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EUROPEAN BICYCLE MANUFACTURERS ASSOCIATION

EBMA

Bicycle Advocacy, Creating many more Green Jobs in EU, Enhancing Bicycle Infrastructure in the EU.

Lobbying Activity

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

The European Bicycle Manufacturers Association (EBMA) represents the EU Bicycle, Pedal-Assist E-Bike and Bike Components Industry with more than 900 SMEs and 110.000 Workers in 23 of 27 EU Member States. The EU Bicycle, Pedal-Assist E-Bike and Bike Components Industry is a major contributor to the EU’s decarbonization goals and forms one of the EU’s Green Industries. In light of these observations, EBMA would like to welcome the EU Commission’s initiative to establish a carbon border adjustment mechanism which will ensure that the price of imports reflect more accurately their carbon content in order to accomplish the EU’s green goals and ensure a level-playing field. Indeed, the Bicycle, Pedal-Assist E-Bike and Bike Components Industry is a very good example of a sustainable EU industry developed locally by SMEs: realistically, the only possible way to seriously cut CO2 and Sulphur dioxide emissions, and create long-term green jobs, is to help and defend the development of EU manufacturing SMEs. One bicycle or pedal assist e-bike made in the EU generates 61kg to 123kg less CO2 and lethal emissions such as sulphur dioxide than one imported from China. The import of 20 million bicycles and e-bikes, which is the annual EU demand, from China would result in over 2 Million tons of extra emissions globally. As proven in the study of the Milan Politecnic, these additional emissions would result from: • 50% by the difference in the manufacturing carbon footprint in China which still relies heavily on coal (for instance, aluminium production in China relies on coal up to 80%, while EU aluminium production uses only 5% coal). • the other 50% because of transport emissions: containerships still use heavily polluting sludge oil which causes lethal emissions of sulphur dioxide, and over 60% of containers go back to China empty because of the trade imbalance between the EU and China. Moreover, the reduction of greenhouse gas emissions with the shift to renewable energy is a major goal for the EU, as stated in guidelines such as the “European Green Deal” (European Commission, 2019), the “2020 climate and energy package” (European Commission, 2008), the “Roadmap for moving to a competitive low-carbon economy in 2050” (European Commission, 2011) and the “2030 framework for climate and energy policies” (European Commission, 2014). China is by far the biggest polluter in the world and will continue using more and more coal-based energy until 2050 thanks to its unjust status as a developing country (rather than industrialized country) confirmed in the Paris Agreement COP 21. You can also see the pollution radar here: https://earth.nullschool.net/cs/#current/chem/surface/level/overlay=cosc/orthographic=120.92,24.23,450/loc=114.120,24.762 Further, regarding circular economy, the EU bicycle, e-bike and components industry has already started investments now with the EU aluminium industry to adapt secondary alloys for cycle components in the near future. This would improve further and significantly the carbon footprint of EU-manufactured bicycles, e-bikes and components. Moreover, EU pedal assist e-bike producers have for many years been in the lead worldwide in the promotion of the recycling of old batteries. In addition, EU tire producers are already adopting green compounds made largely from recycled and renewable rubber.
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Response to REFIT review of the Motor Insurance Directive

18 Jul 2018

I am replying on behalf of the European Bicycle Manufacturers Association (EBMA): we are very much against the inclusion of Electrically Power Assisted Cycles (EPACs) within the revision of the Motor Insurance Directive because of the following reasons: EPACs are not motor vehicles: it is a matter of regulatory consistency 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. Environmental and health benefits at risk A mandatory third-party liability insurance for EPACs users is an over-regulatory barrier that would have a severe impact on the environmental and health benefits deriving from cycling an EPAC: the health benefits of cycling are over 191 billion Euros per year and EPACs are zero emission vehicles that tackle the growing problem of traffic congestions in cities. If motor vehicle insurance were to be made compulsory for EPACs, EPAC users would be discouraged from cycling, and the mentioned benefits be lost. The European Commission has left out the opinions of the Transport and the Public Health sectors in trying to understand the costs and benefits within a thorough impact assessment. Jobs and investments at risk EPACs are a key part of the cycle industry's future employment growth potential. Current EPAC sales show that in the European Union, millions of EPACs are sold every year and sales are increasing constantly. The inclusion of EPACs in the scope of the MID would directly impact an industry that invests 1 billion euro per year in research, innovation and development and which provides 90,000 direct/indirect Green jobs across the EU. A functioning Single Market stimulates trade and improves efficiency. The European Commission’s proposal would have the opposite effect as it indirectly foresees the possibility for each European country to exclude EPACs from the scope of the revised Motor Insurance Directive just in its own territory: that would undoubtedly create fragmentation at European level with a negative impact on exports within the European market. Divergent implementation by EU Member States of the Motor Insurance Directive with regard its scope of application would not represent a positive outcome. Complexity of extending the current motor insurance regime and risk of significant non-compliance The complexity of extending the current motor insurance regime to many millions of additional vehicles will result in significant non-compliance, leading to an increase in uninsured driving. EPACs are not dangerous EPACs are not dangerous so no mandatory third-party liability insurance burden should be put on EPAC users. Statistics show that EPAC users are, at all effects, vulnerable road users and not the cause of serious third-party injuries. In conclusion we call on the European Parliament and Member States to amend the text. We would like to see a definition of a motor vehicle within the legislation that excludes Electrically Power Assisted Cycles. More specifically we would like to see “motor vehicle” defined with the word “solely” included in the text, therefore a motor vehicle should be a vehicle that is “…solely propelled by mechanical power”.
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Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and Confederation of the European Bicycle Industry ASBL

7 Nov 2016 · EGA negotiations

Meeting with Cecilia Malmström (Commissioner) and

7 Nov 2016 · Ecological Goods agreement

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

29 Jan 2016 · Impact of China MES

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion) and The European Steel Association and

2 Dec 2015 · Le statut d’économie de marché de la Chine.

Meeting with Jean-Luc Demarty (Director-General Trade) and The European Steel Association and

10 Nov 2015 · EU industry and China

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen) and The European Steel Association and

17 Sept 2015 · EU-China trade relations

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and The European Steel Association and

17 Sept 2015 · Presentation of a study

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

17 Sept 2015 · AEGIS presenting new study on consequences of granting MES to China

Meeting with Bernd Martenczuk (Cabinet of First Vice-President Frans Timmermans) and The European Steel Association and

17 Sept 2015 · Market economy status for China