Confederation of the European Bicycle Industry ASBL
CONEBI ASBL
The Confederation of the European Bicycle Industry - CONEBI - is the result of the merger between COLIPED the Association of the European Two-Wheeler Parts’ and Accessories’ Industry and COLIBI the Association of the European Bicycle and EPAC Industry.
ID: 677937617205-76
Lobbying Activity
Response to Exclusion of L-category vehicles from scope of the Cyber Resilience Act
2 Jun 2025
CONEBI - the European association of the bicycle, e-bike, parts & accessories industries - fully supports the proposals laid down by the European Commission in draft Delegated Acts on cybersecurity requirements for L-category vehicles: 14431 and 14506. In summary, CONEBI proposes that compliance with the Cyber Resilience Act (CRA) be recognised as fulfilling the cyber security requirement for all products in our sector that contain digital elements, i.e. for non-type approved e-bikes (EPAC) as well as for type-approved L1e vehicles designed to pedal (mainly S-EPAC), since they are not technically different in terms of cybersecurity. We therefore fully support the current proposals which take this suggestion into account. CONEBI is willing to cooperate and further elaborate with the European Commission in case of any questions or remarks being raised by other stakeholders or EU Member State experts during this public consultation. Full details in attachment.
Read full responseResponse to Cyber Security Requirements for L-category vehicles
2 Jun 2025
CONEBI fully supports the proposals laid down by the European Commission's draft Delegated Acts on cybersecurity requirements for L-category vehicles; all details are in attachment.
Read full responseMeeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and Association des Constructeurs Européens de Motocycles
20 May 2025 · End-of-Life Vehicles
Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)
14 Mar 2025 · End-of-Life Vehicles Regulation
Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)
9 Sept 2024 · meeting on cycling
Response to Revision of EU legislation on end-of-life vehicles
4 Dec 2023
CONEBI Position on Commission Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles CONEBI, the Confederation of the European Bicycle Industry, representing the EU Bicycle, Pedal Assist E-Bike, Parts and Accessories Industries, would like to express its views on the Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles. CONEBI welcomes the proposal and supports the Commission´s proposal exempting powered cycles within vehicle sub-category L1e-A, as well as cycles designed to pedal within sub-category L1e-B of the regulation EU 168/2013. This decision provides long-term clarity and significantly enhances the capacity of the bicycle industry to engage in strategic planning particularly in light of the big overlaps of pedal driven cycles within type approval and those outside type approval such as electrically power assisted cycles (EPAC). Overlaps to be mentioned that are relevant to the topic at hand are especially the distribution and end-of-life treatment channels as well as development and sourcing of technical components. The aspect of strategic planning and legal certainty are particularly crucial for our industry, which predominantly comprises SMEs. Long-term planning capability greatly influences their success. In this context CONEBI would like to recall our feedback submitted in November 2022 to the public consultation on the evaluation of the WEEE directive (reference: F3353298), which is also in line with our earlier feedback on the revision of the ELV Directive submitted in October 2021. Since we are advocating to exclude L1e category from the proposed Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles, we are advocating to include them in the WEEE Directive to keep type-approved and non type-approved pedal-driven cycles together. Our feedback explains the benefits of including also type approved e-bikes (L1e-A and L1e-B) in the WEEE Directive, along with non-type approved e-bikes, which already fall within the WEEE today. Treating similar vehicles equally and including all types of pedal assisted e-bikes within one legislation would facilitate: 1) Proper waste collection by enabling correct disposal of e-bikes by the consumer. 2) The work of waste operators for whom it might be difficult to distinguish an EPAC and a Speed-EPAC at the end of its life. 3) Streamlining product and supply management within the industry and avoiding additional burdens on an industry dominated by SMEs. CONEBI remains at full disposal for any further clarification.
