markus datgloi
Member
Some links:
The german EBIKE-MTB article warns that driving a self-built ebike on public roads without CE/UKCA marking is not conform the rules and gives several alternatives/warnings: buy a new cheap ebike, 2nd hand is cheaper, its not a simple case of putting parts together, you need build skills and know how, etc.
It is hard to believe this article that when one (1) private person assembles one (1) ebike, he/she becomes a manufacturer and has to comply to EU market rules/regulations intended to protect consumers from industries/manufacturers who are selling products in large numbers within the EU market. That may change when a private person assembles and sells several ebikes within the EU market or when a bike shop does this.
One thing is obvious: the ebike must comply with the 25km/h and 250Watt engine rules to drive it legally on the public roads.
The article completely ignores the joy one can have from putting together a self-built ebike, whatever the costs or effort needed.
For me the article raises questions.
Why is the managing director of the german Bicycle-Industry-Association (ZIV) interviewed ? Isn't he biased by representing the industry ? He is informative in listing the demands for the industry and states "That also includes providing a CE mark for the pedelec.". An official german BDSF expert states also that every pedelec must have an CE-mark on the bebike. A bike shop-owner selling ebike conversion kits doesn't want to get strangled in the EU's bureaucracy and leaves the conversion of the bike to ebike to the buyer of the kit.
Specialized sells frames without CE mark but Specialized does not state that a completed ebike with their frame must be CE certified. According to Specialized the ebike must be compliant with current applicable directives and a conformity assessment (see link above) must be carried out. Is the result a conformity certificate, a document in which is stated that the product meets the EU requirements (the CE mark) ? The document is for the consumer... but for a self built ebike that would be me ! Why would I make a document for myself and nobody else ? There isn't a registration authority for the document. It is not required to carry the conformity certificate of the ebike with you when you ride the ebike. What are the consequences if I store the document in the waste bin ? Can I still sell the ebike ?
What if I buy a Specialized ebike with valid CE mark and replace parts for better ones ? Does that violate the CE-mark ? Is a conformity assessment required, a new CE certification ? How do ebike shops that when they repair ebikes ?
Since DieselGate we know that fullfilling regulations is often creatively done by industries/manufacturers.
YT has 6 Decoy type ebikes each with 4-5 frame sizes. Imagine you have to test 24-30 ebikes at 20000 to 25000 Euro for a CE mark (price stated by velotech.de) as a company self-certifying is cheaper and you can test more 'creatively', maybe just one certification for all YT decoys. Self-certifying is allowed, see link CE marking. Maybe you can test cheaper in other EU countries. On velotech.de, mentioned in the article as CE mark certifier, I found only one (1) reference to a known ebike manufacturer: CUBE bikes. Velotech's list with (valid) "Gultige GS-Zertificate", last update 2016-11-18, shows only one (1) pedelec25 and it's not from CUBE. The GS Blacklist is empty (last update 2016-11-18). How serious is velotech.de with these lists ? Maybe manufacturers don't want to be listed, afraid for a bad name when they are black-listed when failing the required CE certification.
CE mark test-results could become vital consumer information. Measured values could help choosing an ebike but manufacturers are probably afraid to publish the values.
TosaBikes (www.tosabikes.com) sells ebikes with the same parts as Rob's ebike (at least frame, motor, battery and the Am 1.0 Pro even more parts). I mailed TosaBikes and their answer, if their ebikes have a CE mark (refering to the article), was: "All components that require a CE certificate have such markings.". I assume they didn't understand the question or are not aware of EU rules when you export/sell ebikes to other EU countries or, not likely, the Dengfu E10 frame has a CE mark.
I mailed a local ebike producer, www.sensabikes.com, and asked about the CE mark for their ebikes. Their answer: "Our E-bikes do not have a CE mark. CE marking is not mandatory within the Benelux. Outside these countries, yes. For that reason, our E-bikes are only sold in the Benelux and not outside.". I didn't expect that answer but good news for the Benelux. In other words, living in the Benelux, you can safely build an ebike, as long as it complies with the 25km/h and 250Watt engine rules, and you don't export it to other EU countries outside the Benelux. Selling it locally is not a problem.
This may apply in more EU countries: as long as you do not export to other EU countries, you do not need a CE mark. Was the article written for Germany ? What is the truth here ?
When you do export, export as an “incomplete machine” with some parts the need to be assembled, with all required technical documentation and a declaration of incorporation but without the need for a CE mark.
