Questions about e-bikes/EPACS – and some answers
With almost 16 million e-bikes (defined legally as «EPACs») 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, EPACs must retain their status as bicycles and vehicles of active mobility. Accordingly, the ZIV proposes more precise definition of the assistance ratio in the drive systems of EPACs.
We answer the question of how the ZIV came upon the standards it is proposing along with other questions that have come up frequently in recent discussions on this subject in these FAQs:
We answer the question of how the ZIV came upon the standards it is proposing along with other questions that have come up frequently in recent discussions on this subject in these FAQs:
Overview
Why are new regulations needed? Aren’t there already enough laws and standards for EPACs?
What is the European Commission planning?
Why should new thresholds be set for the power output, weight and assistance ratio?
Why does the ZIV propose a maximum assistance power of 750 W? How was this value determined?
What about heavy cargo bikes for commercial uses? Is the assistance power of 750 W also sufficient for these?
Will limitation of the maximum assistance power jeopardise safety, for example when transporting cargo in hilly areas?
Will the planned limitation of the power output be disadvantageous to children, senior citizens and people with disabilities?
Will this prevent technical innovations?
Will the criteria the ZIV is proposing benefit the entire bicycle industry or will manufacturers of certain types of motor have an advantage?
Will the criteria the ZIV is proposing hinder the mobility transition?
Is the industry restricting itself with new regulations rather than campaigning for greater freedom?
What is the European Commission planning?
Why should new thresholds be set for the power output, weight and assistance ratio?
Why does the ZIV propose a maximum assistance power of 750 W? How was this value determined?
What about heavy cargo bikes for commercial uses? Is the assistance power of 750 W also sufficient for these?
Will limitation of the maximum assistance power jeopardise safety, for example when transporting cargo in hilly areas?
Will the planned limitation of the power output be disadvantageous to children, senior citizens and people with disabilities?
Will this prevent technical innovations?
Will the criteria the ZIV is proposing benefit the entire bicycle industry or will manufacturers of certain types of motor have an advantage?
Will the criteria the ZIV is proposing hinder the mobility transition?
Is the industry restricting itself with new regulations rather than campaigning for greater freedom?
Why are new regulations needed? Aren’t there already enough laws and standards for EPACs?
There is indeed already a regulatory framework in place for electric bicycles – or to be more precise, for electrically power assisted cycles (EPACs). Section 2(h) of EU Regulation 168/2013 explicitly exempts EPACs from the requirement for type approval if they meet certain technical criteria. Their legal equivalence with purely muscle-powered bicycles is key to the successful spread of EPACs in Europe and enables numerous freedoms: no mandatory insurance; no helmet obligation; the option of using cycle paths and forest tracks, transporting children and attaching a bike trailer; and, above all, unrestricted usage in everyday life and for leisure.
This success also brings new challenges, however. While EPACs hardly differ from muscle-powered bicycles in their appearance, the technology they contain continues to evolve at a rapid pace. Ever more powerful drive systems, rising overall weights and increasingly dynamic riding behaviour mean that the boundaries between bicycles and motor vehicles are becoming increasingly blurred. Vehicles whose classification is in a regulatory grey area are essentially being created that are considered EPACs formally, but are in fact more similar to mopeds in terms of their technical design – with a correspondingly higher risk potential and scope for conflict with other cyclists.
It is for this reason that more precise legal regulations are needed – not to limit the success of EPACs, but rather to ensure it in the long term. The aim is to safeguard active mobility – meaning that cyclists actively propel their vehicle. The more they pedal, the greater the assistance. Physical activity (i.e. pedalling) remains necessary for the electric motor to work. This is what sets EPACs apart from motor vehicles. Active mobility is not only beneficial to users’ health but also central to sustainable transport policy.
New regulations would help to safeguard this status. They would clarify which technical criteria an EPAC must meet, such as a reasonable ratio between pedal power and motor assistance, limitation of the maximum assistance power and an appropriate overall weight. These technical guidelines would help in the differentiation from other vehicle categories and prevent a «performance competition».
In the e-bike sector, innovations are all too often equated with more power – this doesn’t capture their full scope however. More power doesn’t automatically mean greater progress. Quite the contrary in fact: focusing exclusively on ever more powerful motors can jeopardise the status of EPAC as vehicles of active mobility on a par with muscle-powered bicycles and, in the long term, lead to a shift in the technology and legal status towards mopeds. The freedom their classification as bicycles offers would then be lost.
