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Bosch calls for greater federal oversight of e-bike electronics and batteries

Published December 14, 2022

A version of this article ran in the December issue of Bicycle Retailer & Industry News.

By Paul Tolme

The Consumer Product Safety Commission should take a more active stance in regulating electric bike batteries and electronics to reduce fire risk and enhance safety, according to the head of Bosch eBike Systems in North America.

Speaking at the Austin Electrify Expo last month, Claudia Wasko urged federal regulators to mandate testing and compliance standards for the entire e-bike electronics system — not just the batteries.

In a follow-up interview with BRAIN, Wasko said Bosch would “appreciate the CPSC becoming more involved in the topic of safety standards’’ for e-bikes, just as they did for hoverboards in 2018. 

Federal regulations were among the topics Wasko discussed in a Q&A that included differences in the European versus the American e-bike marketplace, consumer trends here and in the EU, and the industry’s role in climate action. BRAIN edited Wasko’s responses for conciseness.

BRAIN: What are the top e-bike trends in Europe from a sales and consumer perspective versus in North America?

Wasko: The e-City category is dominating the European market based on the recognition that they are an important means of transportation. eTrekking and eMTB also account for major market shares. 

In the United States, the market is more fragmented. Here we see many e-bikes geared toward leisure, but e-bikes for city and transportation use are growing rapidly, as is the eMTB market.

Throttle e-bikes don’t play any role in Europe because they fall outside the definition of EPACs (electrically power assisted cycles), whereas they are significant in the U.S. market. 

In the U.S., Class 3 e-bikes have a market share of 10 to 15%. In Europe, they are underrepresented and treated as a motorized vehicle requiring additional licensing and approval. 

Mid-drive motor equipped e-bikes dominate the European market, and they are viewed as an important mode of transportation. European consumers are willing to pay more, and sales prices are higher. The average sales price in Europe’s core markets (Germany, Switzerland, Austria) is $2,700 compared to $1,800 in the United States.

The EU also has a more uniform regulatory structure when it comes to e-bikes. 

BRAIN: What norms and standards from the EU would you like to see adopted here?

Wasko: There are a number of relevant norms and standards in Europe related to e-bikes, most importantly EN 15194 and ISO 4210.

EN 15194 covers common hazards and hazardous events related to e-bikes. It is the first comprehensive certification for e-bikes and their integrated electronics. It covers mechanical safety, electromagnetic compatibility, and electrical safety.

In the U.S., the CPSC only recommends voluntary standards from organizations including ASTM, ANSI, and UL, but not EN standards. The CPSC is aware of EN 15194 and ISO 4210, but their engagement is limited to UL standards. Their staff actively participated in the development of UL 2849, the voluntary standard for electrical systems for e-bikes. 

With e-bikes becoming more important in the U.S., Bosch would appreciate the CPSC becoming more involved in the topic of e-bike safety standards. 

In 2018, the agency issued a letter that “urged” manufacturers and distributors of self-balancing scooters (hoverboards) to sell only products that comply with voluntary safety standards like UL 2272, which is a standard for electrical systems for personal e-mobility devices. Bosch would appreciate a similar approach for e-bikes.

BRAIN: Why does Bosch feel it is important that safety standards reflect the entire e-bike system rather than just the battery? 

Wasko: To obtain third-party NRTL (Nationally Recognized Testing Laboratories) certification and compliance with various voluntary UL standards, companies must go through rigorous evaluation and testing. Being compliant with UL 2849 means meeting constructional and test requirements for preventing electrical, fire, and shock hazards. There are also quarterly unannounced inspections at manufacturing locations by a third-party certification organization.

UL 2849 has robust functional safety requirements for battery packs and battery management systems, and it also addresses risks associated with the other components of an e-bike system. Certification includes a detailed evaluation and testing of the drive unit, display unit, interconnecting cables and connectors, electrical accessories, battery system and charger system combinations.

Standards such as UL 2849 are essential to ensure safety through the thousands of cycles of charges and discharges. Testing and validating the safety of battery packs and battery management systems is needed to minimize the risk of fire and electric shock.