Read full responseResponse to European Critical Raw Materials Act
29 Jun 2023
Kindly see the attached file
Read full responseResponse to Evaluation of the 2012 Directive on waste from electrical and electronic equipment
2 Nov 2022
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. Via the CONEBIs national industry members, more than 600 small, medium and large companies are represented in CONEBI. CONEBI welcomes the evaluation of the rules for Waste from electrical and electronic equipment (WEEE) and would like to provide its feedback on the overall functioning and scope of the legislation as it directly impacts the Bicycle Industry. The Bicycle Industry has made efforts in the last years to be compliant with the WEEE and believes that this is a suitable system for e-bikes in general as it implies take back at the municipal waste centres and leads to mandatory take back in some Member States legislation and therefore eases disposal for consumers. Should the Commission consider a revision of the scope, we believe that it could be extended to also cover type approved e-bikes. This would ensure that the consumers have similar rights for similar vehicles when handing them over to be recycled and that the bicycle industry, which is traditionally dominated by SMEs can easily apply the same set of rules and is protected from over-proportional burdens. We have also stated this position when providing our feedback to the revision of the ELV Directive in October 2021, where we asked the Commission to keep the end-of-life requirements of type-approved e-bikes as close as similar to those of bicycle and EPAC. In addition, we would like to point out that while the legislative frameworks for EPACs and Speed-EPACs differ due to their typical divergent use and corresponding technical layout (e.g. higher assisted speed and corresponding technical components for Speed-EPACs), when it comes to end-of-life handling, they both could be treated the same. Furthermore, it should be ensured that there are many and conveniently located collection points, making it as easy as possible for consumers to bring back their WEEE. Ideally, it should be possible to return all kinds of e-bikes as well as their components at the same place, as the EPACs and Speed-EPACs are often found in the same distribution channels and are used similarly by the end-users. In general, the importance of awareness campaigns and the role of education within the respective Member States should be stressed. Finally, it is necessary to ensure that all requirements are proportional and are not subject to frequent changes leading to increased burdens for companies. In some of the Member States, the existing collection systems are overtly complicated for producers, especially for the many small SMEs within the Bicycle Industry. The WEEE revision could therefore be an opportunity to streamline and simplify the rules throughout the EU; using the many already existing best practices within the national collection schemes for future harmonisation. CONEBI and the Bicycle Industry are looking forward to further discussions about the revision of the WEEE rules and stand ready to provide their expertise.
Read full responseResponse to Sustainable Products Initiative
10 Jun 2022
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. In the EU there are about 1000 companies, the majority of them being small and medium sized enterprises (SMEs), providing more than 150,000 direct/indirect jobs. Via the CONEBI’s national industry members, more than 600 small, medium and large companies are represented in CONEBI.
CONEBI welcomes the European Commission’s Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products, hereafter called Ecodesign rules. We support the efforts to facilitate a more circular and green economy as well as make it easier for consumers to make sustainable choices. The bicycle industry has for a long time been at the forefront of producing long-lasting, repairable and high-quality products that promote European sustainability goals.
It is therefore very important for the whole cycling ecosystem that the new Ecodesign rules are efficient, enforceable, and demonstrably contribute to the circular economy goals – all while keeping product safety in mind. Importantly, the burden put on companies shall be proportionate; additional requirements must be manageable and affordable for all companies, in particular SMEs; while providing maximum environmental benefits for European customers. We welcome that the proposal paves the way for product-specific measures, allowing for tailoring the requirements to fit given products or product groups.
As the bicycle industry, we are prepared to provide our expertise in the process of developing the product-specific Ecodesign rules. It shall also be ensured that stakeholders for the relevant products are closely involved in the process of drafting the product-specific acts providing expert information and input.
Please see detailed comments and suggestions by CONEBI attached.
Read full responseMeeting with Alviina Alametsä (Member of the European Parliament, Shadow rapporteur)
9 Jun 2022 · ITS directive
Response to Promoting sustainability in consumer after-sales
4 Apr 2022
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. CONEBI welcomes the European Commission’s initiative ‘Sustainable consumption of goods – promoting repair and reuse’. The bicycle industry takes sustainability seriously and strongly supports efforts to reduce waste and produce more environmentally sustainable products to promote the move towards a circular economy.
Cycling and bicycles are the key elements facilitating the green transition in Europe. More and more people are choosing cycling in order to be healthier, but also to reduce their climate footprint and contribute to a more sustainable future. The bicycle industry is determined to continue providing customers with high quality and long-lasting products, in line with efforts to reduce unsustainable consumption. That being said, when introducing new policies, it is crucial to always ensure high consumer and product safety.