A clearly defined technical framework wouldn’t restrict innovation. Rather, it would create the basis for innovation where it would be of the greatest social benefit: in safety, sustainability, user-friendliness and integration into the mobility system of the future.
This success also brings new challenges, however. While EPACs hardly differ from muscle-powered bicycles in their appearance, the technology they contain continues to evolve at a rapid pace. Ever more powerful drive systems, rising overall weights and increasingly dynamic riding behaviour mean that the boundaries between bicycles and motor vehicles are becoming increasingly blurred. Vehicles whose classification is in a regulatory grey area are essentially being created that are considered EPACs formally, but are in fact more similar to mopeds in terms of their technical design – with a correspondingly higher risk potential and scope for conflict with other cyclists.
It is for this reason that more precise legal regulations are needed – not to limit the success of EPACs, but rather to ensure it in the long term. The aim is to safeguard active mobility – meaning that cyclists actively propel their vehicle. The more they pedal, the greater the assistance. Physical activity (i.e. pedalling) remains necessary for the electric motor to work. This is what sets EPACs apart from motor vehicles. Active mobility is not only beneficial to users’ health but also central to sustainable transport policy.
New regulations would help to safeguard this status. They would clarify which technical criteria an EPAC must meet, such as a reasonable ratio between pedal power and motor assistance, limitation of the maximum assistance power and an appropriate overall weight. These technical guidelines would help in the differentiation from other vehicle categories and prevent a «performance competition».
In the e-bike sector, innovations are all too often equated with more power – this doesn’t capture their full scope however. More power doesn’t automatically mean greater progress. Quite the contrary in fact: focusing exclusively on ever more powerful motors can jeopardise the status of EPAC as vehicles of active mobility on a par with muscle-powered bicycles and, in the long term, lead to a shift in the technology and legal status towards mopeds. The freedom their classification as bicycles offers would then be lost.
A clearly defined technical framework wouldn’t restrict innovation. Rather, it would create the basis for innovation where it would be of the greatest social benefit: in safety, sustainability, user-friendliness and integration into the mobility system of the future.
What is the European Commission planning?
The European Commission has already announced that it will revise the regulations on light electric vehicles (including EPACs) as part of new legislation on personal mobility devices (PMD). Fundamental revision of the existing legal framework is thus imminent.
We also see this revision as proactive preparation for possible future European legislation for which preliminary discussions are currently underway on the EU level. To ensure that EPACs continue to be considered bicycles in the future, the technical criteria must first be defined more clearly – in such a way that their safety and traffic law advantages are retained.
In short, the existing regulations were a good start. However, to continue the EPAC success story and maintain their special status as an active, healthy and free means of transport, they must be adapted to today’s realities and technical developments.
We also see this revision as proactive preparation for possible future European legislation for which preliminary discussions are currently underway on the EU level. To ensure that EPACs continue to be considered bicycles in the future, the technical criteria must first be defined more clearly – in such a way that their safety and traffic law advantages are retained.
In short, the existing regulations were a good start. However, to continue the EPAC success story and maintain their special status as an active, healthy and free means of transport, they must be adapted to today’s realities and technical developments.
Why should new thresholds be set for the power output, weight and assistance ratio?
The proposed parameters for the maximum power output, overall weight and assistance ratio are not intended to restrict, but rather to precisely define what constitutes an EPAC – and thus help to maintain its legal status as a bicycle.
To date, EU legislation such as Regulation 168/2013 have only defined EPACs based on a handful of criteria: assistance only when pedalling, maximum continuous rated power of 250 W, assistance cuts out at 25 km/h. In practice, it has become clear that these criteria alone are no longer sufficient to clearly and comprehensibly distinguish EPACs from motor vehicles. Ever more powerful drive systems, increasing overall weights and, in some cases, high assistance ratios mean that some vehicles are formally classified as EPACs, but are in fact very different from muscle-powered bicycles in terms of their riding behaviour and effect.
Additional technical guidelines are therefore needed that for example define:
At the same time, they would prevent EPACs from developing unchecked into motor vehicles. In the medium to long term, such a trend could lead to the entire EPAC category being re-evaluated from a regulatory perspective, with mandatory insurance, a helmet obligation and restrictions on the use of infrastructure, for example. This is exactly what needs to be prevented.
The new criteria wouldn’t create an artificial barrier, but rather ensure the integrity, safety and future viability of EPACs – and thus also their social acceptance as a form of sustainable mobility.
