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Federation of European Motorcyclists' Associations

FEMA

The Federation of European Motorcyclists' Associations (FEMA) is the European federation of national road rider organisations.

Lobbying Activity

Meeting with Hannes Heide (Member of the European Parliament)

11 Sept 2024 · Reception

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

16 Jun 2024

To the European Commission, 16 June 2024 Federation of European Motorcyclists' Associations (FEMA) wants to express its concerns with the current Block Exemption Regulation 461/2010. The task of the Block Exemption Regulation is to ensure free competition on the motor vehicle market in terms of access to information, the possibility of servicing motor vehicles under warranty, access to spare parts, etc. Our point of concern is that motor vehicles with two wheels are currently not covered by the regulation. In CHAPTER 1 COMMON PROVISIONS Article 1 Definitions, there is under section g indicated: (g) "motor vehicle" means a self-propelled vehicle intended for use on public roads and having at least three wheels; The description that motor vehicles are defined with three wheels and above excludes motorcycles from free competition and allows manufacturers, importers and brand dealers to void the warranty if a motorcycle has been serviced (not repaired) by an independent motorcycle workshop. Furthermore, we have experienced that when a used, newer motorcycle under warranty is resold by an independent motorcycle dealer, the remaining warranty is removed from the motorcycle, which means that the customer no longer has a warranty on his motorcycle. Therefore, we propose that in CHAPTER 1 COMMON PROVISIONS Article 1 Definitions, point g the indication of the number of wheels is removed and will in the future say: (g) 'motor vehicle': a self-propelled vehicle intended for use on public roads. With regards, Wim Taal, General Secretary. Federation of European Motorcyclists' Associations (FEMA) Avenue des Arts 47 B-1000 Brussels - Belgium
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Response to Cross-border enforcement of road traffic rules

20 Apr 2023

FEMA welcomes the proposals for the revised cross-border enforcement Directive (EU) 2015/413. We also support the addition of several traffic offences that are related to road safety. The enhanced possibly to be prosecuted or fined after a traffic rule violation will probably lead to less traffic offences. This could in general lead to more road safety. However, we have some concerns,Several items in the propsed directive give us reason for concern because they provide a large risk for the privacy of our citizens. We therefor urge the Commission to reconsider the opportunity for authorities to directly collect information from databases in other countries to this purpose without any form of applicability check in advance. For a more detailed reaction we refer to th eattached paper.
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Response to Revision of the Directive on Driving Licences

20 Apr 2023

FEMA welcomes the proposal for a revision of the third driving licence directive 2006/126/EC (3DLD) and supports the intention of the European Commission to improve road safety, further reduce administrative burdens, and facilitate the freedom of movement. The digital driving licence can be an improvement in facilitating the freedom of movement. We also welcome the proposed standard administrative validation of 15 years for driving licences A and B. However, we are disappointed on some elements, which includes the way hazard perception is included in the tetst, the unchanged progressive access to the A-licence, the absence of a solution for towing trailers behind a motorcycle, the lack of harmonisation of riding a small motorcycle with a B-licence with some additional requirements. For a more detailed overview and motivation we refer to the attached paper.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

8 Nov 2022 · Road safety

Response to Approval of automated vehicles and of systems intended for such vehicles

13 Apr 2022

The Federation of European Motorcyclists' Associations (FEMA), representing the European riders of powered two- and three-wheelers (PTTWs) considers it of the upmost importance that vehicles that are equiped with provisions that take away part or even the entire driving task from the driver detect and react in a safe way to other (partly) automated and/or connected vehicles, not automated and/or connected vehicles, including PTTWs, and other L-category vehicles, as well as other road users as bicyclists and pedestrians. Systems like AEB, LKAS, BSW, ACC etc. are at present not always designed with PTTWs in mind and/or tested with PTTWs and provide therefor a potential danger for the PTTW riders. Future systems should provide no danger anymore. This means that all parts of the vehicle that play a role in (partly) automated driving as well as the relevant software must be designed with PTTWs in mind, tested with PTTWs and other road users and found safe for PTTWs and other road users before a vehicle or the relevant part of the vehicle are allowed to be used on the public roads in the EU. This also means that the relevant parts and the software of the (partly) automated vehicle must be part of the periodical technical inspection of the vehicle to ensure correct and safe reactions of the vehicle and its driver to PTTW riders and other road users during the whole operational time of the vehicle.
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Response to Revision of the Roadworthiness Package

