The Bicycle Association, representing the UK cycle industry, has serious concerns about reported proposals to change the well-established rules about road legal e-bikes in the UK.
UPDATE: the offical consultation has now been published here. We are now urging the industry to respond before the deadline of 25th April – pre-filled emails and suggested replies are here.
Currently, e-bikes are limited to a motor power rating of 250 W, and the motor can provide assistance up to 25 km/h only when the rider is pedalling.
We understand that the Department for Transport intends to launch a consultation on doubling the power to 500W, and allowing the motor to act without the rider pedalling at all.
We will comment in more detail once the consultation document is available, but our initial concerns include:
- Risk of moped-like requirements: These proposed changes to the well proven Electrically Assisted Pedal Cycle (EAPC) regulations to allow motor operation without pedalling put at risk the pedal cycle status of e-bikes, which is key to their growth potential. Non-pedalling electric cycles would be less like pedal cycles and more like mopeds in character or performance, so in time, if not immediately, it will in our view prove impossible to resist calls for moped-like requirements such as mandatory insurance, registration and helmets. This will make the whole category significantly less attractive for users.
- Public health: Availability of e-cycles for which no pedalling is required could also make the active travel modes of walking, wheeling and pedalled (e-)cycling relatively less attractive, without necessarily attracting many new users to the new no-pedalling e-bikes (because it is perceived safety, not the effort of pedalling, which has repeatedly been found to be the main barrier to any form of cycle use). This would have obvious consequences for public health.
- Fire risk: If this change is made it risks driving users to purchase the very online-sourced, poorly regulated e-bike kits, and batteries from overseas which are, evidence increasingly confirms, responsible for very many of the recent tragic battery fire incidents. It would take considerable time for responsible suppliers to develop and test cycles to the new specification (so that they fully comply with relevant safety regulations) and in the meantime, 500W e-bike kits of unknown quality or safety, sourced from online marketplaces and sent directly to consumers from overseas, would be the primary source of new-specification e-bikes for consumers. To avoid this a transition period of at least three years, to allow suppliers to develop, test and produce safe products to the new specificition, is essential if this change is to be made.
- Other unintended consequences could include the legitimisation of tampering with existing e-bikes to boost their power to the new specification – again with possible very serious fire safety consequences.
We urge Government to:
- Consider carefully whether there is really a pressing need for change to EAPC regulations. Rules aligned with current UK EAPC regulations are widely used and accepted internationally, and in many countries EAPCs under these rules are highly popular and successful. The industry stands ready to propose a number of interventions to Government which would boost uptake of EAPCs as has been done overseas.
- Weigh carefully any possible benefits of this proposed change against the very real risk that it will, in time if not immediately, see the attractiveness to users of the EAPC category degraded by additional restrictions. This will put at risk the UK’s active travel and decarbonisation objectives, and UK cycle industry growth.
- Consider any amendments to EAPC regulations only as part of a comprehensive, overall plan for micromobility, not as an isolated change. The introduction of a new Low-speed Zero Emission Vehicle (LZEV) legislative framework would be the most appropriate opportunity to consider any such change. If a new category of higher power, ‘no pedalling’ e-cycle is to be introduced, it would better be proposed and consulted on as part of a holistic LZEV plan, rather than as a change made in isolation.