To date, EU legislation such as Regulation 168/2013 have only defined EPACs based on a handful of criteria: assistance only when pedalling, maximum continuous rated power of 250 W, assistance cuts out at 25 km/h. In practice, it has become clear that these criteria alone are no longer sufficient to clearly and comprehensibly distinguish EPACs from motor vehicles. Ever more powerful drive systems, increasing overall weights and, in some cases, high assistance ratios mean that some vehicles are formally classified as EPACs, but are in fact very different from muscle-powered bicycles in terms of their riding behaviour and effect.
Additional technical guidelines are therefore needed that for example define:
- an assistance ratio that ensures users are are still actively involved in propelling their vehicle;
- a reasonable maximum assistance power that ensures controlled, bike-like riding behaviour;
- upper limits for the overall weight to ensure that the dynamics and handling still correspond to that of a bicycle.
At the same time, they would prevent EPACs from developing unchecked into motor vehicles. In the medium to long term, such a trend could lead to the entire EPAC category being re-evaluated from a regulatory perspective, with mandatory insurance, a helmet obligation and restrictions on the use of infrastructure, for example. This is exactly what needs to be prevented.
The new criteria wouldn’t create an artificial barrier, but rather ensure the integrity, safety and future viability of EPACs – and thus also their social acceptance as a form of sustainable mobility.
Why does the ZIV propose a maximum assistance power of 750 W? How was this value determined?
The proposed maximum assistance power of 750 watts is not an arbitrary value. Rather, it is based on international standards and serves to clearly differentiate between EPACs and motor vehicles requiring type approval.
The 750 watt limitation has been the standard in the USA for many years now: e-bikes in Classes 1–3 with motor power of up to 750 W (equivalent to 1 HP) can be ridden without registration or a driving licence, provided that they comply with certain speed restrictions and don’t exceed the permitted pedal assistance. This value has proven to be a practical compromise between performance, safety and regulatory convenience and is widely accepted in the market.
Introducing a comparable performance threshold in Europe would make it easier to classify EPACs and also to compare them internationally.
Important here is that the 750 W refers to the maximum assistance power at the drive wheel, not to the thermally defined «nominal continuous power» of 250 W, which remains the limit for legal classification as an EPAC (as per EU Regulation 168/2013). Thus, the 750 W limit helps to define the scope for manoeuvre without jeopardising the legal status.
The 750 watt limitation has been the standard in the USA for many years now: e-bikes in Classes 1–3 with motor power of up to 750 W (equivalent to 1 HP) can be ridden without registration or a driving licence, provided that they comply with certain speed restrictions and don’t exceed the permitted pedal assistance. This value has proven to be a practical compromise between performance, safety and regulatory convenience and is widely accepted in the market.
Introducing a comparable performance threshold in Europe would make it easier to classify EPACs and also to compare them internationally.
Important here is that the 750 W refers to the maximum assistance power at the drive wheel, not to the thermally defined «nominal continuous power» of 250 W, which remains the limit for legal classification as an EPAC (as per EU Regulation 168/2013). Thus, the 750 W limit helps to define the scope for manoeuvre without jeopardising the legal status.
What about heavy cargo bikes for commercial uses? Is the assistance power of 750 W also sufficient for these?
New legal regulations are required for cargo bikes with a permissible overall weight of more than 300 kg that are used commercially. The ZIV recognises that these vehicles have their own requirements, both in terms of engine performance and their brakes as well as their stability and handling. The ZIV therefore proposes developing suitable parameters for these «commercial cargo bikes». Within the e-bike/EPAC segment, a reasonable upper limit is necessary to ensure that the bicycle character is not undermined.
Will limitation of the maximum assistance power jeopardise safety, for example when transporting cargo in hilly areas?
No, quite the contrary in fact. Targeted limitation can prevent EPACs from becoming unstable or uncontrollable. On hills, not only a bike’s performance is decisive, but also the interplay between weight, gear ratio and riding dynamics. Rather than extending the existing bicycle regulations to quasi-motorised and non-bicycle-like vehicles, new categories are needed for heavy bicycles.
Will the planned limitation of the power output be disadvantageous to children, senior citizens and people with disabilities?
Limiting the performance means limiting the vehicle’s maximum assistance ratio and electrical power, not the individual assistance for weaker riders. Cyclists must still actively propel their vehicle. Specialised vehicles for special requirements (for example, to enable inclusion) require their own technical categories and adapted regulations. These vehicles may no longer be defined as EPACs, but should still receive regulatory support – albeit in a different way.
