, and address
FCC 47 CFR Part 15 – Radio Frequency Devices
The Federal Communications Commission (FCC) enacts Title 47 CFR Part 15, which regulates the electromagnetic compatibility of radiofrequency (RF) devices.
Importers and manufacturers of RF devices should ensure that their products comply with FCC 47 CFR Part 15’s requirements before importing them into the US. This might include accessories or components of e-bikes.
FCC 47 CFR Part 15 covers products and accessories that may be used in conjunction with e-bikes, such as the following:
- Electrical motors
- LED Lights
- Display screens
- GPS or Bluetooth or WIFI devices
The FCC provides several measurement standards by which an RF device’s electromagnetism can be measured to ensure it complies with relevant technical requirements. Examples that are incorporated by reference into Part 15 include standards such as the following:
a. ANSI C63.10 – American National Standard Of Procedures For Compliance Testing Of Unlicensed Wireless Devices
b. ANSI C63.4 – American National Standard For Methods Of Measurement Of Radio-Noise Emissions From Low-Voltage Electrical And Electronic Equipment In The Range Of 9 kHz To 40 GHz
c. ANSI C63.17 – American National Standard Methods of Measurement of the Electromagnetic and Operational Compatibility of Unlicensed Personal Communications Services (UPCS) Devices
Unintentional radiators are devices that generate RF energy for use inside those devices but do not emit it wirelessly. These radiators are meant to send electrical signals via internal wiring.
Unintentional radiators that could be used in conjunction with e-bikes include examples such as the following:
- LED lighting
- External switching power supply
Supplier’s Declaration of Conformity (SDoC)
The FCC states that unintentional radiators should be authorized using the SDoC procedure. As such, importers and manufacturers are required to ensure that their RF devices are approved using this procedure before placing them on the market.
Importers and manufacturers should provide, upon request, a test report providing evidence that their product complies with relevant requirements.
Unintentional radiators subject to SDoC approval are required to carry information such as the following:
a. Product identification (e.g. model or trade name)
b. Compliance statement
c. Name, address, phone number, or email address of the importer or manufacturer in the US
The above information must be placed in a reasonably accessible location, such as in the instruction manual.
Importers and manufacturers may choose to display the optional FCC logo on their SDoC-approved unintentional radiators.
Intentional radiators are devices that emit RF energy via induction or radiation, such as the following:
- Bluetooth speakers
- Bluetooth e-bike display
- E-bike alarm wireless vibration motion sensors
The FCC mandates the authorization of intentional radiators using the certification procedure as products such as those listed above have the potential to negatively interfere with other RF devices.
As such, importers and manufacturers have to send their intentional radiators for testing at an accredited test lab that is recognized by the FCC. If the product passes relevant tests, and includes the relevant documentation, an FCC-recognized Telecommunication Certification Body (TCB) issues the equipment authorization, thereby approving the product for sale.
Intentional radiators subject to the certification procedure are required to carry an FCC identifier (FCC ID) and a compliance statement, either as a physical label or an e-label.
Requirements for physical FCC ID labels include the following:
a. The label should be on the surface, or an accessible but nondetachable compartment, of the product
b. The label should be permanently attached to the product for easy identification
c. The FCC ID should be placed in the user manual and packaging when the size of the product does not permit the placement of the label
Energy Conservation Program for Consumer Products – 10 CFR Part 430
10 CFR Part 430 establishes energy efficiency testing procedures for consumer products, excluding automobiles.
Consumer products that may be used in conjunction with e-bikes and are covered by 10 CFR Part 430 include examples such as the following:
- Battery charger
- LED lights
- Reflector lamps
- Reflectorized or aperture lamp
10 CFR Part 430 contains many test methods for multiple products listed within, each having its testing requirements. For example, Part 430 outlines a test method that requires the measurement of electrical and photometric characteristics, and this test method only covers products such as the following:
- General service fluorescent lamps
- Incandescent reflector lamps
- General service incandescent lamps
As another example, the regulation provides a test method to measure the energy consumption of battery chargers.
Energy Efficiency Program for Certain Commercial and Industrial Equipment – 10 CFR Part 431
10 CFR Part 431 establishes test procedures and energy conservation standards for certain commercial and industrial equipment. Products listed in 10 CFR Part 431 are required to undergo testing procedures outlined within. It also establishes certification requirements for electrical motors.
10 CFR Part 431 covers products that may be used on, or in conjunction with, e-bikes, such as the following:
- Electric motors
- Distribution transformers
The compliance certification in 10 CFR Part 431 applies to electrical motors and requires attestation that the basic model complies with relevant standards. The certification requires acknowledgment of the following:
a. That the electric motor’s nominal full load efficiency is not less than the motor’s required nominal full load efficiency
b. That the motor complies with the requirements in 10 CFR Part 431
c. That all information provided is accurate, complete, and factual
d. That the importer or manufacturer understands the federal penalties regarding the provision of false information
Products covered by 10 CFR Part 431 are subject to their specific testing requirements. For example, Subpart B concerns testing procedures for determining the efficiency of electric motors only, and Appendix A to Subpart K has a test method for measuring how much energy distribution transformers consume.
