Revised EN 15194 E-Bike Safety Standard Implemented

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Revised EN 15194 E-Bike Safety Standard Implemented

Postby AUbicycles » Fri Nov 17, 2017 2:13 am

source: Bike EU

This is a shortened extract, read the full article in the original above.
This is relevant as the EN standard is used in many other nations including many of (or all of) the Australian states for defining electric bikes and their requirements / legal status.

Bike-EU wrote:BRUSSELS, Belgium – The very long-awaited revision of EN 15194 has finally been published and is already implemented by quite a few national standardization institutes. They have until 30th April 2018 to implement at national level, by publication of an identical national standard or by endorsement. This revised version of the standard for 25km/h – 250W e-bikes is very different from the ‘old’ standard.

The previous standard only covered the electrical part of the concerned electric bicycles with pedal assistance up to 25 km/h and a maximum continuous rated power of 250W. For the mechanical part, producers were referred to the ISO 4210 standard for conventional bicycles. EN 15194:2017 now covers the complete electric bicycle. This change was made because the mechanical part of an electric bicycle needs more stringent requirements than a conventional bicycle.

Changes in scope
The revised standard also entails some major changes in the scope. Because ISO 4210 was not applicable to specialized types of bicycle such as delivery bicycles, recumbent bicycles, tandems, BMX bicycles, and bicycles designed and equipped for use in severe applications
such as sanctioned competition events, stunting, or aerobatic manoeuvres, the old EN 15194 could not be applied to the electric versions of such bicycles either.

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby find_bruce » Fri Nov 17, 2017 1:06 pm

Thanks Christopher. Have to say I'm struggling to see how they justify
the mechanical part of an electric bicycle needs more stringent requirements than a conventional bicycle.


In 2012, the Commonwealth Department of Infrastructure and Regional Development exempted pedelecs from the Australian Design Rules if they complied with the European standard (EN 15194:2009) .This was then followed in the road rules to allow 250w pedelecs as bicycles and exempted them from needing registration if they are compliant with the EN standard.

Bikes with an auxiliary 200w electric motor are currently defined as bicycles without the need for compliance with the EN standard.

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby pteknae » Sat May 12, 2018 10:29 am

So based on the VicRoads interpretation, a EN15194 compliant bike needs to be stamped with a label stated its compliant (APAC to EN15194), state the max 25km/hr speed and the max 250w power rating and have no throttle.

So where does that leave all the ebike kits that are 250w, 25km/hr limited, have no throttle, but have no EN15194 stamp?? Are these illegal??

There are so many sellers online (dillenger etc) selling bikes with 250W kits, or just 250w kits on their own as 'street legal' even though they dont have the stamping to comply with EN15194.

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby queequeg » Sat May 12, 2018 10:02 pm

pteknae wrote:So based on the VicRoads interpretation, a EN15194 compliant bike needs to be stamped with a label stated its compliant (APAC to EN15194), state the max 25km/hr speed and the max 250w power rating and have no throttle.

So where does that leave all the ebike kits that are 250w, 25km/hr limited, have no throttle, but have no EN15194 stamp?? Are these illegal??

There are so many sellers online (dillenger etc) selling bikes with 250W kits, or just 250w kits on their own as 'street legal' even though they dont have the stamping to comply with EN15194.


It's the same rule in NSW: http://www.rms.nsw.gov.au/documents/roa ... cycles.pdf

If it doesn't comply with EN15194, and also does not comply with the 200W limit for bikes with a throttle, then it's an electric motorcycle that needs to be registered (whether it can subsequently be registered is another matter). The bike must be labelled. If it's not, then you are mostly like going to be found to be riding an unregistered motorbike if queried.

All the kits you can buy online that exceed 200W are rendered illegal.