Will this prevent technical innovations?
In the e-bike sector, innovations are all too often equated with more power – this doesn’t capture their full scope however. More power doesn’t automatically mean greater progress. Quite the contrary in fact: focusing exclusively on ever more powerful motors can jeopardise the status of EPAC as vehicles of active mobility on a par with muscle-powered bicycles and, in the long term, lead to a shift in the technology and legal status towards mopeds.
These days, innovation is actually taking place in other areas, including:
A clearly defined technical framework does not restrict innovation but rather creates the basis for innovation where it would be of the greatest social benefit: in safety, sustainability, user-friendliness and integration into the mobility system of the future.
These days, innovation is actually taking place in other areas, including:
- drive system efficiency;
- use of new materials;
- improved ergonomics for different user groups;
- further development of the riding dynamics, for example through intelligent sensor technology or optimised frame designs;
- digitalisation, for example through smart controls, networking, theft protection, over-the-air updates or integrated service functions.
A clearly defined technical framework does not restrict innovation but rather creates the basis for innovation where it would be of the greatest social benefit: in safety, sustainability, user-friendliness and integration into the mobility system of the future.
Will the criteria the ZIV is proposing benefit the entire bicycle industry or will manufacturers of certain types of motor have an advantage?
The ZIV represents the interests of its member companies, but also of the entire bicycle industry. From production through retail to the end consumers, it keeps sight of the interests of the entire bicycle industry. The proposed regulations are based on safety and riding dynamics considerations as well as politically realistic limits, not on the interests of individual companies. The aim is to preserve the EPAC – whether with a centre, hub or hybrid drive. Healthy market diversity and technological openness to more innovation will remain possible – within a defined regulatory framework.
Will the criteria the ZIV is proposing hinder the mobility transition?
No, on the contrary, the ZIV’s proposal will support and safeguard the mobility transition as it will preserve what has made EPACs so successful: their legal equivalence to bicycles and, with this, their suitability for everyday use by millions of people.
Today, more than 16 million people in Germany already use an EPAC – to travel to work, transport children, do their shopping or go on leisure trips. What they appreciate about it is not just the electrical assistance, but also what must be retained: the freedom to ride on cycle paths, no helmet obligation, no mandatory insurance, no type approval, no obstacles to everyday life. And last but not least, the enjoyment in cycling. More than almost any other vehicle, EPACs stand for active and healthy mobility that is both accessible and fun.
It is precisely these characteristics that the ZIV proposal ensures – through clear yet moderate technical guidelines. Without more precise definitions, there is a real danger that the market will develop in a direction in which vehicles classified as «EPACs» will be used that actually resemble mopeds more. So, motor vehicles rather than bicycles in terms of their riding dynamics, motor performance and weight. This would not only affect cyclists’ feeling of safety on cycle paths, but could also lead to a regulatory reassessment in the medium term – with far-reaching consequences: insurance and helmet obligations, restrictions on use and the loss of status as an active means of transport.
The proposed restrictions on motor performance, assistance ratio and weight are based on the actual usage behaviour and technical values of the vast majority of vehicles on the market today. The industry is not ruling out any tried-and-tested systems, but merely is defining what an EPAC is and should remain at its core: a safe, active and human-centred vehicle that gets people moving and at the same time facilitates mobility.
Last but not least, the proposal also sends a clear message to politicians – on both the national and European levels. It shows that the bicycle industry is taking responsibility and wants to help shape the future.
The ZIV’s proposal isn’t an obstacle, but rather acts as a safeguard for the mobility transition. It protects EPACs as we know and appreciate them today and ensures that they remain a free, healthy and fun means of transport for everyone in the future.
Today, more than 16 million people in Germany already use an EPAC – to travel to work, transport children, do their shopping or go on leisure trips. What they appreciate about it is not just the electrical assistance, but also what must be retained: the freedom to ride on cycle paths, no helmet obligation, no mandatory insurance, no type approval, no obstacles to everyday life. And last but not least, the enjoyment in cycling. More than almost any other vehicle, EPACs stand for active and healthy mobility that is both accessible and fun.
