Response to the call by Deutsche Umwelthilfe (DUH) for a standardised charging system for EPACs
15 July 2025
In a position paper published in June 2025, the German environmental action association Deutsche Umwelthilfe (DUH) calls for the EU-wide introduction of a mandatory standardised charger for electrically assisted bicycles (EPACs) based on the EnergyBus system. In the opinion of the ZIV, this is not practical, appropriate for the market or sustainable.
In a position paper published in June 2025, the German environmental action association Deutsche Umwelthilfe (DUH) calls for the EU-wide introduction of a mandatory standardised charger for electrically assisted bicycles (EPACs) based on the EnergyBus system. In the opinion of the ZIV, this is not practical, appropriate for the market or sustainable.
Standardised charging systems only worthwhile in specific cases
The ZIV and its more than 140 member companies are not fundamentally opposed to a standardised system. For certain uses – in the tourism sector or for commercial fleets, for example – a uniform and standardised charging system could prove helpful. However, a debate based on the actual facts is needed that also takes safety aspects and the technical and economic characteristics of EPACs into account. Licensing requirements exist for the EnergyBus system called for by the DUH in its position paper. The DUH’s proposal fails to recognise significant innovations in the field of electric bicycles. It is not without reason that the EnergyBus system has failed to gain in market relevance despite existing for more than a decade.
1. E-bikes the biggest success in the mobility transition
16 million e-bikes are today on the roads in Germany. This is by far the largest fleet of electric vehicles in Europe. In total, there are over 30 million e-bikes in Europe. No other electric vehicle is even remotely as prevalent and no other vehicle fleet is anywhere near as large. All available data shows that people use e-bikes extensively, both in their everyday lives and for leisure. At the same time, it is becoming increasingly clear that e-bikes are far more durable than expected. The first generation of e-bikes is now significantly older than the five to eight years originally projected – and continue to be used extensively. The e-bikes themselves, along with their engines and batteries, are proving to be very durable.
2. Public e-bike charging stations not a success – and never have been
Everyday journeys are short and every cyclist has a private charging facility waiting for them at home. The 2023 national survey on mobility in Germany[1] revealed that cyclists’ daily commute is an average of 35 kilometres in length. Any e-bike available on the market today can cover this distance without needing to be recharged, even in topographically challenging settings – and can actually often cover far greater distances.
The lion’s share of the 16 million e-bikes in Germany are currently far more likely to be found in rural areas than they are in cities. The 2023 survey on mobility in cities (SRV 2023)[2] confirms that EPACs are used more in rural areas and the everyday journeys are also longer there. This essentially means that EPACs are most successful where no public charging infrastructure is available.
The 2024 ADFC Bicycle Travel Analysis[3] found that cycle tourists cover an average of 44 km during single-day trips and 62 km during multi-day trips. These distances can easily be covered without having to stop to charge the e-bike, whereby their range is expected to increase further in the coming years thanks to improvements in battery performance. The success of EPACs is therefore not based on a public charging infrastructure, but rather on decentralised, flexible and private charging. More than ninety percent of all charging takes place at home or at work where users use the charger designed specifically for their battery.[4] Thus the reality shows that the need for public charging facilities is minimal. The construction and maintenance of such charging stations is not only complex, but also costly and space-intensive. Despite this, the DUH claims that a standardised plug is a prerequisite for e-bikes to be a success – an unsubstantiated theory that contradicts all market experience. EPACs also even work with an empty battery – almost as effectively as any non-motorised bicycle. This makes them fundamentally different from other electrically powered vehicles and contradicts the call for public charging infrastructure.
The lion’s share of the 16 million e-bikes in Germany are currently far more likely to be found in rural areas than they are in cities. The 2023 survey on mobility in cities (SRV 2023)[2] confirms that EPACs are used more in rural areas and the everyday journeys are also longer there. This essentially means that EPACs are most successful where no public charging infrastructure is available.
The 2024 ADFC Bicycle Travel Analysis[3] found that cycle tourists cover an average of 44 km during single-day trips and 62 km during multi-day trips. These distances can easily be covered without having to stop to charge the e-bike, whereby their range is expected to increase further in the coming years thanks to improvements in battery performance. The success of EPACs is therefore not based on a public charging infrastructure, but rather on decentralised, flexible and private charging. More than ninety percent of all charging takes place at home or at work where users use the charger designed specifically for their battery.[4] Thus the reality shows that the need for public charging facilities is minimal. The construction and maintenance of such charging stations is not only complex, but also costly and space-intensive. Despite this, the DUH claims that a standardised plug is a prerequisite for e-bikes to be a success – an unsubstantiated theory that contradicts all market experience. EPACs also even work with an empty battery – almost as effectively as any non-motorised bicycle. This makes them fundamentally different from other electrically powered vehicles and contradicts the call for public charging infrastructure.