Specialized sells a frameset as an “incomplete machine” with all required technical documentation and a declaration of incorporation but without CE mark.Canyon states in their pedelec manual: "Your pedelec and the translation of these original operating instructions together with the detailed type-specific Canyon bicycle manual and the system instructions of the drive manufacturer comply with the requirements of the EN 15194:2017 standard for pedelecs, the EN ISO standard 4210-2 as well as with the Machinery Directive 2006/42/EC."
That statement is not a CE mark, they do not mention the CE mark nor is it printed in their manual. It could be the declaration of incorporation printed within the technical documentation as is mentioned for the Specialized frame. I have simular findings in the YT bicycle user manual, no CE mark is mentioned or even printed in the manual or on their shipped carton box. Correction: I did find the CE mark on my YT Decoy (searching for a frame number) which sits on the lower end of the motor mount but is only readable when you remove the rear-wheel.
Article Conclusion: "If you ride your self-built ebike without a CE mark you’re not conforming to current rules and regulation.".
Ehh... What do our governments state about ebikes or bicycles ? Some countries have very clear webpages :
None of these pages refers to a CE mark or other 'EU' rules. Note that there can be additional rules in your country.
"DIY ebikes with the new Shimano EP8 motor? Unlikely, but more likely impossible!"
Well... just order by mail an ebike with EP8 motor from some EU company and assemble the shipped ebike parts at home. By assembling parts you are instantly labelled as manufacturer (article context) of an... DIY ebike ?
All this doesn't protect anyone from local authorities (police) when they inspect your ebike but at least you know something about a CE mark when they ask, if they know what that is.
I'm sure we can have endless discussions about the CE/UKCA marking for self-built ebikes, being labelled a manufacturer and that EBIKE-MTB reads this text.
Update 2021-02-18:
The following EU page and subpages: CE marking - Internal Market, Industry, Entrepreneurship and SMEs - European Commission clearly describe what manufactures, importers, distributors and consumers are and their role. Reading these pages I don't recognize me being a business (manufacturer, importer or distributor) by assembling parts that I acquire as consumer, even when I sell the assembled ebike.
The statement from the german BDSF expert "That includes a CE compliant nameplate on the pedelec." is not correct.
He did not read the "How do you affix the CE marking ?". I quote "If the CE marking cannot be affixed to the product itself, you can affix it to the packaging if there is any, or to any accompanying documents.". It would not supprise me if he can show a EU document that states something else. Webpages and documents are not always consistent. I understand that YT, besides the CE mark on the ebike, also stores the CE marking as a document in the toolbox that comes with the ebike.
Update 2021-02-19:
I was wrong about YT. There is a CE mark on the Decoy but you have to remove the rear-wheel to find and read it. Edited some parts due to new findings.
I do not believe that an EU consumer becomes a manufacturer just by assembling bicycle parts, even when I sell the assembled bicycle.
You can argue that assembled parts turn into a new product but as consumer I never have the intention to trade within the EU and go into any businesses. All bicycle parts are bought from a manufacturer, importer or distributor and according to EU rules the products they sell must comply to EU rules. As long as the assembled bicycle has a maximum speed 25km, maximum power 250watt, only uses pedal assist or when not pedal assisted upto a maximum speed of 6 km/h, it remains a bicycle (in my country).
Do I have to carry out a conformity assessment for my self-built bicycle?
The EU page states: "A manufacturer can only place a product on the EU market when it meets all the applicable requirements. The conformity assessment procedure is carried out before the product can be sold.". I don't want to place my self-built bicycle as a product on the EU market, I intent to ride it. I as consumer understand one thing: as long as you don't sell it, you don't have to prove anything, you can ride it without CE mark as long as it follows the rules stated by the government.
When I sell it then as an “incomplete machine” with all documents that came with the bicycle parts and inform the buyer that he has to carry out a conformity assessment before he can place the bicycle in the EU market as a manufacturer.
Something that will scare you is this EU implementation fact sheet at https://ec.europa.eu/energy/intelli...ocuments/presto_fact_sheet_legislation_en.pdf
- EBIKE-MTB article: Is it legal to build your own eMTB? All the most important information and legislation regarding DIY ebikes | E-MOUNTAINBIKE Magazine
- CE marking (for EU): CE marking – obtaining the certificate, EU requirements
- UKCA marking (for GB): Using the UKCA marking
- Confirmity assesement: Conformity assessment - Internal Market, Industry, Entrepreneurship and SMEs - European Commission
- Declaration of incorporation: Declaration of Incorporation - Conformance.co.uk
The german EBIKE-MTB article warns that driving a self-built ebike on public roads without CE/UKCA marking is not conform the rules and gives several alternatives/warnings: buy a new cheap ebike, 2nd hand is cheaper, its not a simple case of putting parts together, you need build skills and know how, etc.