The great irony is that the local company that recently managed to get a 5% tariff put on all imported e-bikes does not actually make any street legal e-bikes. There's a guy on my local commute who rides with a dillenger kit on his bike, and he is managing speeds close to 60km/h. That is most definitely well outside the envelope for a legal e-bike.
'11 Lynskey Cooper CX, '00 Hillbrick Steel Racing (Total Rebuild '10), '15 Cervelo S5

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby zebee » Sun May 13, 2018 10:00 am

Hmm... so looks like my bionx 250 kit is not legal now. 250W pedal assisted[1]. Don't think it is stamped for example, will have to investigate. Probably not, being Canadian and so less likely to care about Euro standards. The various bionx websites are useless for information like that or information generally.

Hmmm.. "And since the standard only uses the term bicycle, electric tricycles with pedal assistance up to 25 km/h and maximum 250W are now no longer covered by the standard. "

oops! that's even worse for me then!

Given NSW's inability to cope with new standards (the long and sorry saga of motorcycle exhaust standards is well off topic but trust me it is equal parts hilarious and enraging) I guess I just hope the various bods riding about on throttle only 500W kits don't mean some plod sees the trike barrelling along downhill and decides to book me for no stamp.

As I am usually nowhere near the CBD or Centennial park I have so far not been Pedro'd. If they decide to crack down on illegal ebikes I wonder where they will do it? Probably the same target rich environments of the CBD and inner west.

Zebee

[1] but has a throttle that is apparently 200W only but don't ask me how that works!

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby queequeg » Sun May 13, 2018 5:42 pm

zebee wrote:Hmmm.. "And since the standard only uses the term bicycle, electric tricycles with pedal assistance up to 25 km/h and maximum 250W are now no longer covered by the standard. "

oops! that's even worse for me then!



No, a bicycle is defined in the Road Rule....

Road Rules 2014
In accordance with the ‘Dictionary’, bicycle means a vehicle with 2 or more wheels that is built
to be propelled by human power through a belt, chain or gears
(whether or not it has an
auxiliary motor), and includes:
(a) a pedicab, penny-farthing and tricycle, and
(b) a power-assisted pedal cycle*, but does not include:
(c) a wheelchair, wheeled recreational device, wheeled toy, or
(d) any vehicle with an auxiliary motor capable of generating a power output over 200 watts
(whether or not the motor is operating), other than a vehicle referred to in paragraph (b), or
(e) any vehicle that has an internal combustion engine or engines.


So, you are ok with a Tricycle, as long as it also meets the other requirements when powered with a motor.
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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby cj7hawk » Thu Jun 07, 2018 1:22 am

queequeg wrote:
pteknae wrote:So based on the VicRoads interpretation, a EN15194 compliant bike needs to be stamped with a label stated its compliant (APAC to EN15194), state the max 25km/hr speed and the max 250w power rating and have no throttle.

So where does that leave all the ebike kits that are 250w, 25km/hr limited, have no throttle, but have no EN15194 stamp?? Are these illegal??

There are so many sellers online (dillenger etc) selling bikes with 250W kits, or just 250w kits on their own as 'street legal' even though they dont have the stamping to comply with EN15194.


It's the same rule in NSW: http://www.rms.nsw.gov.au/documents/roa ... cycles.pdf

If it doesn't comply with EN15194, and also does not comply with the 200W limit for bikes with a throttle, then it's an electric motorcycle that needs to be registered (whether it can subsequently be registered is another matter). The bike must be labelled. If it's not, then you are mostly like going to be found to be riding an unregistered motorbike if queried.

All the kits you can buy online that exceed 200W are rendered illegal.


Many of the labelled bikes are also illegal. I mentioned some years ago that the label was a requirement under the act, but I don't think the observation was very popular. Likewise, the bicycle must be tested (very expensive) after a kit is added on.

A couple of years ago, I spent a week gathering details of electric bicycles sold and used in Perth, and out of about 20 bicycles, only one I found was correctly labelled and that was being used by a Pizza Delivery company. The form and format of the label is also a legal requirement, and some Chinese knockoffs often get around it by changing the wording slightly so the label looks like a pedelec, but on examination is not. Many says things like "250W Pedelec" and the likes, and many have throttles that go full speed.

Still, I am disappointed. I would have preferred to be proven wrong on this count. If there was a proliferation of more powerful bicycles, then the authorities would have been pressured to relax the rules.

