ZIV position: e-bike tuning
9 January 2025
Providers of tuning kits for e-bikes[1] promise to boost the motor assistance beyond the legal limit of 25 km/h for very little money. Together with manufacturers, trade associations and experts, the ZIV has been campaigning for years on both the national and European levels to prevent tuning and raise awareness among consumers of the risks and legal consequences.
With more than 11 million e-bikes on the road in Germany by the end of 2023, the appeal of this environmentally-friendly mobility solution is clear. At the same time, however, a large number of tuning kits are being offered (and used) that enable the legally permitted speed of 25 km/h to be exceeded. This situation poses considerable risks to cyclists’ safety and creates legal and technical challenges for both users and retailers alike.
Providers of tuning kits for e-bikes[1] promise to boost the motor assistance beyond the legal limit of 25 km/h for very little money. Together with manufacturers, trade associations and experts, the ZIV has been campaigning for years on both the national and European levels to prevent tuning and raise awareness among consumers of the risks and legal consequences.
With more than 11 million e-bikes on the road in Germany by the end of 2023, the appeal of this environmentally-friendly mobility solution is clear. At the same time, however, a large number of tuning kits are being offered (and used) that enable the legally permitted speed of 25 km/h to be exceeded. This situation poses considerable risks to cyclists’ safety and creates legal and technical challenges for both users and retailers alike.
Technical principles and risks of e-bike tuning
According to Section 1(3) of the German road traffic act (Straßenverkehrsgesetz, StVG), e-bikes are classified as bicycles as long as they do not exceed a continuous rated power output of 250 watts and a maximum assisted speed of 25 km/h, and only provide motor assistance while the cyclist is pedalling. Mechanical, electronic and software-based tuning kits are today available that remove these limits and sometimes also make considerably higher speeds possible.
Tuning has far-reaching technical implications. The mechanical components of e-bikes, such as the brakes, frame, forks, and handlebars, are not designed to withstand the stresses caused by consistently higher average speeds. This can lead to dangerous material wear and, in turn, to serious accidents. Tuning also invalidates cyclists’ legal right to warranty claims for material defects and any guarantee provided by the bicycle manufacturers. What’s more, workshops refuse to repair tuned e-bikes due to the unpredictability of the effects tuning can have on the safety of bikes and their components – and thus also on any possible liability for repairs.
Tuning has far-reaching technical implications. The mechanical components of e-bikes, such as the brakes, frame, forks, and handlebars, are not designed to withstand the stresses caused by consistently higher average speeds. This can lead to dangerous material wear and, in turn, to serious accidents. Tuning also invalidates cyclists’ legal right to warranty claims for material defects and any guarantee provided by the bicycle manufacturers. What’s more, workshops refuse to repair tuned e-bikes due to the unpredictability of the effects tuning can have on the safety of bikes and their components – and thus also on any possible liability for repairs.
Legal consequences for users and retailers
When an e-bike is tuned to increase its assisted speed, it no longer qualifies as a bicycle. Instead it is legally classified as a motor vehicle – and a whole variety of obligations and restrictions then apply. Among others, users need an operating licence, a driving licence and insurance; they must also wear a helmet and usage restrictions apply on public roads.
The legal consequences can be serious for users: in addition to fines, they may also face criminal charges[2] for driving without a licence or violating the requirement to hold liability insurance. Repeat offences can even lead to a criminal record. Users are also normally liable in the event of an accident, even if they did not cause it.
Retailers who sell, assist with or install tuning kits also face considerable risks. They can be prosecuted for aiding and abetting a criminal offence or made liable for any personal injury and property damage caused by the modified vehicle. They also risk losing their business liability insurance.
The legal consequences can be serious for users: in addition to fines, they may also face criminal charges[2] for driving without a licence or violating the requirement to hold liability insurance. Repeat offences can even lead to a criminal record. Users are also normally liable in the event of an accident, even if they did not cause it.
Retailers who sell, assist with or install tuning kits also face considerable risks. They can be prosecuted for aiding and abetting a criminal offence or made liable for any personal injury and property damage caused by the modified vehicle. They also risk losing their business liability insurance.
Initiatives of the bicycle industry
The ZIV and its member companies identified this problem early on and signed a voluntary commitment to prevent e-bike tuning back in 2016. In it, companies undertake to make manipulation more difficult through preventive technical measures and to raise awareness for the risks. Joint efforts were moreover made to have the requirements for detection and prevention included in DIN EN 15194:2017[3] and to develop CEN/TS 17831:2023[4].