It is hard to believe this article that when one (1) private person assembles one (1) ebike, he/she becomes a manufacturer and has to comply to EU market rules/regulations intended to protect consumers from industries/manufacturers who are selling products in large numbers within the EU market. That may change when a private person assembles and sells several ebikes within the EU market or when a bike shop does this.
One thing is obvious: the ebike must comply with the 25km/h and 250Watt engine rules to drive it legally on the public roads.
The article completely ignores the joy one can have from putting together a self-built ebike, whatever the costs or effort needed.
For me the article raises questions.
Why is the managing director of the german Bicycle-Industry-Association (ZIV) interviewed ? Isn't he biased by representing the industry ? He is informative in listing the demands for the industry and states "That also includes providing a CE mark for the pedelec.". An official german BDSF expert states also that every pedelec must have an CE-mark on the bebike. A bike shop-owner selling ebike conversion kits doesn't want to get strangled in the EU's bureaucracy and leaves the conversion of the bike to ebike to the buyer of the kit.
Specialized sells frames without CE mark but Specialized does not state that a completed ebike with their frame must be CE certified. According to Specialized the ebike must be compliant with current applicable directives and a conformity assessment (see link above) must be carried out. Is the result a conformity certificate, a document in which is stated that the product meets the EU requirements (the CE mark) ? The document is for the consumer... but for a self built ebike that would be me ! Why would I make a document for myself and nobody else ? There isn't a registration authority for the document. It is not required to carry the conformity certificate of the ebike with you when you ride the ebike. What are the consequences if I store the document in the waste bin ? Can I still sell the ebike ?
What if I buy a Specialized ebike with valid CE mark and replace parts for better ones ? Does that violate the CE-mark ? Is a conformity assessment required, a new CE certification ? How do ebike shops that when they repair ebikes ?
Since DieselGate we know that fullfilling regulations is often creatively done by industries/manufacturers.
YT has 6 Decoy type ebikes each with 4-5 frame sizes. Imagine you have to test 24-30 ebikes at 20000 to 25000 Euro for a CE mark (price stated by velotech.de) as a company self-certifying is cheaper and you can test more 'creatively', maybe just one certification for all YT decoys. Self-certifying is allowed, see link CE marking. Maybe you can test cheaper in other EU countries. On velotech.de, mentioned in the article as CE mark certifier, I found only one (1) reference to a known ebike manufacturer: CUBE bikes. Velotech's list with (valid) "Gultige GS-Zertificate", last update 2016-11-18, shows only one (1) pedelec25 and it's not from CUBE. The GS Blacklist is empty (last update 2016-11-18). How serious is velotech.de with these lists ? Maybe manufacturers don't want to be listed, afraid for a bad name when they are black-listed when failing the required CE certification.
CE mark test-results could become vital consumer information. Measured values could help choosing an ebike but manufacturers are probably afraid to publish the values.
TosaBikes (www.tosabikes.com) sells ebikes with the same parts as Rob's ebike (at least frame, motor, battery and the Am 1.0 Pro even more parts). I mailed TosaBikes and their answer, if their ebikes have a CE mark (refering to the article), was: "All components that require a CE certificate have such markings.". I assume they didn't understand the question or are not aware of EU rules when you export/sell ebikes to other EU countries or, not likely, the Dengfu E10 frame has a CE mark.
I mailed a local ebike producer, www.sensabikes.com, and asked about the CE mark for their ebikes. Their answer: "Our E-bikes do not have a CE mark. CE marking is not mandatory within the Benelux. Outside these countries, yes. For that reason, our E-bikes are only sold in the Benelux and not outside.". I didn't expect that answer but good news for the Benelux. In other words, living in the Benelux, you can safely build an ebike, as long as it complies with the 25km/h and 250Watt engine rules, and you don't export it to other EU countries outside the Benelux. Selling it locally is not a problem.
This may apply in more EU countries: as long as you do not export to other EU countries, you do not need a CE mark. Was the article written for Germany ? What is the truth here ?
When you do export, export as an “incomplete machine” with some parts the need to be assembled, with all required technical documentation and a declaration of incorporation but without the need for a CE mark.
Specialized sells a frameset as an “incomplete machine” with all required technical documentation and a declaration of incorporation but without CE mark.Canyon states in their pedelec manual: "Your pedelec and the translation of these original operating instructions together with the detailed type-specific Canyon bicycle manual and the system instructions of the drive manufacturer comply with the requirements of the EN 15194:2017 standard for pedelecs, the EN ISO standard 4210-2 as well as with the Machinery Directive 2006/42/EC."
