E-bike makers: be mindful of legal requirements

Dirk Zedler on: market surveillance procedures
Markets for bicycles are growing — drawing greater attention from the various market surveillance authorities. Sales bans are being imposed on manufacturers for a variety of different reasons.
After the tremendous success of the past ten years, we as an industry are entitled to some pride. Electric bicycles were originally seen as mobility aids for pensioners, and criticized for



their poor reliability and short useful life. Since then, e-bikes have matured and become a respectable option for all user groups and categories, from the enduringly popular low-entry or unisex bike to cargo bikes and sporty full-suspension enduro models. Industry association Zweirad-Industrie-Verband (ZIV) says that in Germany alone 2.2 million of the bikes sold in 2022 came with electric support. That amounts to almost half of all the bicycles sold that year. The margin is highest in the mountain bike category, where 90 % of all bikes sold have a motor.
So, everything is fine then? Not quite, because a lot of manufacturers are not on top of all the new tasks electrification has wrought. Some deficits are enormous. This can – and often does – lead to sales bans imposed by the authorities and penalties of sometimes tens of thousands of euros.
© Eurobike Show Daily
‘e-’ turns a bicycle into a machine

Market surveillance authorities cannot and must not be complacent in the face of the success of our industry. The statutory framework throughout the whole European Union clearly states that the authorities must ensure a uniform, continent-wide safety level. Wherever in the EU a product with a mandatory CE marking is sold, the customer must be sure it is safe. No ifs or buts — e-bikes must meet all applicable directives and laws. This is meant to prevent unsafe products from reaching customers, but also to ward off market players trying to gain unfair advantages through lower safety benchmarks for reduced production costs and prices.

Other countries have instituted nearly identical requirements for e-bikes, such as Switzerland, the United Kingdom, Australia and New Zealand.

Such (safety) requirements are by no means unchartered territory. Power tools and household appliances are sectors where transparent conformity procedures and knowledge of the Machinery Directive (one of the applicable legislative acts) have been par for the course for more than 20 years. The cycling industry merely needs to come to terms with the fact that electric motors have changed the legal landscape and that external observers have the right and duty to investigate the manufacturers’ safety measures.

For non-electric bicycles, nothing changes. The courts will only take a look when something has gone awry, i.e. in cases of accidents with severe consequences. But with electric bicycles, an authority may request to see and check the documentation if there is even just a ‘slight initial suspicion’. Even worse, if the regulations are not met, the authority can and must ban distribution until further notice.

Examples of temporary sales bans

A manufacturer was keen to enter the Italian market. The authorities determined that documents were missing and investigated. Sales were stopped until all investigations were passed and all required technical documents submitted.

A police patrol in Germany stopped a cyclist and noticed irregularities on the identification plate. The bike dealer could produce neither a declaration of conformity nor the technical documents, so the case went to the trade supervisory board at the bike manufacturer’s seat.
A shipping container with e-bikes was inspected in Marseille (France). There were no operating manuals in the bike boxes, so officials temporarily blocked the container and the sale of its contents.

The German regulatory authority Bundesnetzagentur banned the sale of cargo bikes in Germany that had not been tested for electromagnetic compatibility (EMC).

A manufacturer in Switzerland received a visit from the Swiss Council for Accident Prevention (BFU). The officials found deficits: incomplete operating manuals and missing risk assessments. The manufacturer could continue delivering the e-bikes only after the new documents were inspected.

For e-MTBs intended for the French market, neither the importer nor the manufacturer from another EU country could provide sufficient test certificates. The authority did not accept the partially incomplete reports provided by the Asian suppliers. Instead, it required tests to be performed in a French laboratory, i.e. in the European Union.

As these examples from our work show, bike manufacturers cannot afford to continue as they have over the past decades. Market surveillance authorities only had big-name manufacturers in their sights at first, but smaller and medium-sized manufacturers are now starting to feel the heat too.

Getting started

The statutory requirements are comprehensive and by far exceed the scope of the Machinery Directive: there is the Low Voltage Directive, the Battery Directive, the RoHS Directive, the many standards for e-bikes themselves and for operating manuals and risk assessments.

