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LEVA-EU vzw

We are working for light electric vehicles (LEVs)in the European Union with a view to raising-awareness and promoting LEVs as a means of transport that can make a considerable contribution to greening mobility and making it sustainable.

Lobbying Activity

Response to Collection of urban mobility data per urban node

19 Nov 2025

Please find attached LEVA-EU's response to the proposed collection of urban mobility data per urban node.
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Response to Proposal amending the Batteries Regulation (EU) 2023/1542 as regards battery due diligence obligations

30 Jul 2025

LEVA-EU is the only trade association in the EU to represent businesses in the sector of Light Electric Vehicles, i.e. all electric vehicles which are either included in Regulation 168/2013 or excluded from the Regulation. Most of these vehicles have batteries that belong to the LMT battery-category. We agree with the Commission Proposal for a Regulation (COM(2025)258) aimed at postponing due diligence requirements. However, we also support the amendment in the attached document. Furthermore, we request the Commission to provide for clarification on the matter explained below. According to Article 47, the chapter on due diligence does not apply to economic operators that had a net turnover of less than EUR 40 million in the financial year preceding the last financial year. Article 3.1(22) defines economic operator as the manufacturer, the authorised representative, the importer, the distributor or the fulfilment service provider or any other natural or legal person who is subject to obligations in relation to the manufacture, preparation for re-use, preparation for repurposing, repurposing or remanufacturing of batteries, the making available or the placing of batteries on the market, including online, or the putting of batteries into service in accordance with this Regulation. The Battery Regulation exempts economic operators with a net turnover of less than 40 million from the due diligence requirements. However, our members report that large customers are contractually requiring them to comply regardless of this exemption. As a result, these operators are effectively compelled to meet the due diligence requirements if they wish to continue supplying these customers. In such cases, the intended purpose of the exemptionto shield SMEs from disproportionate administrative burdensis not being achieved. In the light electric vehicle sector, it is frequently the vehicle manufacturer who is the first to place the battery on the market. Many of these manufacturers qualify as SMEs. However, it remains unclear whether the 40 million turnover threshold applies solely to the battery-related turnover or to the total turnover of the vehicle manufacturer. If the latter interpretation is correct, the measure may also fail to achieve its objective of protecting SMEs. We believe it is essential for the Commission to provide clarity on this matter.
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

LEVA-EU is the voice of the European Light Electric Vehicles (LEV) sector. Our 65 member companies are active in all aspects of the European LEV sector: production and distribution of vehicles and components as well as in LEV-related services. The LEV industry is a Clean Tech industry, as should be recognised as such by the European Commission, because our sector is one of the cornerstones to reach zero emission mobility as part of the EUs climate and competitiveness goals. Due to the innovative nature of our products and services, many of our member companies are Startups and Scaleups. 1. Complex regulatory maze and burden at EU and national level 2. Undue competition with illegal products due to substandard national market surveillance 3. Complex fiscal landscape across the Single Market 4. Difficulties in raising capital to scale up 5. Difficulties in bringing innovation to the market due to legislative barriers 6. Difficulties in procuring components due to existing unjustified anti-dumping measures The above-mentioned hurdles have so far prevented LEV companies to scale up despite the huge potentials of their innovative products both within the EU and abroad. Worse still, many startups fail to bring their product to market due to all the problems mentioned. A large number of them have to stop their activities prematurely. To fully unlock the economic prospects of the LEV companies and their competitive edge, the EU and national authorities must commit to: 1. Putting in place the 28th tax regime as suggested in the Letta Report for LEV startups and scaleups so that they can easier expand across the Single Market. 2. Supporting LEV startups and scaleups as a Clean Tech industry in their bid to produce zero-emission light electric vehicles here in Europe, through innovation funds and other financial instruments. 3. Working with the LEV industry to put in place a dedicated LEV Regulation, that resolves the current regulatory blockages resulting from the inappropriate inclusion of LEVs in Regulation 168/2013 and in the Machinery Regulation. Such a dedicated LEV Regulation will also unlock the innovative zero mobility solutions that our industry can rapidly bring to the market. 4. Strengthening the ability of European LEV startups and scalesups to grow by removing the current anti-dumping measures on bicycles components from China, until when such components are competitively available in Europe or from different sources. This saves our companies from very considerable financial and administrative difficulties just to procure components. The LEV industry stands ready to dialogue with the European Commission to help policymakers better understand the current circumstances faced by our startups and scaleups.
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Meeting with Wopke Hoekstra (Commissioner) and

12 Feb 2025 · Dialogue on the future of the automotive sector - Thematic Working Group on 'Clean Transition and Decarbonisation'