Getting certified to this system standard requires an investment of both time and money. Consequently, only a limited number of suppliers has taken these efforts. 

BRAIN: Why do you believe there should be greater federal regulatory oversight of e-bike batteries and e-bike systems in North America?

Wasko: Considering the evolving character of e-bikes in the U.S., the bicycle industry needs to get engaged both at the local level, such as with the New York City Council, and at the federal level with the CPSC, to create a baseline for standards. CPSC should issue a safety standard recommendation for e-bikes. The question is the scope of the standard. Will it be limited to batteries and chargers only or cover the entire system?

A system certification could decrease sourcing options for bicycle manufacturers who prefer to purchase e-bike components separately. But brands could undertake the efforts to comply with UL 2849. From the Bosch perspective, only complete-system standards can ensure the highest level of safety. 

BRAIN: What are the most significant regulatory, technological, and consumer preference differences in the EU marketplace?

Wasko: The EU defines e-bikes as pedal cycles with assistance up to 25 kph and a motor with a maximum continuous rated power of 250W. Vehicles with a higher assisted speed or throttle are not considered e-bikes.

In the U.S., CPSC regulations define e-bikes as vehicles with operable pedals and an electric motor of less than 750W which provides support up to 20 mph. Class 1 e-bikes are comparable to “Powered Cycles” in Europe. Class 2 and Class 3 e-bikes fall outside the EU definition of an e-bike.

Mid-drive motors dominate the European market. Consumers are willing to pay more, and users expect more in terms of efficiency, performance, and product life. In the U.S., online e-bike sales accounts for approximately 50% of the market, whereas in Europe the vast majority of sales go through physical bike shops. 

For many reasons including their perception, e-bikes in the U.S. have not reached the maturity level of the European market. The electrification rate in the U.S. is around 8%, compared to an average of 23% in Europe, with established countries reaching even 40-50%.

Fiscal legislation in Europe also provides more favorable e-bike tax benefits. In Germany employees can get company bicycles free of income tax. The employer leases the bike, and the tax advantages can save the employee up to 40%. There are almost 300 tax-incentive and purchase-premium programs for cycling across Europe. 

While there are e-bike incentive programs on the state and city level here, for example in Colorado and Vermont, and in Denver, there is no federal tax credit or rebate program. 

BRAIN: What problems do you see with the three-class system?

Wasko: The model legislation which defines the three e-bike classes was created in 2014. States decide which types of bike infrastructure each class can use. It also requires that all e-bike manufacturers apply a class label with wattage to each e-bike to help law enforcement.

Successfully implementing the class system requires action in three areas, all of which have deficiencies: educating consumers, ensuring that bicycle manufacturers stay within the power and maximum speed specifications and apply the correct label, and interest from law enforcement. 

Technologies have evolved since 2014 and there are products which no longer fall into any class, such as e-bikes with throttles that provide power up to 20mph (Class 2) plus pedal-assist up to 28mph (Class 3). How should such an e-bike be labeled?

BRAIN: BRAIN recently wrote about the trends in hub drives versus mid-drives, which concluded that hub motors have stoked consumer demand for e-bikes. Do you see a time when Bosch will introduce a hub motor? 

Wasko: At Bosch, we are continuously observing the market and evolving technologies and trends. We are aware of the strong growth in Class 2 products, especially below $2,000. We see opportunities for Bosch in many different categories but cannot comment further.

BRAIN: BRAIN recently published a story about POW Bike and efforts to get brands, retailers, and people who ride bikes engaged in pushing for climate action. What role should the industry play in lobbying governments for climate action?

Wasko: While banding together as outdoor and cycling industries to tackle climate change is a great idea, it’s important to first look inward to our business practices and supply chains. 

Reducing our global footprint across all divisions is a major initiative for Bosch. We’ve been carbon neutral since 2020. That said, we have much more ambitious goals. If we all make these efforts individually, and work together toward a more sustainable future, what a powerful message that would be to our governments. 

Editor’s note: Bosch’s claim of carbon neutrality is based on its purchase of “carbon offsets.” Critics say offsets are not valid greenhouse gas reductions.

Claudia Wasko

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