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The most common safety risks that we come across in our daily work around bicycle safety, technology and operating instructions are also published by us in articles in the leading German special-interest magazines TOUR (Europe's road bike magazine no. 1), BIKE (Europe's mountain bike magazine no. 1), MYBIKE and EMTB in order to make this information, which is important for the industry, available to a wider public.

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Associations focus on e-bike tuning

It’s a well known problem in the industry and world of cycling: For many users a speed of 25 kmh/15.5 mph is felt to be too slowly. They therefore are tempted to tune. Two new guidelines make clear why this is a very bad idea.

The trade associations of the cycling industry from industry, commerce and trade have published two new guidelines dealing with the “Risks related to e-bike 25 (15.5) / EPAC tuning” and the “Risks related to retrofitting bicycles with e-drives“. Considering supply and demand and with a view to the consequences, there is a clear need for clarification on both topics from the associations' point of view.
Many users seem to be unaware of the serious consequences, including criminal offences, especially in the case of tuning. Retrofitting bicycles with e-drives is another topic that is regarded as critical by the experts in view of the existing technical standards and requirements.
While from the experts’ point of view, retrofitting a motor is more of a specialist topic for workshops, tuning, i.e. increasing the maximum design speed of electric bikes, is primarily about sensitising broad awareness among consumers. As according to the experts’ experience the suppliers of tuning kits do not provide their customers with sufficient information.
Often, it’s only mentioned in the small print that the use of such kits is not permitted on public roads. There is not a single word said to indicate that use in general can be dangerous, as the bicycle components are not designed for a higher permanent load. “Riding without driving licence” or “Driving without insurance protection” on public roads can be particularly serious.
An important fact to know:
EPACs with tuning kits are no longer electric bicycles, but motor vehicles that are moved in traffic without insurance protection and not allowed to be ridden for example on bicycle lanes. The trade associations of the cycle industry, together with the industry, have been campaigning for years to make tuning as difficult as possible and to inform users about the state of facts and the dangers.
Tuning renders e-bikes 25 kmh/15.5 mph and EPACs in motor vehicles:
E-bikes 25 (15.5)/EPACs are limited to a continuous rated power of 250 watts and a maximum design speed through electrical pedal assistance of max. 25 kmh (15.5 mph). In this case only they are equivalent to bicycles in accordance with the road traffic law (section 63a (2) of the German road traffic licensing regulations.
Raising the output and/or the maximum design speed beyond this limit will result in the fact that the bicycle becomes a motor vehicle in terms of traffic law. This results in severe consequences:
  • Subject to compulsory operating licence (individual approval by authorised test centre)
  • Subject to compulsory driving licence (class depends on maximum speed)
  • Subject to compulsory insurance (insurance tag)
  • Helmet compulsory
  • Using cycle lanes not permissible
  • Proof of fatigue strength for all safety-relevant components
Possible legal consequences for users in case of tuning:
  • Administrative offence and penalty
  • Criminal offence (section 21 of German road traffic act: “Riding without driving licence”; section 6 of PflVG (Law on compulsory insurance for motor vehicle holders: “Driving without insurance protection”).  In the event of repetition, possible entry in your criminal record certificate (previously convicted)
  • Loss of insurance cover (private liability)
  • Loss of materials defect liability and warranty claims
  • Loss of driving licence
  • Regularly, partial responsibility in case of accident
Possible legal consequences for dealers in case of tuning:
  • Aiding and abetting of an offence, participating in an administrative offence
  • Retailer liable for personal and material damage
  • Loss of business liability insurance cover
Retrofitting bicycles turns them legally into machines
In their guidelines “Risks related to retrofitting bicycles with e-drives” trade associations of the cycle industry from the industry, commerce and trade indicate that bicycles are designed and tested for being used with pure muscle power. Retrofitting them with special kits turns these bicycles at least into e-bikes 25 kmh/15.5 mph / EPACs that are subject to the Machinery and the EMC Directives (electromagnetic compatibility) and have to be tested accordingly. Finally, the retrofitting person would have to draw up a declaration of conformity what he usually cannot or is not allowed to do. With a higher power than 250 watts and more than 25 kmh / 15.5 mph pedal assistance it is a motor vehicle in terms of traffic law that requires individual approval, an operating licence from an authorized body.
Possible legal consequences for dealers in case of retrofitting:
  • Aiding and abetting of an offence, participating in an administrative offence
  • Retailer liable for personal and material damage
  • Loss of business liability insurance cover
Cooperating institutes and associations
The following institutes and associations were involved in drawing up the guidelines:
The umbrella organization for German industry guilds BIV, TUEV Rhineland,, the German service and bicycle association VSF, Zedler-Institut as well as the German bicycle association ZIV.
The German guidelines are available as pdf-file for download
Author: Press release
The English guidelines are available as pdf-file for download


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