ZIV position:
E-bikes – active mobility as success factor
7 April 2025
With almost 16 million e-bikes now on the roads in Germany, they are today the most important driver of electric mobility in Germany and key to both the mobility transition and the climate turnaround. To ensure their continued success, the legal status of e-bikes must be safeguarded and the existing regulations at the same time defined more precisely.
With almost 16 million e-bikes now on the roads in Germany, they are today the most important driver of electric mobility in Germany and key to both the mobility transition and the climate turnaround. To ensure their continued success, the legal status of e-bikes must be safeguarded and the existing regulations at the same time defined more precisely.
Current regulatory framework
To avoid any confusion, the term «EPAC» (standing for «electrically power assisted cycle») defined in EN 15194[1] has been used in this position paper instead of «e-bike».
EPACs are currently described in EU Regulation 168/2013[2] which stipulates the requirements for the type approval of vehicles. In Chapter 1 Article 2 of this regulation, certain vehicles are exempt from the requirement for type approval. According to Section 2(h), the exemption also applies for: «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 means that EPACs are, in legal terms, equivalent to bicycles. This equal status has contributed significantly to the success of EPACs, as it means that they are not subject to any type approval or technical inspections and do not require a licence plate.
EPACs are currently described in EU Regulation 168/2013[2] which stipulates the requirements for the type approval of vehicles. In Chapter 1 Article 2 of this regulation, certain vehicles are exempt from the requirement for type approval. According to Section 2(h), the exemption also applies for: «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 means that EPACs are, in legal terms, equivalent to bicycles. This equal status has contributed significantly to the success of EPACs, as it means that they are not subject to any type approval or technical inspections and do not require a licence plate.
Challenges due to grey areas and unclear definitions
In the EU, the technical regulation of EPACs is based on mandatory compliance with various European directives and regulations. Specifically, the Machinery Directive (2006/42/EC) plays a key role here. This will soon be replaced with the Machinery Regulation (2023/1230), which sets basic health and safety requirements for machinery and also applies to EPACs.
EN 15194 in which specific safety and performance requirements are set for EPACs is a harmonised European standard in line with the Machinery Directive[3]. It has contributed significantly to positive development of the market and contains clear guidelines for manufacturers.
Grey areas still exist regarding the exact technical description of EPACs, though. The values and requirements currently stipulated in Regulation 168/2013 are by all means reasonable and must be retained. However, they leave room for interpretation and do not cover all aspects relevant to vehicle dynamics adequately. Vehicles that are legally classified as bicycles but have a very high maximum power or a disproportionately high assistance ratio blur the boundary between EPACs and motor vehicles classified in category L1e. In particular, the current regulation does not specify exactly which characteristics make a vehicle a bicycle. This in part insufficient distinction makes market surveillance and the legal classification of EPACs challenging.
EN 15194 in which specific safety and performance requirements are set for EPACs is a harmonised European standard in line with the Machinery Directive[3]. It has contributed significantly to positive development of the market and contains clear guidelines for manufacturers.
Grey areas still exist regarding the exact technical description of EPACs, though. The values and requirements currently stipulated in Regulation 168/2013 are by all means reasonable and must be retained. However, they leave room for interpretation and do not cover all aspects relevant to vehicle dynamics adequately. Vehicles that are legally classified as bicycles but have a very high maximum power or a disproportionately high assistance ratio blur the boundary between EPACs and motor vehicles classified in category L1e. In particular, the current regulation does not specify exactly which characteristics make a vehicle a bicycle. This in part insufficient distinction makes market surveillance and the legal classification of EPACs challenging.
Distinction between vehicles of active mobility and motor vehicles
Similar to purely muscle-powered bicycles, EPACs are vehicles of active mobility. Users actively influence the riding behaviour and propel their vehicle by pedalling. A reasonable ratio between cyclists’ pedalling force and the assistance provided by the electric motor as well as an appropriate bicycle weight are decisive to active mobility and thus to the equal status of purely muscle-powered bicycles and EPACs. Only in this way can it be ensured that cyclists remain actively involved in moving their vehicle and EPACs are not classified as motor vehicles.
Position of the bicycle industry
Despite their electric motor assistance, EPACs are vehicles of active mobility. More precise descriptions and technical regulations are needed for EPACs to ensure safety and distinguish clearly between EPACs and motor vehicles subject to type approval. This is particularly the case for the assistance ratio and the maximum assistance power provided by an electric motor.
The assistance ratio relates to the force a cyclist must exert to turn the pedals and crank and the amount of electrical assistance provided by the motor. Cycles that are powered almost entirely by an electric motor requiring virtually no physical effort cannot be classified as EPACs. Cyclists must always be actively involved in making their cycle move.
To give a simple example of the assistance ratio by way of illustration: If a cyclist has a power output of 100 W, an assistance ratio of 1:4 would mean that the electric motor contributes a maximum of four times this power, i.e. 400 W. This would result in a total power output of 500 W at the drive wheel.