13 Oct 2021

FEMA represents the European riders of powered two-wheelers. Our view on the Vehicle safety – revising the EU’s roadworthiness package is to be found in the attached communication.
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Response to New EU urban mobility framework

21 May 2021

FEMA thanks the European Commission for the opportunity to provide feedback on this important topic. please find our view in the attached document.
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Response to Revision of the Directive on Driving Licences

5 May 2021

See the attached file.
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Response to Revision of EU legislation on end-of-life vehicles

17 Nov 2020

The Federation of European Motorcyclists’ Associations (FEMA) thanks the European Commission for the opportunity to give its vision on the revision of the End-of-life Vehicles Directive (2000/53/EC). In FEMA’s view, the current Directive succeeded in preventing waste from vehicles, the reuse of parts from vehicles and improvement of the environmental performance of all economic operators involved in the life cycle of vehicles. We can also understand the need to extend the scope of the directive to other kinds of vehicles than cars. However, extension of the working of the Directive to powered two-wheelers (PTWs) is less obvious because of the different nature of both use and build of PTWs. PTWs do not have a body like cars; they can have body parts attached to the frame, but this cannot be compared with the body of cars. Most PTWs spend the largest part of their live indoors and as a rule are used for far less kilometres than cars. Because of this, and because parts can easily be removed, PTWs seldomly reach the end of their life like other vehicles do. Virtually all PTW parts can be reused, through a large network of specialised second-hand part suppliers throughout the European Union, or by users themselves who swap and change parts with other owners. Parts that are not reused are recycled through local recycling schemes or sent on by second-hand part shops. There is no evidence of PTWs being dumped beside the road or otherwise disposed of in an inappropriate manner. Inclusion of PTWs could even be contrary to the aim the directive, by causing a problem where none exists now. In particular, the certificate of destruction may prohibit users from dismantling their vehicles for the purpose of reusing components. Furthermore, the administrative requirement on specialised second-hand parts businesses, which are generally small and medium-sized enterprises (SMEs), could mean job losses. An exception could be made for electric powered vehicles (EVs). The demolition of EVs is specialistic work that should not be done by unqualified people. To ensure that the demolition of PTWs with a combustion engine can still be done in-house by the owners themselves or by SMEs, and to ensure that demolition of electric PTWs is done by qualified specialists, FEMA suggests not to include PTWs in the End-of-life Vehicles Directive but to draw a separate Directive for powered two-wheelers and perhaps other L-category vehicles. If the European Commission does propose to include motorcycles and other powered two-wheelers in an End-of-life Vehicles Directive, FEMA would ask the Commission to ensure that the possibility of controlled in-house demolition remains possible (as part of a circular economy), either by including it in the Directive, or by allowing Member States to make their own rules and regulations for in-house demolition. If the European Commission does propose to include motorcycles and other powered two-wheelers in an End-of-life Vehicles Directive, FEMA would ask the Commission to ensure that historic PTWs or PTWs of value to collectors or intended for museums, kept in a proper and environmentally sound manner, either ready for use or stripped into parts, do not fall within the scope of this Directive.
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Response to Rules on vehicle transmission and test vehicles for A2 motorcycles driving licences

1 Jul 2019

FEMA welcomes the reduction of the A2 test motorcycle requirements to 250 cm3. However, we would like the European Commission to reconsider the present staged access that raises an extra threshold for new riders.
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Response to REFIT review of the Motor Insurance Directive