David.

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby pteknae » Sat Jun 09, 2018 5:34 pm

Really sucks, admittedly i ride an illegally spec'd 500W pedalec that i've set up to pedalec spec (25km/hr no throttle), which for a while i regretted choosing over the 250w version thinking it was legal. Sounds like a waste of fretting either way.

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby zebee » Sun Jun 10, 2018 8:42 am

My Bionx has no markings so I guess is now officially illegal in NSW. I will keep riding it though as I reckon the chances of being done are low given that it isn't stamped but it is 25kmh limited and I don't use it on throttle. (Well... I have been known to give myself a bit of a help up hills on the way home)

I hunted austlii for some case law. A case in the ACT was interesting... I give you http://www.austlii.edu.au/cgi-bin/viewd ... 6/160.html

Bod on bike path he'd been on many times before both powered and unpowered. Riding an illegal e-bike that the judge accepted he didn't know was illegal. Driver backed out of driveway and hit him as he rode along the shared path between road and driveway.

Rider was hit and became quadrapelgic :( case was about contributory negligence and turned on speeds up a hill. How much of the crash was due to the rider?

One of the issues was that the bike was "unregistered". Which was dismissed as it wouldn't matter for contributory negligence if a car was a day out of rego.

BUt one of the defendant's arguments was
(b) such illegality was “causative in the sense that the plaintiff’s ability to avoid the accident [was] necessarily affected by the increased braking time associated with a 500 watt electric bike travelling at a speed of 15 to 20 km/h when compared to a normal pedal cycle or even a 200 watt electric cycle”.

THe judge agreed and found that while the rider didn't know it was overspecced they should have checked and known that it was illegal and overpowered and so underbraked.[1]

In the end that didn't affect the outcome - read the case for the details. But it is important to know. If you are in a crash on an overpowered bike then you may well have to show that it doesn't matter cos the speed at the time was within the reasonable braking power of the bike, or else that braking power wasn't important. (such as you got hit without braking involved)

Speed is maybe not that important as unpowered bikes can get cracking. I cruise at 25kmh on my 2 wheeled bent wihout too much effort and can definitely go faster. On the other hand, the trike brakes and slick tyres are a bit interesting downhill with a trailer, never mind the extra weight of the motor and battery. (Yes I stopped in time, even if a bit sideways)

I don't think that anyone who isn't obviously riding an unregistered motorcycle - fast and not pedalling at all while riding right past a cop - is going to be in much risk of being done for not having a sticker but if there is a crash then insurance company lawyers are going to do what they are paid for.

Zebee

[1] I'd like to see the expert testimony in full. Just how much difference in braking is there between a powered and non powered bike? Is a 500W bike on full song going to overpower the brakes of a standard bike compared to a strong rider? GOing to depend on the specs of the bike isn't it?

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby AUbicycles » Mon Jun 11, 2018 4:19 pm

Don’t think the BionX would be picked up as illegal.

Before the broad Australian adoption of the EU law, the original BionX units were throttled to 200W to comply with the then laws. After, they were then allowed at the regular 250W.

The issue is that a new law made some previously compliant motors no longer compliant on paper because of labels (but not actually) and I feel that if a fine was issued, it could be challenged and thrown out.

My tip is to ask for a compliance sticker... problem is that BionX is no longer...

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby zebee » Mon Jun 11, 2018 8:42 pm

Googling for "Bionx E15194 compliance" I found a couple of bike shop sites saying it was compliant. At least the 250W was.

Given the weight of the trike, I can get it up to 30 if I knacker myself doing it, but not for long. I think the difference between someone gasping for breath after doing 30kmh at 100rpm and someone cruising along on a 500W throttle will be obvious.

On the whole I doubt there will be much police activity. They do tend to prefer target rich environments and ebikes don't tend to congregate much. When they were chasing "illegal" motorcycle exhausts they set up traps on the Old Pacific Hwy to catch all the sport bike riders but so missed all the aeroplane level of noisy Harley Davidsons. Another round of Pedro at Centennial Park or Newtown might catch the no bell no helmet lot but probably not many ebikes. Unless, I suppose, they concentrate on the food delivery bikes...

