There are different opinions in the cycle industry as to whether the operating instructions for e-bikes, pedelecs and e-cargo bikes must always be supplied in printed form on paper or whether a digital version is also possible.
In the new Regulation on machinery dealing with the issue a distinction is made that was previously not made. “Digital instructions for use” are now possible, however with restrictions. It herewith opens the gate for digital solutions if they address exclusively to professional users. For final customers the paper documentation shall not be replaced.
The currently applicable EPAC standard DIN EN 15194:2018-11 stipulates that EPACs operating instructions must be provided in printed form: “Each EPAC must be supplied with a set of instructions for use in the language of the country to which the EPAC is destined to be supplied. In various countries local requirements relating to this kind of information may be valid (see EN 82079-1). It is obligatory that the instructions for use are made available in paper form. For more detailed information to enable access for vulnerable people the instructions for use should be available additionally in electronic form on demand.”
Differences B2B versus B2C
Zedler-Institut clarifies how to interpret the new regulation: “In summary, the following simple lesson can be derived from the applicable regulations and standards: B2B purely digital yes, B2C purely digital no. When selling components to the bicycle manufacturer, the component manufacturer may supply digital component instructions. However, the bicycle manufacturer or his trading partner must provide the standard-compliant operating instructions for fully-assembled and ready-to-ride EPACs in paper form when selling them to the end consumer. Furthermore, he is one hundred percent without initial suspicion for a trade or market surveillance authority if he will supply printed instructions for the bicycle/e-bike in the respective national language.”
In practice, however, there is an important digital component in the consumer sector today, as Zedler explains further: “What has also been realised successfully are hybrid concepts with printed, concise operating instructions in several languages referring via weblink or QR code to comprehensive, detailed instructions specifically according to EPAC/e-bike category. Instructions of the drive system and component suppliers were also made available within the “Technical support”. Both concepts were accepted without difficulties from the market surveillance and accident prevention authorities in many countries of the European Union, but also in the UK and Switzerland.”
Another point to be observed with the digital versions of the operating instructions is that they must be accessible and remain available for the service life of the machine, at least ten years.
Author: Daniel Hrkac