24 Jul 2018

Please see attached document.
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Response to Road infrastructure and tunnel safety

9 Jul 2018

When it comes to road safety for vulnerable road users (VRUs) safe infrastructure is of the utmost importance. VRUs do not have a cage that protects them against impacts. Obstacles on the road or on the roadside have more impact. Because of their smaller size, they are harder to detect, especially when obstacles on the road side partially block the view. FEMA supports the proposal for the directive to amend Directive 2008/96/EC on roadside infrastructure safety management (RISM Directive). We are pleased with the Safe System approach, and we are especially pleased with the inclusion of the motorways and primary roads outside the trans-European transport network (TEN-T) and roads outside urban areas that are build using EU funds in whole or in part. We also welcome the change that makes it mandatory to systematically take vulnerable road users into account in all road safety management procedures. We will highlight some of the proposed measurements; 1. Road restraint systems. At present the systems that are in use are not safe for motorcyclists. A motorcyclist who crashes into a barrier has a far less chance to survive than other road users. “In terms of fatalities per registered vehicle, motorcycle riders are dramatically overrepresented in numbers of fatalities resulting from guardrail impacts. Motorcycles compose only 2% of the vehicle fleet, but account for 42% of all fatalities resulting from guardrail collisions” ( H.C Gabler, 2007). In Sweden barriers are the most common crash cause in fatal motorcycle accidents. In 2017, 8 out of 36 motorcyclists died after hitting a barrier. In 2016, the number was 9 out of 37. The cause for this is both the choice of type of barrier and the way they are installed. Especially the cable (or wire-rope) barriers and W-beam barriers without underslide protection are responsible for many fatalities and serious injuries of motorcyclists. The poles are very dangerous for motorcyclists. Barriers that take motorcyclists into account and new test standards that include all kinds of barriers and more accident scenarios are necessary, as are directives that prohibit the installation of barriers too close to the roadside or on places where they are not really necessary. 2. Other objects: a certain distance of fixed and non-fixed obstacles from the roadside is important for VRUs for two reasons: first the risk of collision and the fact that motorcyclists and bicyclists have no protective cage, second because of the limited visibility of motorcyclists, bicyclists and pedestrians because of their smaller size. Already in 1989 the Hard report mentioned this as the most important accident cause were other vehicles were involved. Obstacle free roadsides (including road restraint systems) are extremely important for motorcyclists and other VRUs. 3. Pavement is listed as element of inspection. At present, there is only a technical specification for measuring skid resistance. This means that measurements are done in various ways, although they have one thing in common: the parts of the roads that are measured are not the parts where motorcyclists ride and the measurements are averaged to stretches of 20 to >100 metres. For motorcyclists, a stretch of 2 meters that does not meet the skid resistance standards can be enough to lose balance and crash. Also repairs with bitumen that are not detected with the present ways to measure can be very slippery and dangerous for motorcyclists. Therefor we need new ways to measure the skid resistance and new standards. New ways are available yet and offer also a way to detect potholes, rutting etcetera. The RISM Directive gives the opportunity to have better standards fore the measurements and foresees in an adequate follow-up. The proposals of the Commission are very important to enhance the road safety for motorcyclists and other road users.
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Response to General Safety of Vehicles and Pedestrians

20 Jul 2017

FEMA strongly supports the third option (Regulatory initiative (wider scope)) and sees benefits for the road afety for all road users, including the drivers of powered two-wheelers (mopeds and motorcycles). Having said this, we stress the necessity of including powered two-wheelers in the development and testing of accident avoidance (active) safety measures, especially those that are designed for use outside the urban areas. For example automatic emergency brake systems that are designed for use on motorways should always be tested with motorcycles and not only with cars. We would also like to see an extension of the safety measures for trucks and busses to T-category vehicles that are allowed on public roads, because too many fatal accidents and accidents leading to severe injuries happen between these vehicles and two-wheelers, including bicycles.
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