3. Standardised chargers don’t offer any sustainability benefits
The DUH justifies its call for a standardised charger among others with the aim of avoiding electronic waste and improving sustainability. Both of these arguments do not hold up however. In the e-bike sector, a universal charger might not actually automatically mean resources are saved – and could in fact have the reverse effect. Chargers optimised to the corresponding system are more efficient and use resources more sparingly: the voltage, current, charging behaviour and safety features of charger are today attuned to the respective battery and energy management system. In contrast, a universal charger would have to be designed for all eventualities (e.g. fast charging, high currents, communication). Significantly more materials would then be needed to create larger housing, a higher cooling capacity, larger components, more complex safety mechanisms – even where these are not technically necessary. Compared to other electronic devices, e-bike charger have a significantly longer service life and don’t need to be replaced as frequently. This also means that there is no comparable problem with a surplus of charger like there is with consumer electronics.
Unlike smartphones, tablets or consumer electronics, which are replaced frequently, EPACs and their charger are used for ten or more years. There is no excess of chargers like we know from consumer electronics. The charger remains with the product and often also accompanies it when it gains a new lease of life (second-hand market, refurbishment).
Unlike smartphones, tablets or consumer electronics, which are replaced frequently, EPACs and their charger are used for ten or more years. There is no excess of chargers like we know from consumer electronics. The charger remains with the product and often also accompanies it when it gains a new lease of life (second-hand market, refurbishment).
4. The right charger for the right bike
A huge variety of e-bikes is available on the market today. For many years, customers above all favoured bikes with a long range and heavy drive systems. There are now also a great many lighter bikes with smaller drive systems, cargo bikes with powerful drive systems and bikes for special needs. The charging systems for these bikes have been optimised for their respective use. A standardised charger would undermine the energy-efficient system design: these days, manufacturers invest considerable resources in developing integrated systems consisting of a battery, a battery management system (BMS) and a charger to maximise safety, service life and energy efficiency. Compelling the use of a universal charger would disrupt this industrial system approach and lead to less efficient, sub-optimal systems. This would in turn have clear disadvantages for the environment, safety and user-friendliness.
5. EnergyBus has not established itself on the market for over a decade
EnergyBus is not a new system. Though it has existed for more than ten years now, it has not been able to establish itself on the market. It is not used to a significant extent, either by OEMs or in the end customer market. Despite this, the DUW claims that it is the «best available system». The reality to date proves exactly the opposite though, however. An outdated system that has not been adopted in series or on a wider scale in over ten years is not a suitable future basis for an EU-wide legal obligation.
6. EnergyBus is not an open system but rather a commercial licence model
The EnergyBus system that the DUH proposes is not freely accessible. Rather, it is tied to a complex, multi-stage licensing and testing regime. Manufacturers must pay licence fees, have each individual product certified, apply for identification numbers and be a member of the responsible entity to obtain detailed specifications. This essentially means costs, dependence and bureaucracy – for every charger and battery. The FRAND principle of fair, reasonable, non-discriminatory access is used here as a smokescreen to conceal a proprietary business model. Such a system contradicts the principles of open, competition-friendly regulation in Europe. The DUH is effectively calling for legally imposed market protectionism, which favours one single system that lacks sufficient support – and that is an industrial policy blunder waiting to happen.
7. EnergyBus goes far beyond charging – and jeopardises technological diversity
Particularly concerning is that EnergyBus will not only prescribe a charging system, but also a comprehensive communication protocol for the entire EPAC system. It will dictate how the battery, charger, engine, display, controls, sensors and other components communicate – with the aim of achieving completeness and interoperability within the EnergyBus ecosystem. Such a system would effectively mean the mandatory integration of all EPAC components into one specific communication protocol, significant restriction of the choice of engines, displays, sensors, etc., as well as considerable obstacles to innovation, especially for start-ups, new component manufacturers or highly specialised suppliers. A mandatory charger, which simultaneously dictates the central coordination of all EPAC components, would force e-bike development in Europe into a technological monoculture – with serious consequences for diversity, safety, individualisation and innovation.
8. EnergyBus and IEC TS 61851-3-x are overly complex LEV solutions that are technically unsuitable for EPACs
The charging system that the DUH is calling for is based on specifications (among others, the EnergyBus profile family and the IEC TS 61851-3-x series) that were originally designed for light electric vehicles (LEVs) with significantly higher power requirements, so not for EPACs that are exempt from type approval (up to 25 km/h, max. engine output of 250 W). The specifications are not standards and do not necessarily cover all generally recognised requirements or require the broad consensus of all stakeholders.[5]
The specifications stipulate high voltages (up to >60 V), currents and charging power levels that are not required for EPACs. This overengineering would lead to an unnecessarily complex electrical design for the charging system, larger connectors and cables as well as an overall bulky design for the charger. This is especially problematic for e-bikes with an integrated locking system for public charging. The system architecture would make a disproportionately large charger necessary that is difficult to integrate into the bike. This would in turn have a negative impact on design freedom, ergonomics, weather resistance and overall system costs.