One of the aims of the initiative is to encourage producers to design goods that last longer and are easily repairable. This is a welcome goal; bicycles and e-bikes are known to be high quality and very long-lasting products. This can be attributed to high-quality components, availability of spare parts, adequacy of service network and last but not least the consumer’s positive attitude towards repairing and maintenance of their (electric) bicycles. Depending on the type of repair needed, consumers or bicycle repair shops can easily do it in most cases; bicycles are modular products and repairability is one of their inherent features. At the same time, it is important to keep in mind that relevant technical and safety considerations need to be upheld at all times to ensure safety of the products for the consumers.
Since the right to repair initiative aims to cover a vast range of products, it is important to point out that different requirements are necessary for the different product categories in order to take into account the repairability of the specific products and possible safety implications attached. Moreover, even within product categories, repair needs to follow a multi-staged model. In this sense, repair could be ordered based on the safety impact and the possible risk for the user as well as the complexity of the repair.
Furthermore, consumers should be entitled to have their goods repaired correctly. Therefore, a sound technical framework for repairing of products must be put in place; continued adherence to the European and international standards developed by the bicycle industry (referenced in key European legislation including the EU Machinery Directive and the EU General Product Safety Directive) should be ensured. If a clear framework for repair is lacking, repairing of products can lead to potentially unsafe situations during actual use.
We would like to use this opportunity to address a specific issue in regard to battery-containing products and vehicles. Batteries are electro-chemical devices and must fulfil a series of international, European and national safety requirements during their production, transport, storage, use and end-of-life management. For safety reasons, policy makers therefore must treat battery packs as spare parts for repairable products and not like repairable products themselves. Therefore, batteries should be excluded from a direct right to repair.
In addition to this, liability concerns should be considered when it comes to responsibility of producers for repaired products; the same applies to the issue of legal guarantees.
The bicycle industry is a strong supporter of measures that enhance sustainable consumption and repairability. However, safety of products must be an absolute priority in order to make sure that European consumers can enjoy the benefits of cycling - staying safe at all times.
Please see the attached file for more details.
Read full responseResponse to Revision of the Intelligent Transport Systems Directive
18 Mar 2022
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. CONEBI welcomes the European Commission’s proposal for a revision of the ITS directive and supports the efforts to facilitate more efficient deployment and use of ITS solutions. We particularly welcome the adoption of some of the key messages of the industry and explicit mentions about VRUs (vulnerable road users) as well as the emphasis on the role of CCAM in the future, especially in urban areas. However, besides the positive elements, there is some room for possible improvements.
Firstly, the ITS directive proposal seems to be designed primarily with cars and other motor vehicles in mind. On a regulatory level, it is crucial to strive for inclusiveness of all modes of mobility and all road users, particularly keeping in mind the safety of the vulnerable ones like cyclists and pedestrians (without adding any additional administrative burdens on them).
Secondly, the proposal also brings some new mandatory requirements, asking Member States to ensure availability of various data types listed in Annex III of the ITS directive proposal and their accessibility through National Access Points (NACPs). We reckon that high-quality and accessible data is key to the development of future ITS applications. However, at the moment, the required data listed in Annex III does not include data linked to VRUs. Furthermore, the data to be collected on regulations and restrictions in Annex III only covers areas with access to motorized traffic; cycling and pedestrian infrastructure is not included. The future of ITS and CCAM must take cyclists and pedestrians into account – it is necessary to have sufficient knowledge about VRU dedicated infrastructure as well as infrastructural interfaces between spaces for motorized traffic and bicycle lanes. Going beyond the requirements currently listed in Annex III, it would be desirable to even include mandatory datasets on VRU dynamics and accidents. The world of mobility is changing fast and dynamic data collection is a crucial prerequisite for the new mobility services and planning.
Thirdly, as already pointed out, we highly welcome that the protection of VRUs has become part of a priority area. As many ITS use cases are already handled by smartphones and cloud based services (like multimodal transport services or traffic light information) and since the smartphone appears to be a natural choice to integrate VRUs into ITS services, the question arises to what extent smartphones especially in combination with server based services can also be used for use cases whose aim is to enhance the safety of VRUs, but are not safety critical in terms of functional safety (example: information messages which do not require immediate/strong reactions).
Fourthly, we would like to emphasize that for use cases with functional safety requirements (like strong automated interventions etc.), there will be a need for regulation related to the mutual acceptance of ITS messages exchanged between different traffic participants whose ITS devices and attached sensors were developed based on different functional safety standards.