This restriction would ensure that EPACs can continue to be classified as vehicles of active mobility and set them apart from purely motor-powered vehicles.
The maximum assistance power is the power that the electric motor provides to help to propel the EPAC – together with the cyclist’s mechanical power. The maximum power must be in a reasonable ratio to the human power input in order to ensure realistic and bicycle-like performance characteristics. A clear distinction must at the same time be maintained from motor vehicles subject to type approval.
Beside this legal distinction, safety also plays an important role. It may become difficult to handle an EPAC if the motor assistance is too high. Limiting the assistance power essentially helps to ensure that EPACs retain their bicycle-like characteristics and do not take on the dynamics of a moped.
Harmonised measurement methods should also be specified for a standardised definition of the performance and characteristics of EPACs and to allow their compliance with the relevant regulations to be checked. Activities to develop a European standard will begin soon.
The assistance ratio relates to the force a cyclist must exert to turn the pedals and crank and the amount of electrical assistance provided by the motor. Cycles that are powered almost entirely by an electric motor requiring virtually no physical effort cannot be classified as EPACs. Cyclists must always be actively involved in making their cycle move.
To give a simple example of the assistance ratio by way of illustration: If a cyclist has a power output of 100 W, an assistance ratio of 1:4 would mean that the electric motor contributes a maximum of four times this power, i.e. 400 W. This would result in a total power output of 500 W at the drive wheel.
This restriction would ensure that EPACs can continue to be classified as vehicles of active mobility and set them apart from purely motor-powered vehicles.
The maximum assistance power is the power that the electric motor provides to help to propel the EPAC – together with the cyclist’s mechanical power. The maximum power must be in a reasonable ratio to the human power input in order to ensure realistic and bicycle-like performance characteristics. A clear distinction must at the same time be maintained from motor vehicles subject to type approval.
Beside this legal distinction, safety also plays an important role. It may become difficult to handle an EPAC if the motor assistance is too high. Limiting the assistance power essentially helps to ensure that EPACs retain their bicycle-like characteristics and do not take on the dynamics of a moped.
Harmonised measurement methods should also be specified for a standardised definition of the performance and characteristics of EPACs and to allow their compliance with the relevant regulations to be checked. Activities to develop a European standard will begin soon.
EPAC parameters
The continuous rated power and maximum assistance speed currently stipulated in Regulation 168/2013 are by all means reasonable and should be retained.
The ZIV is of the opinion that the following additional parameters are characteristic of an EPAC:
Further criteria are currently being explored to differentiate between EPACs and motor vehicles subject to type approval.
The ZIV is of the opinion that the following additional parameters are characteristic of an EPAC:
- support ratio of 1:4 and
- support ratio of 1:6 possible up to max. 15 km/h[4] and
- max. assistance power of 750 W at the drive wheel and
- max. weight of 250 kg for single-track EPAC[5] or
- max. weight of 300 kg for multi-track EPAC[6]
Further criteria are currently being explored to differentiate between EPACs and motor vehicles subject to type approval.
Legal adjustments necessary
For EPACs to continue to be considered equal to muscle-powered bicycles as a means of active mobility and not be subject to type approval, the abovementioned restrictions and requirements must be incorporated into the legal regulations.
We advocate the amendment of Regulation 168/2013 accordingly. Restriction of the maximum assistance power, assistance ratio and maximum total permitted weight could be included in the regulation as an additional description and the «pedal-assisted drive» mentioned in Chapter 1 Article 2 defined more precisely. The content of Section 2(h) would then not need to be changed.
We advocate the amendment of Regulation 168/2013 accordingly. Restriction of the maximum assistance power, assistance ratio and maximum total permitted weight could be included in the regulation as an additional description and the «pedal-assisted drive» mentioned in Chapter 1 Article 2 defined more precisely. The content of Section 2(h) would then not need to be changed.
Footnotes
[1] EN 15194:2017+A1:2023: Cycles – Electrically Power Assisted Cycles – EPAC
[2] Regulation (EU) No 168/2013 of the European Parliament and of the Council of 15 January 2013 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:060:0052:0128:en:PDF
[3] For an explanation of the harmonised standard, see www.dke.de/en/standards-and-specifications.
[4] Implementation and applicability to bicycle types will be specified in the next steps.
[5] Max. weight of 250 kg as per EN 17860-2:2024 for privately used single-track light cargo bikes.
[6] Max. weight of 300 kg as per EN 17860-3:2024 for multi-track light cargo bikes.
[2] Regulation (EU) No 168/2013 of the European Parliament and of the Council of 15 January 2013 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:060:0052:0128:en:PDF
[3] For an explanation of the harmonised standard, see www.dke.de/en/standards-and-specifications.
[4] Implementation and applicability to bicycle types will be specified in the next steps.
[5] Max. weight of 250 kg as per EN 17860-2:2024 for privately used single-track light cargo bikes.
[6] Max. weight of 300 kg as per EN 17860-3:2024 for multi-track light cargo bikes.
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Document created | 07.04.25