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby skyblot » Thu Jun 14, 2018 8:32 pm

queequeg wrote:
zebee wrote:Hmmm.. "And since the standard only uses the term bicycle, electric tricycles with pedal assistance up to 25 km/h and maximum 250W are now no longer covered by the standard. "

oops! that's even worse for me then!



No, a bicycle is defined in the Road Rule....

Road Rules 2014
In accordance with the ‘Dictionary’, bicycle means a vehicle with 2 or more wheels that is built
to be propelled by human power through a belt, chain or gears
(whether or not it has an
auxiliary motor), and includes:
(a) a pedicab, penny-farthing and tricycle, and
(b) a power-assisted pedal cycle*, but does not include:
(c) a wheelchair, wheeled recreational device, wheeled toy, or
(d) any vehicle with an auxiliary motor capable of generating a power output over 200 watts
(whether or not the motor is operating), other than a vehicle referred to in paragraph (b), or
(e) any vehicle that has an internal combustion engine or engines.


So, you are ok with a Tricycle, as long as it also meets the other requirements when powered with a motor.


I don't think so. Being compliant with the Australian definition of a bicycle for use on the road is one thing, but meeting the compliance requirement for EN15194 [2017] is another thing entirely.

According to the Bike.EU info, tricycles and the like will not be admissible for the latest issue of EN15194, hence no EC compliance mark and no approval for use in Oz. Note EN15194 {2017} is a voluntary standard at the moment.

Anyway, as it stands all the 250W pedelec kits out there are illegal for road use, as the bike it's fitted to is not certified to meet EN15194. Goodness knows how much it would cost to have a bike certified as a "one off". The kits themselves aren't cetified....

To the best of my research the AU legislation only refers to EN15194, with no issue or revision status.

I doubt any of the regular Police would distinguish the differences....

On a related note, an E-bike reseller was telling me that in Qld recently there was a push by the Police to have 200W bikes made illegal, on the grounds that they (QPS) could not identify what was, and was not, legal. They wanted the 250w with CE approval as the only legal e-bike option, ie no CE mark = illegal, here's your ticket. Fortunately that didn't get through...

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby find_bruce » Thu Jun 14, 2018 9:54 pm

Has anybody had a hub motor tested for power output ?

While power input is easily measured for an electric motor, in NSW at least the limitation is on power output which is trickier to measure. Most hub motors are around 80% efficient, which means a 250w drain from your battery will equate to ~200 w output.

Measuring input will at least give you a rough guide to whether the number printed on the motor is vaguely accurate

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Re: Revised EN 15194 E-Bike Safety Standard Implemented

Postby cj7hawk » Wed Jul 04, 2018 4:14 pm

find_bruce wrote:Has anybody had a hub motor tested for power output ?

While power input is easily measured for an electric motor, in NSW at least the limitation is on power output which is trickier to measure. Most hub motors are around 80% efficient, which means a 250w drain from your battery will equate to ~200 w output.

Measuring input will at least give you a rough guide to whether the number printed on the motor is vaguely accurate


Yes, I went through this regularly - it's very reliant on how you drive it also, but yes, 250W consumption ~ 200W at the wheel.

I spoke to Department of Transport (WA) a few years back on what was a reasonable way to test for this anyone having such a bicycle, and they said that if you make a run in two directions on a flat level road on a calm day in two directions ( up and down the road ) and then take your maximum speed and average the two results, and it was lower than 25kph, that this was a reasonable test of compliance of the hub motor.

They provided this in writing at the time also.

In the end, because of problems ensuring compliance, I derated a 500W motor to 125W, which gives about 19kph, then boosted the output to 200W, which gives about 180W at the wheel, which is well within the limit, measured electrically at the point where the wires go into the wheel. ( Only about 10% loss at this point ) - But even then, the output from the batteries was about 240W.

At some point I want to build a small, accurate rear-wheel gyro though so I can get those 20W back :)

David.

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