Product Regulations for E-Bikes
The EU Machinery Directive 2006/42/EC applies to most energy-powered machinery products placed on the EU market and outlines the essential requirements that importers should comply with before importing to the EU. The directive specifies electronic bikes falling under this category as “cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of 0.25 kW, or which the output is progressively reduced and finally cut off as the vehicle reaches a speed of 25 km/h, or sooner if the cyclist stops pedalling.” (European Commission, 2018). Importers who are importing E-Bikes also need to ensure that the product design satisfies the requirements as outlined in this directive.
Another regulation that must be adhered to for E-Bikes is Electromagnetic Compatibility (also known as the EMC Directive). The purpose of this is to ensure that electric devices in close proximity to each other are not interfering with one another. The EMC Directive stipulates the limits of electromagnetic emissions of equipment in order to ensure that the equipment doesn’t disturb radio and telecommunication, as well as other equipment. This Directive specifies legally-binding protection of requirements, including E-Bikes.
If there are any ‘smart’ communication components like Bluetooth or WiFi-modules included on the product, the Radio Equipment Directive 2014/53/EU (RED) applies to those components. It’s recommended to use pre-certified CE modules that are designed in accordance with the RED Directive.
The European Battery Directive 2006/66/EC regulates all lithium batteries sold in the EU marketplace. It sets limits for the use of harmful substances in the battery product, but in a more rigid way. For example:
- Lead (less than 0.0004% by weight)
- Mercury (less than 0.0005% by weight)
- Cadmium (less than 0.002% by weight)
It is important that before any other considerations are taken into account, these directives are adhered to. Without adherence to these guidelines, the product will not be able to be sold in the European marketplace.
RoHS (Restriction of Hazardous Substances) regulates hazardous substances, such as heavy metals, in electronic products. There are many metallic parts that can be found in E-Bikes, including the battery, sprockets, and crankset. Restricted substances under RoHS include:
- Cadmium (0.01 %)
- Lead (0.1 %)
- Mercury (0.1 %)
- Hexavalent chromium (0.1 %)
- Polybrominated biphenyls (PBB) (0.1 %)
- Polybrominated diphenyl ethers (PBDE) (0.1 %)
- Bis(2-ethylhexyl) phthalate (DEHP) (0.1 %)
- Butyl benzyl phthalate (BBP) (0.1 %)
- Dibutyl phthalate (DBP) (0.1 %)
- Diisobutyl phthalate (DIBP) (0.1 %)
The last four listed substances were added in 2015 and are a part of the updated RoHS Standard known as RoHS 3 (EU 2015/863).
Manufacturers should always ensure RoHS-compliant components when manufacturing products in Europe, or if they are importing to Europe. Suppliers should be instructed as such in the early stage of product design and manufacture. We’ve previously written about certification for electronics in which we touched upon EMC, Low Voltage and RoHS if you want to learn more.
Harmonised Safety Standards for E-Bikes
A standard specifically harmonised for E-Bikes is EN 15194:2017. Most E-Bike safety requirements can be found in this standard. Examples of these are:
- The battery of E-Bikes needs to comply with relevant regulations such as the EU battery directive
- E-Bikes must be clearly and permanently marked with a serial number which must be in a readily visible location
- The frame must be visibly and permanently marked with the name of the manufacturer or the manufacturer’s representative and the number of European Standard. In addition to this, the vehicle must be durably marked with the following words: “EPAC according to EN 15194.”
- The vehicle must be provided with a series of preparation information; including preparing for riding, recommended fasteners, adjustment of gears and brakes, care of wheel rims and explanations of rim-wear and the risks associated with it, and recommendations about battery charging and charger use
This European Standard specifies requirements and test methods for engine power management systems, electrical circuits including the charging system for the design and assembly of electrically power-assisted bicycles and sub-assemblies for systems having a rated voltage up to and including 48 V d.c. or integrated battery charger with a nominal 230 V a.c. input. The Standard specifies safety and safety-related performance requirements for the design, assembly, and testing of EPAC bicycles and subassemblies intended for use on public roads, and lays down guidelines for instructions on the use and care of such bicycles. This applies to EPAC bicycles that have a maximum saddle height of 635 mm or more and that are intended for use.
Labelling Requirements for E-Bikes
CE Marking, as with all compliant products must be affixed to the bike visibly, legibly, and indelibly in the immediate vicinity of the name of the manufacturer or their authorised representative. CE Marking may only be affixed if the E-Bike also conforms to directive 2014/35/EU relating to electromagnetic compatibility (EMC).
RoHS doesn’t require a mark to demonstrate compliance, and the symbol has no legal significance in itself, however many suppliers do choose to label RoHS compliant products to distinguish them from other products. This often gets conflated with the trash bin symbol of the Waste of Electrical and Electronic Equipment Directive (also known as the WEEE). A WEEE symbol, which indicates the separate collection for electrical and electronic equipment including E-Bikes must be printed visibly and permanently on the product, it’s packaging and the user manual.
While these labelling requirements are typically the main ones to consider for manufacturers, there is a whole list which includes more specific labelling requirements that would apply on a case by case basis. Manufacturers should consult with a legal body to ensure compliance with these is adhered to if necessary.
Technical Documentation for E-Bikes
Manufacturers need to be aware that they will need to have a completed technical file on the product available. They also need to ensure they supply the E-Bike with an EC Declaration of Conformity. The technical file, while similar to the product specification, also includes all relevant testing reports for identification. It should include information such as:
- Bill of materials
- Design and electrical drawings
- Label files
- Packaging files
- List of applied standards and directives
- Test reports
- QC reports
- Risk assessment
- Declaration of Conformity
The EMC Directive requires that E-Bikes be identified by type, batch, serial number, and any other information allowing for the identification of the vehicle. The manufacturer needs to be identified by name and addressed or if, outside the European Union, the name and address of the authorised representative must be given.
In addition to the above files, a WEEE label file must be supplied in .ai or .esp format to instruct the supplier with information such as placement, size and dimension.
Testing Requirements for E-Bikes
Importers must either request test reports from the supplier or book a lab testing for their E-Bikes. There are a number of reputable testing companies that offer compliance services including lab testing, conformity assessment and product certification.
There must be careful considerations when placing forth products into the European market. For example, E-Bikes manufactured in China or other countries outside the EU, are not necessarily designed to comply with EN 15194:2017. It is therefore essential that manufacturers request EN 15194:2017 testing reports prior to beginning the import process. The E-Bike must also be correctly labelled as outlined above.
RoHS lab testing may be required if the supplier fails to provide RoHS test reports. RoHS quotes are done on a per-component basis and the cost is relatively lower than other compliance tests.
E-Bikes, the vehicles of the future: with so much potential to benefit society in multiple ways, many manufacturers are considering selling these in the marketplace. It is however very important to ensure that the future is ‘future-proofed’ by taking into consideration all of the above before beginning the manufacturing process.