Response to Single Market Strategy 2025

31 Jan 2025

LEVA-EU is the voice of the European Light Electric Vehicle (LEV) industry. We fully support the Single Market Strategys aim to strengthen an integrated home market for LEV-companies. However, to unlock the full potential of our sector, the strategy must also ensure faster and more accessible legislative updates and standardisation, particularly for SMEs and startups. Currently, the LEV industry faces severe regulatory fragmentation, creating barriers to innovation, market expansion, and sustainability goals: Outdated Vehicle Classifications in Regulation 168/2013 Inappropriate Inclusion in the Machinery Regulation According to the Court of Auditors' midway report on "Reaching EU road safety objectives", "upcoming road safety challenges, such as new forms of mobility in urban areas and the presence of autonomous vehicles, will probably require further integration and coordination of the Commissions different actions." LEVA-EU aligns with the Single Market Strategy to focus on removing existing regulatory and administrative barriers and preventing new ones from materialising. Currently, the situation for LEVs has resulted in discrepancies in the legal framework and fragmented national rules, which in turn created bottlenecks for our companies to invest and innovate. To this end, we propose for a single harmonised legislative framework for ALL LEVs. In fact, the European Commission has acknowledged the need for harmonised LEV legislation. Both the Commissions mid-term review of the EU Road Safety Policy Framework 2021-2030 and the Recommendations for Accelerated Deployment of Innovative Sustainable Solutions state: The Commission must develop harmonized technical legislation and mandate related standards, specifically for LEVs, in close consultation with the light electric vehicle sector. Despite this recognition, no legislative initiative has been taken. A dedicated LEV Regulation within the Single Market is essential to: 1. Unlock Economic Potential A unified framework will provide regulatory clarity, ensuring European LEV companies can confidently invest and innovate, maximising growth in the transport modal shift. 2. Accelerate Sustainable Urban Mobility LEVs can replace over almost 80% of all car trips, significantly advancing EU zero-carbon goals. 3. Eliminate Legislative Barriers Existing regulations hinder market access for certain LEVs (e.g., seated e-scooters, L1e-A powered cycles). Moving all LEVs from the Machinery Regulation and Regulation 168/2013 into a dedicated LEV Regulation will resolve this. 4. Incorporate Established Standards A considerable number of LEV-standards has already been developed. The Commission and MS need to acknowledge and respect this work done by European experts. The existing standards must be linked to the new LEV-Regulation and assessed based on that Regulation. 5. Enable an Innovation-Friendly, Technology-Neutral Approach LEV legislation should be evidence-based, simplified, and avoid unnecessary burdens. It must move beyond outdated classifications and power limits, focusing instead on kinetic energy and safe acceleration. The LEV-Regulation should be future-looking and technologically neutral to encourage innovation and not restrict our companies to existing form factors through outdated type-approval classification.6. Ensure Consistency Across the Single Market apart from the current fragmented regulatory landscape for LEVs, which the new LEV-Regulation will iron out, we strongly oppose current proposals (such as the 2024 PMD Report of DG GROW) to apply new "universal approval schemes" to only certain LEVs while excluding electric cycles. This will add to even further fragmentation and ineffective implementation of rules. A LEV-Regulation will avoid divergent national technical requirements by MS, further exacerbating the administrative and regulatory burden for the sector. LEVA-EU urges the European Commission to act now and develop a dedicated LEV-Regulation
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Response to European Critical Raw Materials Act

30 Jun 2023

LEVA-EU is the only trade association in Europe to work exclusively for businesses in the sector of light electric vehicles (LEVs). We currently have over 80 members, a large majority of which are SMEs. Their activities are focussed on the production, import and/or distribution of a variety of light, electric vehicles and LEV-components, including motors that include permanent magnets. On a general note, LEVA-EU and its members are in full support of measures to improve the sustainability and circular economy for LEVs. However, it should be noted that a very large majority of companies in the LEV-sector consists of SMEs, often labelled by European authorities as the backbone of the economy. SMEs in the LEV-sector are already subject to an impressive set of rules and regulations including an ever growing number of administrative obligations. We therefore urge the Commission to request for a study on the potential savings on critical raw materials by downsizing and reducing the weight of both shared and privately owned road vehicles. The average hybrid or electric vehicle uses between 2 and 5 kg of rare earth magnets. Therefore, the substitution of ICE-cars by electric cars will unleash an unparalleled demand. The aggregate weight of magnets in LEVs will no doubt be many times less. Therefore, the substitution of cars by LEVs will make an unparalleled contribution to a sustainable demand and supply of these magnets. For all these reasons, it is particularly important to carry out a cost/benefit analysis regarding the extraction and recycling of permanent magnets in LEVs. This analysis should consider the contribution of LEVs to sustainable mobility. In addition, there are several articles in the proposed Regulation that will create very specific problems for the LEV sector. In the attached position paper we explain these problems and we propose amendments to solve the problems.
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Response to New EU urban mobility framework

