Dirk Zedler – Zedler institute
Pedelecs have to be provided by the manufacturer with a CE-marking. To this end the complete product must undergo a conformity procedure based on the original parts list of the pedelec. Only if the product has passed all tests and only if the imperative risk analysis was successful, the vehicle can be put on the market. Therefore, modifications to the pedelec, i.e. changes to the assembled pedelec, can compromise the CE-marking which means that the pedelec may no longer be sold by the dealer. This implicit prohibition to make changes refers in particular to components which mean considerable modifications to the characteristics of the vehicle. That does not only concern the motor power, but also things which seem trivial at first sight, such as the transmission or the stem.
A stem or handlebars combined with another seating position for the cyclist may change the riding characteristics of the pedelec. This can mean that the operational safety is no longer given. A solution to this difficult situation for the dealer is that the pedelec manufacturers work out lists specifying the products with which the dealer can assemble the vehicle to the customer wishes.
A positive thing is that some manufacturers have already started to do so, others are about to do so. My recommendation for the dealers is to order the pedelecs from those manufacturers where often necessary changes are already provided. Trade supervisory authorities may impose a stop of sales to dealers grossly ignoring this point. In addition, dealers assume liability for the changes, if the worst comes to the worst.