Certification, Compliance, and Enforcement for Consumer Products and Commercial and Industrial equipment – 10 CFR Part 429
10 CFR Part 429 establishes certification, compliance, and enforcement procedures for consumer products and commercial and industrial equipment. Subpart B covers many different products, some of which may be used in conjunction with e-bikes, such as the following:
- General service fluorescent lamps
- External power supplies
- Incandescent reflector lamps
- Integrated LED lamps
The certification procedures for each product listed in Subpart B vary from product to product. As such, importers and manufacturers are required to submit product-specific certification reports to the US Department of Energy (DOE) before putting their products on the market.
For example, the certification report for integrated LED lamps requires the inclusion of product-specific information such as the following:
- The test lab’s NVLAP identification number
- Date of manufacture
- Initial lumen output in lumens (lm)
- Input power in watts (W)
- Lamp efficacy in lumens per watt (lm/W)
- Correlated color temperature (CCT) in Kelvin (K)
- Power factor
- Lifetime in years
Importers and manufacturers are required to submit their annual filings to the DOE. There are different dates for different products.
For instance, those who import or manufacture general service fluorescent lamps and incandescent fluorescent lamps have until March 1 to submit their annual filings. Importers and manufacturers of external power supplies and battery chargers have until September 1.
Energy Labeling Rule – 16 CFR Part 305
16 CFR Part 305 – Energy Labeling Rule, establishes requirements that importers and manufacturers are mandated to abide by with regards to labeling electrical products and appliances.
16 CFR Part 305 covers many different types of electrical appliances. Some of these products or components may be used in conjunction with e-bikes, such as lighting.
Lighting products include examples such as the following:
- General service lamps
- Specialty consumer lamps
Part 305.23 provides labeling requirements for various types of lighting products. These requirements vary between products.
However, many have similar requirements, such as the following:
- Energy consumption
- Energy efficiency
- Energy cost
- Operating cost
The label should also include required information such as the following:
- Capacity (size)
- Model number
- Manufacturer’s or company’s name
Underwriter Laboratories (UL) develops and establishes standards for many categories of products including e-bikes. UL is an accredited standards developer in the US and Canada, and the standards are often seen as de facto mandatory for e-bikes and other electronics.
UL standards are generally voluntary and it is in the importers’ interest to comply with the UL requirements, as they might be held liable for any injury or property damages caused by unsafe e-bikes.
UL 2849 – Standard for electrical systems for E-bikes
UL 2849 is an SCC and ANSI-approved standard that covers electrical systems for e-bikes, provided that these e-bikes operate using rechargeable lithium-based batteries. The standard covers two types of e-bikes:
- Electrically-power assisted cycle (EPAC – pedal assist)
- Non-pedal assist e-bikes
UL 2849 notes that the e-bike electrical system has to at least include the following:
- Drive unit
- Battery management system (BMS)
- Interconnecting wiring
- Power inlet
UL Standards for Lithium Batteries
Lithium batteries can be used in e-bikes, or in accessories that can be used in conjunction with e-bikes. To ensure that lithium batteries do not malfunction or are a source of immediate danger to the user or the device the batteries are in, UL has published two standards that focus on lithium batteries:
b. UL 60086-4 – Standard For Safety For Primary Batteries – Part 4: Safety Of Lithium Batteries
Amazon requires companies that sell e-bikes on its platform to abide by its policy, which includes requiring evidence that e-bikes conform to 16 CFR Part 1512 – Requirements for Bicycles as well as one of the following standards:
a. ANSI/CAN/UL 2849 – Standard for Electrical Systems for E-Bikes
b. ANSI/CAN/UL 2272 – Standard for Electrical Systems for Personal E-Mobility Devices
c. EN 15194 – European Electric Bike Safety Standard
Sellers also have to provide information such as the following:
- Company name and seller ID
- Contact information
- List of all e-bikes they list
- Images of the product and its packaging
- Test reports)
- General Certificate of Conformity
All e-bikes, including batteries and AC adapters, are not always tested and compliant with applicable UL standards. On the contrary, plenty of lithium batteries and other components are non-compliant, and may, therefore, be a potential fire or electrical hazard. Notice that this is also the case for compliance with CPSC rules and ASTM standards.
UL 2849 does not cover the mechanical structure requirements of e-bikes. In this case, e-bike importers can refer to ASTM standards for product specification and test methods.
ASTM standards are often voluntary for importers or manufacturers to comply with unless the standards are incorporated by reference in one or more regulations. However, if you import and sell unsafe e-bikes, your products may be forcefully recalled and you will have to pay heavy fines.
Examples of ASTM standards
a. ASTM F2793 – Standard Specification for Bicycle Grips
b. ASTM F2802 – Standard Specification for Condition 1 Bicycle Frames
c. ASTM F2868 – Standard Specification for Condition 2 Bicycle Frames
d. ASTM F2274 – Standard Specification for Condition 3 Bicycle Forks
e. ASTM F2711 – Standard Test Methods for Bicycle Frames
You can also search for more applicable standards for your e-bikes on the ASTM’s official website.