25 May 2021

LEVA-EU is the only trade association in Europe that works exclusively for light electric vehicles. LEVA-EU currently represents more than 60 companies, active in various parts of the LEV-business. The term light, electric vehicle (LEVs) includes a range of vehicles with one or more wheels that offer affordable, accessible, healthy and clean transport. These vehicles are included in the L-category or excluded through Article 2.2 of Regulation 168/2013. The pandemic has clearly shown to what extent LEVs offer a solution for sustainable transport. Thousands of cities throughout Europe, literally gave way, not only to pedestrians and cyclists but also to electric bicycles, electric cargo bikes, e-scooters, electric mopeds, light electric three and four-wheeled vehicles: affordable, accessible, healthy and clean transport. And yet, the EU and its member states either ignore or marginalize LEVs, or both. With the UK and the Netherlands, we only quote 2 examples of countries that are still not allowing e-scooters on public roads. In other member states, millions of citizens use them for short trips ... trips, a large percentage of which previously would have been done by car. And still, the Commission is focussing to a very large extent on electrifying cars. In the meantime, millions of people have taken up commuting by e-scooter, e-bike, speed pedelec, ... whilst a growing number of businesses deliver their goods and services by electric cargo bikes. The growing shortage of road space for pedestrians, bicycles and LEVs stirs up a public and political debate, not about pushing back big, polluting, noisy, dangerous, expensive vehicles and giving back space to affordable, accessible, healthy and clean travel. The debate is about how to continue to squeeze all that sustainable transport onto little strips on the side of the road. LEVs first and foremost need the right regulatory framework. Their uptake is very seriously hampered by European and national regulatory bottlenecks, which the Commission fails to solve. We believe that the New Urban Mobility Framework should be used as a prime opportunity to remove those bottlenecks. The plea for taking LEVs out of the legislative framework for ICE mopeds and motorcycles to give them their own accurate framework is more than 20 years old. The LEV market still consists for a large part of e-bikes with pedal assistance up to 25 km/h and 250W. These are the only LEVs to enjoy their own regulatory and non-regulatory framework. The market needs new solutions, a wider variety of vehicles but Regulation 168/2013 remains untouched, causing no type-approvals in L1e-A, huge constraints for ecargo-bikes and speed pedelecs, increasing divergence in national rules for e-scooters and many people with physical impairments being denied access to e-bikes. Furthermore, LEVs need exchange of good practice, research and regulatory support for: • sufficient and safe on and off-road infrastructure for LEVs • the modernisation and update of national traffic codes, which today or still based on outdated vehicle concepts • the integration of LEVs in MaaS • the development of the most effective fiscal incentives • the integration of LEVs as fully-fledged transport solution in public procurement The Urban Mobility Framework should be used to raise awareness among EU, national and local policymaker as to the potential of LEVs in “delivering a 90% reduction in transport-related greenhouse gas emissions by 2050 to support the EU’s aim to become the first climate neutral continent.” LEVA-EU herewith calls upon the Commission to study light, electric vehicles, to research and acknowledge their potential for providing affordable, accessible, healthy and clean transport and to start a dialogue with LEV-businesses and users. LEVA-EU calls upon the Commission to give LEVs a prominent role in the Framework since they will play a key role in delivering the 90% less GHG emissions.
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

As the European trade association for the light, electric vehicle sector, LEVA-EU welcomes the Commission’s proposal to include specific provisions for batteries for ‘light means of transport’ in the draft Regulation. However, if the current proposals are upheld, they will constitute no less than an existential threat to the European market of light, electric vehicles (LEV). All furhter details are in the attached position paper
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Response to Sustainable and Smart Mobility Strategy