Finally, since the revision of the ITS directive was announced as a part of a larger mobility package, it is important to put the proposal ‘in conversation’ and in sync with other EC proposals, especially the Urban Mobility Package. The cycling ecosystem has welcomed the Urban Mobility Package proposal, as it provides a significant boost for cycling and sustainable mobility. More explicit inclusion of bicycles and cycling within the ITS directive proposal would be beneficial. The world of mobility is changing, with more and more people choosing bicycles for environmental and health reasons; and the new ITS directive must be ready for the future.
Please find more details in the attached position paper.
Read full responseMeeting with David Cormand (Member of the European Parliament, Shadow rapporteur)
19 Oct 2021 · Machinery Regulation
Response to Review of the general product safety directive
1 Oct 2021
CONEBI, the Confederation of the European Bicycle Industry, would like to hereby provide its comments on the European Commission’s proposal for a new General Product Safety Regulation (GPSR). For us this legislation is of particular relevance because bicycles as well as certain bicycle parts and accessories fall within the scope of this legislation.
Attached you can find our full feedback.
Read full responseMeeting with Silvia Modig (Member of the European Parliament, Shadow rapporteur)
16 Sept 2021 · Batteries and waste batteries
Response to Standardisation Strategy
9 Aug 2021
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its 15 national industry members. In the EU there are about 1,000 companies in this industry, many of them being SMEs, providing more than 155,000 direct/indirect jobs. The European Bicycle Industry brings value to the European economy in terms of jobs, investment, entrepreneurship and innovation. Plus, our environmental footprint is a net positive when it comes to the Green Economy. Local production in EU/UK results in a reduction exceeding 2-million tons of CO2 emissions per year thereby offering an important contribution to reaching the Green Deal objectives.
The European Bicycle Industry is actively participating in national, European and international standardisation bodies to develop relevant standards and update existing ones where needed. Thereby the industry is contributing towards safe products being placed on the EU internal market. These efforts have also been recognized by the European Commission as several bicycle related standards are officially recognized in European legislations including the Machinery Directive and the General Product Safety Directive (GPSD).
Overall, CONEBI welcomes the efforts of the European Commission to update its standardisation strategy due to the high importance that standards play in putting safe products on the EU internal market. As such, the European Bicycle Industry with its expertise in national, European and international standardisation bodies would be happy to advise the European Commission further on this topic.
Our detailed feedback can be found attached.
Read full responseResponse to Revision of the Machinery Directive
15 Jul 2021
CONEBI, the Confederation of the European Bicycle Industry, representing the EU Bicycle, Pedal Assist E-Bike, Parts and Accessories Industries, would like to express its views on the proposal for a new EU Machinery Regulation. CONEBI has been a member of the Machinery Working Group for the past years as well as a member of the respective expert group since its first meeting in March 2021.
The EU Machinery Directive is of high importance to the EU Bicycle Industry as it legislates the essential health and safety requirements relating to the design and construction of electrically power assisted cycles (EPACs). The fact that EPACs are within the scope of the Machinery Directive was officially acknowledged in the first Edition of the Guide to Application of the Machinery Directive 2006/42/EC of December 2009. Additionally, the widely-accepted standard EN15194:2017 is harmonized under the Machinery Directive.
Completely excluding EPACs from the scope of the new Machinery Regulation will create uncertainty for the industry and for the ongoing standardization work that aims to put safe products on the market. CONEBI acknowledges that the Machinery Directive was not designed for EPACs or other road vehicles but would like to stress that at this point there is no other more specific legislation under which EPACs may fall.
Therefore, CONEBI calls on the European Commission to clarify the scope of the new Machinery Regulation, in particular Art. 2.2(e), to state that EPACs can stay within the scope of the new Machinery Regulation until a more EU specific framework based on harmonized standards is in place. This could, for example, be something similar to a dedicated legislative framework for personal mobility devices (PMD) that the European Commission is currently preparing, and the bicycle industry is open to discuss this in further detail with EU legislators as a long-term solution. Meanwhile, adapting the scope of the new Machinery Regulation will ensure a safe harbour for EPACs.