Manufacturers commonly don’t have the equipment and expertise to carry out ASTM testing. Established testing companies like SGS, Intertek, and QIMA, provide ASTM testing services such as conformity assessment, lab testing, certification, and test reports.
E-Bike State Regulations
Many states in the US have implemented specific regulations concerning e-bikes that include age restrictions, e-bike classification, operating licenses, and registration requirements. Here is a non-exhaustive overview of different state regulations.
California defines e-bikes as motorized bicycles with a limitation of 1,000 Watts for power and 20 mph for speed. In addition, customers under the age of 17 must wear an approved helmet while operating e-bikes in California.
New York has banned the use of e-bikes on any public roadway and any violators are subject to arrest. The state of New York requires users to apply for a National Highway Traffic Safety Administration (NHTSA)-issued vehicle identification number (VIN) for their vehicles. However, the acquisition of a VIN for an e-bike is nearly impossible.
Oregon requires e-bikes to be equipped with two fully-operative pedals for human propulsion and an electric motor, which shall not exceed more than 1000 watts and a speed limit of 20mph. Additionally, Oregon restricts the age of e-bike users to 16 and forbids the usage of e-bikes on sidewalks.
Michigan requires motor vehicles to be registered with the Michigan Secretary of State and equipped with headlights, turn signals, a horn, and brake lights. Furthermore, motors on 2 or 3-wheeled e-bikes must not exceed 100 cubic centimeters of piston displacement and the speed must not exceed 30 mph.
Here we list other regulations that might apply to e-bikes.
Hazardous Materials Regulations (HMR)
Batteries are subject to specific transport requirements in the United States, as the batteries contained in e-bikes might cause potential hazards during transportation. Therefore, importers should properly label the product per HMR instructions, and provide relevant documents for compliance.
Click here for more information on how to ship hazardous materials into the United States here.
The Hazardous Material Regulations require importers and manufacturers of batteries to ensure that their products comply with the UN 38.3 requirements when the products are intended to be transported by air.
In turn, UN 38.3 requires importers and manufacturers to:
- Ensure that their batteries are tested according to relevant standards (e.g. Test T.1: Altitude Simulation)
- Provide a test summary
- Provide a Shipper’s Declaration
- Properly label their batteries
The Consumer Product Safety Improvement Act (CPSIA) regulates products for children, and as such, requires that importers and manufacturers provide evidence that their products, including children’s e-bikes, comply with requirements such as the following:
a. Show compliance with safety rules applicable to children’s products
b. Undergo compliance testing at a CPSC-accepted accredited test lab
c. Have a written Children’s Product Certificate
d. Have permanent traceability information on the product or its packaging
Many states in the US restrict hazardous substances such as lead, cadmium, mercury, and nickel on electronic components.
Those restricted substances can be easily found in the parts of e-bikes, especially in the battery and electronic parts. Meanwhile, not many suppliers are aware of the US RoHS regulations, thus importers should verify the compliance via third-party testing companies.
Country of Origin
Most imported products, including e-bikes, must carry a country of origin label on the products and their packaging. The label must be permanently and visibly attached in English.
- Made in the USA
- Made in Germany
- Made in China
- Made in Korea
- Made in Japan
Importers are responsible for providing a country of origin label file to the supplier. The label file shall be in .ai or .eps format, and importers must instruct the supplier about the placement and dimension information.
California Proposition 65
If you are planning to import and sell e-bikes in California, you should also comply with the chemical and hazardous substances restrictions in California Proposition 65 concerning your e-bikes.
The proposition limits certain hazardous substances such as lead, cadmium, mercury, and phthalates, and you cannot import and sell e-bikes in California without a warning label if your products contain an excess amount of those restricted substances.
California Proposition 65 applies to coatings, paints, and other e-bike components. Therefore, we suggest that you book a third-party lab test before importing your e-bikes, as not many suppliers in this industry can provide the California Proposition 65 test report.
Packaging Materials Regulations
Importers and manufacturers should also comply with packaging regulations when importing e-bikes to the United States. In general, the packaging materials must not contain hazardous substances at a harmful level and should be labeled correctly.
Heavy Metals Restrictions
The Model Toxics in Packaging Legislation restricts heavy metals such as lead, cadmium, nickel, and mercury on packaging materials. Unless your supplier can provide relevant test reports for the packaging (which is not common), you may consider requesting testing companies to verify the packaging material.
It may also be necessary to print all required compliance markings and information on the product’s packaging. Importers or manufacturers would also commonly include product information on the packaging.
Bag Suffocation Warning
In certain US states, it is compulsory to add a bag suffocation warning label to avoid non-compliance penalties.
Here is an example from Amazon:
Warning: To avoid the danger of suffocation, keep this plastic bag away from babies and children. Do not use this bag in cribs, beds, carriages, or playpens. This bag is not a toy.