21 Jul 2020

LEVA-EU Feedback on the Commission’s Roadmap for an EU Strategy for a Sustainable and Smart Mobility LEVA-EU is the only trade association in Europe that works exclusively for light electric vehicles. LEVA-EU currently represents around 50 companies, active in various parts of the LEV-business. The term light, electric vehicle (LEVs) includes a range of vehicles with one, two, three or more wheels that offer affordable, accessible, healthy and clean transport. These vehicles are included in the L-category or excluded through Article 2.2 of Regulation 168/2013. The objectives for the future Sustainable and Smart Mobility Strategy include: • Increasing the uptake of zero-emission vehicles • Making alternative solutions available to the people and businesses • Supporting digitalisation and automation • Improving connectivity and accessibility To what extent are LEVs at the forefront of the Commission’s mind in achieving these objectives? And yet, COVID-19 has clearly shown to what extent LEVs effectively offer a solution for sustainable transport. Thousands of cities throughout Europe, literally gave way, not only to pedestrians and cyclists but also to electric bicycles, electric cargo bikes, e-scooters, electric mopeds, light electric three and four-wheeled vehicles: affordable, accessible, healthy and clean transport. And yet, the EU and its member states either ignore or marginalize LEVs, or both. With the UK and the Netherlands, we only quote 2 examples of countries that are still not allowing e-scooters on public roads. In other member states, millions of citizens use them for short trips ... trips, a large percentage of which previously would have been done by car. Fifty percent of all car trips in the EU are less than 5 km and 30 percent even less than 3 km. And still, the Commission is focussing to a very large extent on alternative fuels and on charging infrastructure, in other words on cars. In the meantime, millions of people have taken up commuting by e-scooter, e-bike, speed pedelec, ... whilst a growing number of businesses deliver their goods and services by electric cargo bikes. The growing shortage of road space for pedestrians, bicycles and LEVs stirs up a public and political debate, not about pushing back big, polluting, noisy, dangerous, expensive vehicles and giving back space to affordable, accessible, healthy and clean travel. The debate is about how to continue to squeeze all that sustainable transport onto little strips on the side of the road. LEVs do not need alternative fuels, nor charging infrastructure. They all work on small amounts of electricity, which they can get from just plugging them into any power point. LEVs first and foremost need the right regulatory framework. Their uptake is very seriously hampered by European and national regulatory bottlenecks, which the Commission refuses to solve. Our full feedback is in the attached document
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Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

In showing the EU the way to a climate-neutral economy by 2050, the Long-Term Climate Strategy of the Commission overlooks a key player in the decarbonisation of mobility, i.e. light, electric vehicles (LEVs) such as electric bicycles, scooters, motorcycles, light 3 and 4-wheeled vehicles, … E-bikes constitute the single biggest EV success in Europe. Sales in 2018 are estimated at 2.5 million and have been growing steadily since the 2nd half of the 90's. An ever growing part of the EU population is discovering e-bikes and other LEVs as the ultimate solution for a large part of their mobility. They are being encouraged by the increasing number of European cities that ban not only petrol - but all private cars as well as all larger vehicles from their city centres. In these instances, electric propulsion is not a solution unless it is in small, light vehicles. That is one of the reasons why the use of electric cargo bikes in cities is surging. Large distribution companies introduce micro-hubs at the urban peripheries where trucks unload and electric cargo bikes load for the last mile. And yet, the European institutions seem to lack the necessary awareness of this success and of the potential of LEVs to include them into relevant EU policies. The Long-Term Climate Strategy is only one of the many examples of policy documents completely overlooking LEVs even though they can play a crucial role. In the AFID, LEVs have not been completely overlooked. In the Directive, the L-category, which covers most LEVs is mentioned twice in the preambles. Article 4.13 announces EU standards for recharging points for L-category vehicles. There is now a draft Regulation that includes references to specific standards for the benefit of L-category vehicles. Unfortunately, the current Directive holds no real incentives to encourage MS to also consider L-category vehicles in their NPFs. This is a missed opportunity that needs amending in the review of the AFID, especially in view of the huge success of LEVs in urban areas. If the Commission requires MS states to add L-category vehicles to the scope of their NPFs, that would allow for an assessment of the current state and future development of the charging infrastructure for L-category vehicles. Furthermore, it will help to raise awareness of LEVs among MS. The 2017 summary on national plans for alternative fuel has 3 references to e-bikes. Austria, Belgium and Luxembourg just mention that in this framework they also pay attention to electric bicycles. That is only 3 out of 28! And yet, the Belgian region of Flanders for instance puts commendable efforts into LEVs in this framework. Every year they launch a call for projects including LEVs in the framework of CPT. As a result, in 2017, an exhaustive report on the potential of LEVs was published (https://bit.ly/2UHHygU). Since last year, a project is ongoing on the potential of speed pedelecs for commuting (https://365snel.net/) In order to raise awareness for LEVs among all 28, the Commission should require MS to: - include LEVs in their assessment of the actual state and future development of the market. - include LEVs in their national targets & objectives as well as in their measures to ensure that these targets & objectives are reached. - in designating urban/suburban agglomerations for public charging points so that the charging infrastructure can also be used by LEVs. We believe that a proper cost-benefit analysis would show that these measures for the benefit of LEVs are beneficial for charging infrastructure in general. These measures do not need additional infrastructure, they just need adding charging facilities for LEVs to installed or future charging points. Charging points that can be used by both electric cars and LEVs will be much more efficient/effective. It will also avoid charging points becoming redundant should a city decide to ban all cars.
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and Portland PR Europe Limited

29 Nov 2018 · anti-dumping and anti-subsidy investigations on e-bikes

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

13 Sept 2018 · Electric bicycles issues

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Portland PR Europe Limited

25 Jun 2018 · electromobility

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and Portland PR Europe Limited and Squire Patton Boggs LLP

19 Jun 2018 · Light Electric Association