In 2021, the Confederation of the European Bicycle Industry (CONEBI) launched the ‘Companies against Tampering’ anti-tuning initiative. The ZIV continues to work with trade associations, manufacturers and experts to prevent manipulation and inform people about the effects of tuning.[5]
In 2021, the Confederation of the European Bicycle Industry (CONEBI) launched the ‘Companies against Tampering’ anti-tuning initiative. The ZIV continues to work with trade associations, manufacturers and experts to prevent manipulation and inform people about the effects of tuning.[5]
Regulatory challenges and possible solutions
While the use of tuning kits on e-bikes used on public roads is already legally prohibited, it is difficult to control and enforce this ban. The German Road Safety Council (DVR) also points out that many users are not aware of the legal and technical consequences of e-bike tuning. It therefore recommends more stringent regulations and a comprehensive ban on the advertising and sale of tuning kits.[6] The ZIV expressly supports the DVR’s recommendations.
Proposed legislative changes
The ZIV proposes an expansion of the type approvals for vehicle parts to include a clear regulation on speed limiters. This could be achieved by amending Section 22a of the German Road Traffic Licensing Regulations (StVZO), which prohibits the sale and use of unauthorised equipment. Alternatively, the German road traffic act (StVG) could be amended to explicitly prohibit the advertising and sale of software and other electronic components for the purpose of speed manipulation.
Such a ban would not only improve the legal possibilities to address retailers and manufacturers of such kits, but also send a clear message to discourage potential users from making modifications. In France, the advertising and sale of such tuning kits is already prohibited.
Such a ban would not only improve the legal possibilities to address retailers and manufacturers of such kits, but also send a clear message to discourage potential users from making modifications. In France, the advertising and sale of such tuning kits is already prohibited.
Outlook: a comprehensive approach to e-bike tuning
Tuning e-bikes poses a serious risk to road safety and has considerable legal and technical consequences for users and retailers. While initiatives like ‘Companies against Tampering’ perform important awareness-raising work, legal measures are essential to effectively prevent the sale of tuning kits. A combination of regulatory adjustments, technical prevention and awareness raising could decisively improve the safety of e-bikes.
Footnotes
[1] In this document, e-bikes are «pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km/h». This is the definition provided in Chapter 1 Article 2 Section 2(h) of EU Regulation No. 168/2013 on the approval and market surveillance of two- or three-wheel vehicles.
[2] Criminal offence as per Section 21 of the German road traffic act (StVG) on driving without a licence or violation of the German compulsory insurance act (Pflichtversicherungsgesetz, PflVG)
[3] Regulation DIN EN 15194:2017 on Cycles – Electrically Power Assisted Cycles – EPAC bicycles
[4] Regulation CEN/TS 17831:2023 on Cycles – Electrically Power Assisted Cycles – Anti-Tampering Measures. Reproducible Tests to Combat Tampering.
[5] List of risks involved in tuning e-bikes: www.ziv-zweirad.de/wp-content/uploads/2023/09/Leitfaden_Risiken_Nachruesten_von_E-Antrieben-E-Bike_DE_2023-08-2.pdf
[6] DVR proposal to ban the sale of tuning kits for e-bikes to manipulate or removal of the speed limit (in German): www.dvr.de/fileadmin/downloads/Stellungnahmen/240628_DVR-Stellungnahme_Verbot_Vertrieb_Tuning-Kits_Pedelecs.pdf
[2] Criminal offence as per Section 21 of the German road traffic act (StVG) on driving without a licence or violation of the German compulsory insurance act (Pflichtversicherungsgesetz, PflVG)
[3] Regulation DIN EN 15194:2017 on Cycles – Electrically Power Assisted Cycles – EPAC bicycles
[4] Regulation CEN/TS 17831:2023 on Cycles – Electrically Power Assisted Cycles – Anti-Tampering Measures. Reproducible Tests to Combat Tampering.
[5] List of risks involved in tuning e-bikes: www.ziv-zweirad.de/wp-content/uploads/2023/09/Leitfaden_Risiken_Nachruesten_von_E-Antrieben-E-Bike_DE_2023-08-2.pdf
[6] DVR proposal to ban the sale of tuning kits for e-bikes to manipulate or removal of the speed limit (in German): www.dvr.de/fileadmin/downloads/Stellungnahmen/240628_DVR-Stellungnahme_Verbot_Vertrieb_Tuning-Kits_Pedelecs.pdf
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Document created | 09.01.25