The required mechanical interface would simply not be practicable for EPACs with limited installation space – especially compact frame shapes, lightweight urban models, children’s bikes or cargo bikes with enclosed electronics. A mandatory charger based on this technical standard would mean that every EPAC would need to be equipped with components that were actually developed for entirely different vehicle classes – with no clear advantages.
The specifications stipulate high voltages (up to >60 V), currents and charging power levels that are not required for EPACs. This overengineering would lead to an unnecessarily complex electrical design for the charging system, larger connectors and cables as well as an overall bulky design for the charger. This is especially problematic for e-bikes with an integrated locking system for public charging. The system architecture would make a disproportionately large charger necessary that is difficult to integrate into the bike. This would in turn have a negative impact on design freedom, ergonomics, weather resistance and overall system costs.
The required mechanical interface would simply not be practicable for EPACs with limited installation space – especially compact frame shapes, lightweight urban models, children’s bikes or cargo bikes with enclosed electronics. A mandatory charger based on this technical standard would mean that every EPAC would need to be equipped with components that were actually developed for entirely different vehicle classes – with no clear advantages.
9. Standardisation needs flexibility, not rigid regulation
The EU Battery Regulation envisions the development of a charging system for LMT batteries through standardisation involving all interested stakeholders, rather than by imposing regulations. This is exactly what we also call for: a fact-based, technology-open debate within European standardisation committees involving all relevant stakeholders – industry, standardisation bodies, market surveillance authorities, consumer associations and public authorities.
Attempting to use political pressure to impose a technical solution that has not gained widespread acceptance, been tested technically or proven marketable undermines the legitimacy of an orderly standardisation process and damages the credibility of regulatory processes within the EU.
Attempting to use political pressure to impose a technical solution that has not gained widespread acceptance, been tested technically or proven marketable undermines the legitimacy of an orderly standardisation process and damages the credibility of regulatory processes within the EU.
10. Charge2Bike as the technical basis for standardisation – practical, backward compatible and open
In contrast to EnergyBus, Charge2Bike (developed by the CHAdeMO consortium) is today already a viable option that could serve as the technical basis for future standardisation of a uniform charging system for e-bikes. Developed specifically for EPACs, the system is mechanically and electrically robust, can easily be integrated into existing infrastructures and offers a viable basis for interoperable solutions. Another key advantage of Charge2Bike is its backward compatibility: millions of e-bikes already on the market can safely be connected to compatible chargers or charging points using an adapter solution that complies with the standards. This capability is a key component for the success of any future charging infrastructure – and missing entirely from the EnergyBus concept. What is more, such a charging system defined in a future standard can be used without a licence, is supported by manufacturers, is free of proprietary restrictions and has already been tested in pilot projects. The ZIV and its member companies therefore call for Charge2Bike to be used as the starting point for developing a European standard. All relevant stakeholders (industry, municipalities, consumer associations, safety authorities) should work together to conceive a technically feasible, economically viable and future-proof charging system for public use – with optional (but not mandatory) implementation.
Conclusion
The more than 16 million EPACs on the roads in Germany are impressive proof that a standardised charger isn’t actually necessary for success. E-bikes work on the market, sell in their millions, are safe and durable – even without public charging infrastructure or standardised plugs.
The bicycle industry therefore advocates:
The bicycle industry therefore advocates:
- an open European standardisation process
- involving all relevant interest groups
- with the aim of developing an interoperable, backward-compatible, robust and economically viable charging system.
- stipulation of a specific mandatory charger for all EPACs;
- establishment of proprietary systems with licensing models like the DUH is calling for;
- transfer of regulatory concepts from consumer electronics to safety-critical battery systems in the bicycle sector. The DUH fails in its proposal to recognise key aspects of the market environment for EPACs, technological developments and the proven reality of standardisation.
- hinder innovation;
- destroy technological diversity;
- distort competition;
- force thousands of companies into a licensing and communication system that does not reflect the current state of technology.
Footnotes
[1] www.mobilitaet-in-deutschland.de/publikationen2023.html
[2] https://tu-dresden.de/bu/verkehr/ivs/srv/srv-2023#intro
[3] www.adfc.de/artikel/adfc-radreiseanalyse-2024-die-ergebnisse
[4] The Charging Behaviour of Private Electric Vehicles; https://encyclopedia.pub/entry/52419
[5] www.dke.de/de/normen-standards/grundlagen-der-normung
[2] https://tu-dresden.de/bu/verkehr/ivs/srv/srv-2023#intro
[3] www.adfc.de/artikel/adfc-radreiseanalyse-2024-die-ergebnisse
[4] The Charging Behaviour of Private Electric Vehicles; https://encyclopedia.pub/entry/52419
[5] www.dke.de/de/normen-standards/grundlagen-der-normung
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Version history
In light of ongoing developments, this paper is a living document that will be adapted/updated as necessary.
Document created | 15.07.25
Document created | 15.07.25