It is precisely these characteristics that the ZIV proposal ensures – through clear yet moderate technical guidelines. Without more precise definitions, there is a real danger that the market will develop in a direction in which vehicles classified as «EPACs» will be used that actually resemble mopeds more. So, motor vehicles rather than bicycles in terms of their riding dynamics, motor performance and weight. This would not only affect cyclists’ feeling of safety on cycle paths, but could also lead to a regulatory reassessment in the medium term – with far-reaching consequences: insurance and helmet obligations, restrictions on use and the loss of status as an active means of transport.
The proposed restrictions on motor performance, assistance ratio and weight are based on the actual usage behaviour and technical values of the vast majority of vehicles on the market today. The industry is not ruling out any tried-and-tested systems, but merely is defining what an EPAC is and should remain at its core: a safe, active and human-centred vehicle that gets people moving and at the same time facilitates mobility.
Last but not least, the proposal also sends a clear message to politicians – on both the national and European levels. It shows that the bicycle industry is taking responsibility and wants to help shape the future.
The ZIV’s proposal isn’t an obstacle, but rather acts as a safeguard for the mobility transition. It protects EPACs as we know and appreciate them today and ensures that they remain a free, healthy and fun means of transport for everyone in the future.
Is the industry restricting itself with new regulations rather than campaigning for greater freedom?
What at first glance appears to be self-imposed restriction is actually a deliberate strategy to preserve freedom – the freedom that EPACs already enjoy today: use of the bicycle infrastructure, no mandatory insurance or type approval, no helmet obligation, transport of children and luggage – in short, complete legal equivalence with muscle-powered bicycles.
This equivalence is no coincidence though, but rather is based on the technical specifications laid out in EU Regulation 168/2013, in particular restriction of the motor performance (250 W nominal continuous power) and assistance (up to max. 25 km/h) – combined with active pedalling. This is precisely where grey areas are increasingly emerging however. It is difficult to equate some of the vehicles currently on the market with EPACs – and therefore also with muscle-powered bicycles – due to their design (size and weight) or riding behaviour (high peak power, no pedal power required). This threatens to dilute the classification – and consequently to lead to re-evaluation of the entire EPAC segment by politicians and authorities.
The proposed criteria don’t represent a blanket restriction, but rather an appropriate specification of existing requirements. And they don’t restrict most of the systems currently available on the market. The vast majority of drives are currently significantly below the proposed criteria, for example in terms of the maximum assistance power. The aim is not to ban existing solutions, but to create a reliable framework for the future.
At the same time, this anticipatory position ensures planning security for manufacturers and market surveillance. It strengthens the trust of authorities, politicians and consumers in the industry’s integrity and prevents sweeping and possibly excessive regulation by external parties.
Last but not least, the bicycle industry positions itself with this step as a responsible stakeholder that defines the success of EPACs not through short-term technical limitations, but rather through their long-term social acceptance as an active, safe, sustainable means of transport. Only clear regulations can prevent EPACs from being classified as motor vehicles – with all the consequences this would bring for users, infrastructure and the market.
In short, the industry is not limiting itself, but rather protecting what has made EPACs such a success.
This equivalence is no coincidence though, but rather is based on the technical specifications laid out in EU Regulation 168/2013, in particular restriction of the motor performance (250 W nominal continuous power) and assistance (up to max. 25 km/h) – combined with active pedalling. This is precisely where grey areas are increasingly emerging however. It is difficult to equate some of the vehicles currently on the market with EPACs – and therefore also with muscle-powered bicycles – due to their design (size and weight) or riding behaviour (high peak power, no pedal power required). This threatens to dilute the classification – and consequently to lead to re-evaluation of the entire EPAC segment by politicians and authorities.
The proposed criteria don’t represent a blanket restriction, but rather an appropriate specification of existing requirements. And they don’t restrict most of the systems currently available on the market. The vast majority of drives are currently significantly below the proposed criteria, for example in terms of the maximum assistance power. The aim is not to ban existing solutions, but to create a reliable framework for the future.
At the same time, this anticipatory position ensures planning security for manufacturers and market surveillance. It strengthens the trust of authorities, politicians and consumers in the industry’s integrity and prevents sweeping and possibly excessive regulation by external parties.
Last but not least, the bicycle industry positions itself with this step as a responsible stakeholder that defines the success of EPACs not through short-term technical limitations, but rather through their long-term social acceptance as an active, safe, sustainable means of transport. Only clear regulations can prevent EPACs from being classified as motor vehicles – with all the consequences this would bring for users, infrastructure and the market.
In short, the industry is not limiting itself, but rather protecting what has made EPACs such a success.