Sure, it is hardly possible to get on top of all this in an instant. Which is why it is so important for manufacturers to get started across their portfolios. And just as importantly, the whole team, from the management down, needs to be committed. That training employees is usually a first successful step. The company can turn things around only if all participants are familiar with the safety concepts behind the legislation.


Photo: Zedler-Institut

New dates – product liability and CE workshops

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For 25 years now, the Product Safety Act has been in force, and yet there are many manufacturers and importers of bicycles and e-bikes that are still not familiar with it. Anyone who imports EPACs into or manufactures them in the EU cannot avoid dealing with the CE marking.

Without CE marking these bicycles with electric auxiliary motor must not be sold. If they are placed on the market nevertheless


and cause damage in use, manufacturers or importers must be prepared to face legal action and high compensation for damages.

However, market surveillance authorities can impose a sales ban on EPACs, e-MTBs and e-transportation bikes even without event of damage if they detect deficiencies in the entire chain of the conformity procedure. That’s what happened in Italy, Switzerland and Germany with several manufacturers and importers – this year already.

The very day of the workshop for individual persons and small groups the directives, laws and standards relevant for placing bicycles and EPACs on the market will be treated comprehensively from practice for practice. Specific international regulations as well as detailed, mandatory, product-related documentation, such as a risk assessment, can be also presented.

This workshop provides you and your team with the necessary background knowledge and the practice-approved toolset and ensures that the CE marking for placing EPACs, e-MTBs, e-gravel and e-cargo bikes on the market is no longer a book of seven seals for you. This workshop mainly addresses decision makers (CEOs, CTOs, etc.) and key staff (e.g. product management, purchase department, quality assurance, service, etc.).

For companies with many employees we recommend an exclusively tailored training course – either also in Ludwigsburg or at their premises.

Register for the product liability and CE-conformity workshop now on one of the following dates in our German webshop. If you do not succeed in booking the workshop in our German webshop, please write an e-mail:


Monday, September 19, 2023

Wednesday, October 18, 2023 (held in English)

Friday, December 1, 2023

Thursday, February 1, 2024

Monday, March 4, 2024


You find further information on our website.

Also have a look at our training video.


© Photo: Zedler-Institut


New webshop online

© Zedler-Institut
For about 30 years now, we have been a provider of services around bicycles and e-bikes. From now on, we want to make processes even faster and easier.
That’s why we launched a webshop (at present in German language only) that will grow continuously.
From now on, you can:




We are looking forward to your orders. If you do not succeed in booking a training course or requesting the portfolios or the information from our German webshop, please write us an e-mail.

In case you detect any optimization potential for the webshop or desire further products/services in the shop, feel free to let us know.

Climate protection concepts on the international level

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Sustainable mobility and climate protection are much discussed topics not only in Europe. In Ecuador, people are also working on projects in this field.

For this reason, a delegation from the Ecuadorian city of Ambato, with which Ludwigsburg has a climate partnership, came to the twin city recently to




gather information and ideas for their own projects. The Department of Urban Development, Climate and International Affairs of the City of Ludwigsburg also arranged an appointment for the South Americans with the Zedler-Institut.

As a beacon company in the field of climate protection, founder and managing director Dirk Zedler welcomed the delegation led by the twin city’s Mayor, Dr. Javier Altamirano, and presented the Zedler-Group's sustainability and climate protection concept to the guests. The South American experts from the urban departments mobility and road traffic safety delved into the world of cycles and showed themselves impressed by the awarded climate positive company building, the lived philosophy of the company, the possibilities that cycling offers for mobility and the exhibits.

The findings gained were shared and exchanged with Swabian “local food”, i.e. pretzels, Maultaschen (stuffed pasta pockets) and braided yeast bun.

Finally, Mayor Altamirano, did not miss the opportunity to let Dirk Zedler know through the accompanying interpreter: “There should be more people like you”. An exuberant ¡Muchas gracias! and a warm South American embrace of the host by all the guests at the end underlined their thanks once again for the informative morning.

Photos: Zedler-Institut