Last but not least, looking at the work that went into preparing the proposal for a new regulation, a wide variety of aspects were taken into consideration and opportunities were given to stakeholders to comment on these. However, the decision to exclude transport vehicles from the scope seems to have occurred very close to the publication date and was stated for the first time publicly during the Machinery Expert Group on March 23rd 2021. Neither the inception impact assessment nor the impact assessment show due diligence in regards to the intention to exclude transport vehicles from the scope. In addition, CONEBI would like to highlight that the exclusion of vehicles from the Machinery Regulation was also not mentioned in the EU Sustainable and Smart Mobility Strategy published in December 2020. This raises concerns about the transparency of the decision-making process and in turn has made it impossible for the Bicycle Industry to assess the impact, give considered feedback and flag important technical aspects at an earlier stage.
Above all, the European Bicycle Industry wants to ensure legal certainty for the producers of EPACs and that safe products continue to be placed on the market. In addition, we should not forget the important contributions cycling as a healthy, environmentally friendly, accessible, inclusive and resilient transport mode can make to achieving the EU’s goals of sustainable mobility. Until a more specific framework based on well-established, harmonized standards is in place we therefore deem it best to keep EPACs within the scope of the new Machinery Regulation. To allow for a smooth transition, once a specific framework is in place, the industry would require a transition period of several years to ensure continued harmonization of relevant standards.
Please find CONEBI's complete feedback attached.
Read full responseResponse to New EU urban mobility framework
24 May 2021
CONEBI, the Confederation of the European Bicycle Industry, welcomes the opportunity to provide its feedback on the “Sustainable transport – new urban mobility framework” roadmap. We strongly believe that cycling and e-cycling can make an important contribution to sustainable transport as it is the key to developing urban transport systems that are safe, accessible, inclusive, affordable, smart, resilient and emission-free. During the COVID-19 pandemic we have seen that cycling is an integral part of urban transport but that several barriers still need to be overcome to make cycling an equal mode of transport.
For more information please read the attached statement.
Read full responseResponse to Modernising the EU’s batteries legislation
26 Feb 2021
CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its 15 national industry members. In the EU there are about 900 companies providing more than 120,000 direct/indirect jobs. Via the CONEBI’s national industry members, more than 500 small, medium and large companies are represented in CONEBI.
CONEBI welcomes the European Commission’s proposal for improved and more harmonized rules for batteries across the EU but would like to point out some key aspects in the attached document that we believe are important in order to ensure the safe placing on the market and efficient recycling of e-bike batteries.
Read full responseResponse to Sustainable and Smart Mobility Strategy
27 Jul 2020
CONEBI, which stands for Confederation of the European Bicycle Industry, represents a sector that provides more than 120.000 jobs through 900 companies. In 2019 the turnover was approximately 14€ bn and the investments in R&I amounted to more than 1€ bn.
We welcome the initiative by the EC to draft a European Strategy for Sustainable and Smart Mobility and believe that cycling should be an integral part of it as it tackles many of the problems highlighted.
The EU Green Deal states that a 90% reduction in transport emissions is needed by 2050. This can be achieved by focusing on more affordable, accessible, healthier and cleaner alternatives, such as bicycles and e-bikes which can make an important contribution to lowering GHG emissions in road transport and easing.
Bicycles and especially pedal assist e-bikes have a promising potential to substitute motor vehicle usage over short journeys. In 2019, e-bikes sales grew by 23% to 3.4 million units representing 17% of all EU bicycle sales. In some countries particular high increases of e-bike sales have been noticed due to the introduction of e-bike subsidies. Large scale deployment of bicycles and e-bikes will be further facilitated by digital solutions such as bike sharing and Mobility as a Service which also helps to improve multi-modality.
The EU Bicycle Industry is a major contributor to the EU competitiveness, innovation, sustainable manufacturing, circular economy and the overall development of Industry 4.0. Thanks to the investments in the industry and the increased sales of e-bikes, the production of bicycles and e-bikes increased by 11% in 2019 and the production of e-bikes even increased by 60% from 2018 to 2019.
However, the industry will only be able to continue this growth, if the right conditions are met:
1. The current status of EPACs remains in place;
2. The positive momentum for Cycling in the EU continues as a response to COVID-19 and more cycling infrastructure is built to give space and safety to cyclists;
3. Intelligent Transport Systems are developed within the right EU legislative and technical frameworks for motor vehicle to detect bicycles and thus making Cycling Safer.
