EN15194
3.1 cycle
vehicle that has at least two wheels and is propelled solely or mainly by the muscular energy of the
person on that vehicle, in particular by means of pedals
3.3 electrically power assisted cycle
EPAC
cycle, equipped with pedals and an auxiliary electric motor, which cannot be propelled exclusively by
means of this auxiliary electric motor, except in the start-up assistance mode
4.2.16 Failure mode
4.2.16.1 Requirements
It shall be possible to ride the EPAC by pedalling even if the assistance failed.
4.2.16.2 Test method
This requirement shall be checked as described in 4.2.16.2.
a) Remove or disconnect the battery pack.
b) Ride the bicycle up to 10 km/h.
Frikar/Podbike say:
CLASSIFICATION
Frikar ebike is classified as cycle within Europe (you can use bike lanes). No licence or registration needed.
and
- Frikar ebike is designed to be an EPAC/Pedelec within regulations as defined for EU; i.e. max assisted speed 25 kph, max continuous assist power 250W and assist cease to function if cyclist stop pedalling
MOTORS
Two motors, one in each rear wheel, is the only propulsion – no greasy chains.
A compact generator propelled by pedals provide human power input. An electronic transmission complying to pan-European requirements for electric assisted cycles. We use a battery pack specially developed for electronic transmission on cycles in Nordic climate.
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1. All experiments with 2 motors and generators are gambling that the legislation in target market countries will be modified so that they are legally considered to be cycles. If the manufacturer does not obtain those modifications to the law then the vehicle will need to be type approved in one of the many light electric vehicle classes. Special clauses had to be written into the French road code for Segway and electric scooters etc. They are all limited to 25 km/h top speed, even downhill, and require a helmet and security vest when used on the road. Please show me where
"An electronic transmission complying to pan-European requirements for electric assisted cycles." is formalised? It isn't in EN15194:2017 in any case.
2. Frikar/Podbike (and others) are not being honest when they say, as copied from the web site and cited above, that they are fully within EPAC regulations. They can not be because EN15194 applies to bicycles with electric assistance, and
https://www.podbike.com/faqs/frikar-speed/ says that Frikar is a light electric vehicle in all letters, it is powered by a motor over and beyond 25 km/h!!! They also all fail 4.2.16. If you fail a test you can not be an EPAC (hint: the second motor is not auxiliary, it is the main motor...)
3. After reading through it is clear that any trike or vélomobile with electric assistance can only be considered to be "within the spirit of EN15194" if they are limited to 25 km/h assisted speed and 250W nominative power with a 48v nominative battery. That last point is also new in the 2017 version because previously the voltage was limited to 48v
maximal voltage. You are more or less an EPAC but not a bicycle within EN15194 so no special marking is required. I would put a sticker on with "cut off speed 25 km/h, maximun continous rated power 0.25 kW" however.
I am not personally hostile to light electric vehicles. I can not accept "fake news" however and companies pretending that their product is something which it is not. Light electric vehicles belong on the road and not the bicycle path.
Long and interesting read which, for me, sounds the death bell for bicycle kit conversions. That is what Bosch and Co, wanted all along. Even Bafang prefers to sell complete systems to bicycle manufacturers these days.