That statement is not a CE mark, they do not mention the CE mark nor is it printed in their manual. It could be the declaration of incorporation printed within the technical documentation as is mentioned for the Specialized frame. I have simular findings in the YT bicycle user manual, no CE mark is mentioned or even printed in the manual or on their shipped carton box. Correction: I did find the CE mark on my YT Decoy (searching for a frame number) which sits on the lower end of the motor mount but is only readable when you remove the rear-wheel.
Article Conclusion: "If you ride your self-built ebike without a CE mark you’re not conforming to current rules and regulation.".
Ehh... What do our governments state about ebikes or bicycles ? Some countries have very clear webpages :
- United kingdom: Electric bikes: licensing, tax and insurance
- Netherlands: Welke regels gelden voor mijn elektrische fiets (e-bike)?
- France: Bicyclette et vélo à assistance électrique (VAE) : conseils pour un achat en toute sécurité
- Germany (where ?): Rechte und Gesetze rund ums Thema E-Bike: Alles Wissenswerte or Gesetzliche Regelungen für E-Bike und Pedelec - ingenieur.de
- Spain, Italy,... : where ?
None of these pages refers to a CE mark or other 'EU' rules. Note that there can be additional rules in your country.
"DIY ebikes with the new Shimano EP8 motor? Unlikely, but more likely impossible!"
Well... just order by mail an ebike with EP8 motor from some EU company and assemble the shipped ebike parts at home. By assembling parts you are instantly labelled as manufacturer (article context) of an... DIY ebike ?
All this doesn't protect anyone from local authorities (police) when they inspect your ebike but at least you know something about a CE mark when they ask, if they know what that is.
I'm sure we can have endless discussions about the CE/UKCA marking for self-built ebikes, being labelled a manufacturer and that EBIKE-MTB reads this text.
Update 2021-02-18:
The following EU page and subpages: CE marking - Internal Market, Industry, Entrepreneurship and SMEs - European Commission clearly describe what manufactures, importers, distributors and consumers are and their role. Reading these pages I don't recognize me being a business (manufacturer, importer or distributor) by assembling parts that I acquire as consumer, even when I sell the assembled ebike.
The statement from the german BDSF expert "That includes a CE compliant nameplate on the pedelec." is not correct.
He did not read the "How do you affix the CE marking ?". I quote "If the CE marking cannot be affixed to the product itself, you can affix it to the packaging if there is any, or to any accompanying documents.". It would not supprise me if he can show a EU document that states something else. Webpages and documents are not always consistent. I understand that YT, besides the CE mark on the ebike, also stores the CE marking as a document in the toolbox that comes with the ebike.
Update 2021-02-19:
I was wrong about YT. There is a CE mark on the Decoy but you have to remove the rear-wheel to find and read it. Edited some parts due to new findings.
I do not believe that an EU consumer becomes a manufacturer just by assembling bicycle parts, even when I sell the assembled bicycle.
You can argue that assembled parts turn into a new product but as consumer I never have the intention to trade within the EU and go into any businesses. All bicycle parts are bought from a manufacturer, importer or distributor and according to EU rules the products they sell must comply to EU rules. As long as the assembled bicycle has a maximum speed 25km, maximum power 250watt, only uses pedal assist or when not pedal assisted upto a maximum speed of 6 km/h, it remains a bicycle (in my country).
Do I have to carry out a conformity assessment for my self-built bicycle?
The EU page states: "A manufacturer can only place a product on the EU market when it meets all the applicable requirements. The conformity assessment procedure is carried out before the product can be sold.". I don't want to place my self-built bicycle as a product on the EU market, I intent to ride it. I as consumer understand one thing: as long as you don't sell it, you don't have to prove anything, you can ride it without CE mark as long as it follows the rules stated by the government.
When I sell it then as an “incomplete machine” with all documents that came with the bicycle parts and inform the buyer that he has to carry out a conformity assessment before he can place the bicycle in the EU market as a manufacturer.
Something that will scare you is this EU implementation fact sheet at https://ec.europa.eu/energy/intelli...ocuments/presto_fact_sheet_legislation_en.pdf
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.I was reading your post, and I was thinking for exemple about this covid-19 think. Read several news about face masks and other stuff apprehended due the lack off/or false certificates of EU complience. So this is not differente. Should we be agains it? Don´t think police is going to chek this, but maybe in customes services, or in shops fiscalizations. 