COVID-19 also heavily impacted the Bicycle Industry. In March and April factories were closed in most EU countries, supply chains were disrupted and bike shops could repair but not sell. The economic impact in the above context is therefore considerable. We can say that the loss of sales was in a range of 15% to 60% (depending on the country) in comparison with the pre-COVID 19 forecast for March and April 2020.
In May the situation in Europe improved: factories re-opened, bike shops were allowed to sell again and Cycling was encouraged with new cycling infrastructure. What we see now is that sales will be almost fully recovered.
To achieve the targets prescribed in the European Green Deal with the support of cycling, we ask for:
1. Treating cycling as an equal partner in the mobility system, including recognising EuroVelo, the European cycle route network, as another TEN-T network in addition to existing networks such as road, rail, or inland waterways;
2. Funding at least €6bn in investments in safe, high quality cycling infrastructure in the 2021-27 MFF;
3. Improving the EU Urban Mobility policy framework by making access to EU funding for safe and attractive transport infrastructure conditional on the implementation of Sustainable Urban Mobility Plans (SUMPs) and the collection of urban mobility data;
4. Enabling a centralised €5.5 bn EU E-bike Access Fund that will make the benefits of e-bikes available in all countries in the EU and stimulate further job creation; and
5. Responding to the call of the Declaration of Luxembourg (2015) and the Graz Declaration (2018) as well as the blueprint EU Cycling Strategy: Recommendations for Delivering Green Growth and an Effective Mobility in 2030 (2017) by developing a genuine European Commission EU Cycling Strategy.
Read full responseResponse to Modernising the EU’s batteries legislation
9 Jul 2020
Please see PDF document attached
Read full responseResponse to REFIT review of the Motor Insurance Directive
23 Jul 2018
The Confederation of European Bicycle Industries (CONEBI) would like to express its opposition to the inclusion of Electrically Power Assisted Cycles (EPACs) within the scope of the Motor Insurance Directive (MID) for the following reasons:
1. EPACs are not motor vehicles and they are safe to use:
An EPAC is an Electrically Power Assisted Cycle that provides electrical assistance to the cyclist up to 25km/h only while pedalling. EPACs have maximum 250W and are excluded from the EU Type-Approval because from a regulatory point of view they are not considered motor vehicles.
Power assistance is designed ONLY to complement rather than replace the main propulsion, which is by human muscle energy through manual pedalling: if an EPAC user does not pedal, he/she does not receive any assistance. Power is limited to 250W, which is a level perfectly achievable by riders without assistance.
In addition, statistics show that EPAC users are vulnerable users and not the cause of serious injuries to third-parties.
2. The potential loss of environmental and health benefits brought by EPACs:
A mandatory third-party liability insurance for EPACs would disincentivise Cycling, with negative consequences on the environment and public health. The health benefits of cycling are over 191 billion Euro per year and EPACs are zero emission vehicles that tackle the growing problem of traffic congestions in cities.
3. A threat to industrial growth, investments and green jobs:
Every year, millions of EPACs are sold in the EU and sales are increasing: EPACs are key to the cycle industry’s future and growth; an industry which is currently investing 1 billion euro each year and provides 90,000 direct/indirect jobs EU-wide. The inclusion of EPACs in the MID’s scope will have a direct impact leading to a loss of jobs in the EU.
4. Future fragmentation and impact on exports:
A directive which provides the possibility to each Member State to exclude EPACs from the scope of motor insurance will create fragmentation at EU level. This goes against the rationale of a well-functioning single market aimed at promoting harmonisation and trade.
Hence, we kindly call on the European Parliament and Member States to amend the text so that Electrically Power Assisted Cycles are excluded from the definition of a motor vehicle. To achieve this, we propose the inclusion of the word “solely” in the text so that motor vehicles are defined as vehicles which are “solely propelled by mechanical power.” We remain open to any suggestions the European Parliament and Member States might have for the direct/indirect exclusion of EPACs in the text of the European Directive
Read full responseMeeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and EUROPEAN BICYCLE MANUFACTURERS ASSOCIATION
7 Nov 2016 · EGA negotiations
Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen) and European Aluminium AISBL and
18 Jul 2016 · China Market Economy Status