The Bicycle Association of Great Britain (BA) is the trade association representing the cycling industry in the UK. The 70+ BA member companies cover all sectors of the industry: manufacturers, distributors, retailers and services. www.bicycleassociation.org.uk
A small number of our member companies already supply e-scooters, either as retailers or distributors.
Please note that this submission should not be taken as representing the individual view of all member companies of the Bicycle Association, some of who will also be providing separate evidence to the Committee and to the other relevant consultations. This submission aims to represent the broad views and interests of the UK cycle industry as expressed to our Association.
The BA is aware of a growing number of reports, including some from overseas, concerning e-scooter safety, and about other aspects of their introduction. We would urge some caution in this regard:
With this in mind, the BA supports the Government’s intention to trial e-scooters in UK conditions before making any final recommendations about regulation.
The discussion document to which we referred earlier provides considerable further detail on all of these aspects (and some alternatives which we considered), but for convenience we summarise overleaf an approach which the BA believes would be acceptable to a broad range of stakeholders.
Exempted from motor vehicle requirements. Regulated under “New Approach” product safety regulations including General Product Safety, Machinery, EMC, REACH, RoHS and with suppliers incurring responsibilities under WEEE and Batteries regulations. (this is similar to the e-bike regulatory landscape, and largely relies on self-declaration of conformity via CE marking)
Electric propulsion only, must have 2 wheels in line. Standing, no seating position. Single rider. Brake/drive controls on a handlebar in front of the rider
20 km/h (12.5 mph)
Rated motor power
250 W continuous rating, as determined by EN15194 or UNECE R85
Minimum wheel size
200 mm (8”)
Brakes to be fitted on both front and rear wheels. At least one braking system to be independent of the vehicle’s electrical system. Braking levers arranged with the front brake(s) operated by the right hand. Brakes to be in “efficient working order” for legal use.
Braking performance requirements: TBC (no standard is yet available, but EN 17128 is close to publication and may provide a basis for requirements. The BA is happy to provide more details about e-scooter standards on request)
Mandatory reflectors front, rear, side. Lights required when used at night only. Detail of lighting regulations can be similar to those for bicycles
No mandatory audible warning device
Marked visibly and durably with:
Other C&U reqs
Fitted with (a) a battery which does not leak so as to be a source of danger (b) a device biased to the off position which allows power to come from the motor only when the device is operated to achieve that result
Cycle lanes and roads only, as cycles
We would like to draw the attention of the committee to a number of specific considerations which have been flagged by stakeholders as of particular concern, or which are to a degree unresolved by the suggestions on the previous page:
The 25 km/h cut-off for the electric assist on e-bikes provides a reasonable upper limit for e-scooters for the reasons expressed earlier, and is favoured by many e-scooter suppliers and rental companies. But we suggest a lower (20 km/h, 12.5 mph) e-scooter limit for the following reasons:
We believe 20 km/h is fast enough attract users from cars and public transport by offering reduced journey times in cities (because users are not caught in congestion, and are able to use cycle lanes and back routes), but not so fast as to compromise the appeal of cycling as the first active travel choice for most urban journeys.
We have seen it argued that because e-bikes can provide up to 250W assistance as well as the human power used to propel them, e-scooters should have motors rated above 250W to maintain equivalent performance, for example 350W or 500W.
The BA has some concerns about this.
Concern has been expressed that there may be liability issues for local authorities responsible for roads who may be unable to guarantee that road surfaces etc are kept to a standard which is safe for use by e-scooters.
This can be addressed in part through a minimum wheel size requirement (we suggest 8” as a starting point).
It can be difficult to maintain control of an e-scooter when lifting a hand from the bars, for example to indicate. If lifting the right hand, motor power will also be lost, resulting in unwanted loss of speed.
The BA believes that this could be a significant issue, especially for other users of cycle lanes or roads who may find it hard to anticipate manoeuvres made by e-scooter riders if they do not have a practical form of signalling. We suggest that e-scooter trials examine this area closely.
The cycle industry is proud to contribute, through our products, to the health of the nation. The health benefits, both mental and physical, of cycling are well documented. And with the COVID-19 outbreak, the advantages for socially distanced transport have also come into focus.
E-scooters have potential to contribute to the necessary shift from public transport, which is likely to be constrained in capacity for some time, to independent mobility which does not contribute to car use congestion.
We hope that the DfT’s e-scooter trials may investigate whether there are any health benefits or disbenefits to e-scooter use, and also to investigate whether users would otherwise have made their journeys by car, public transport, on bike or on foot. If there is significant evidence that e-scooters reduce active travel, legislators should take this carefully into account.
The BA has for some years promoted cycle industry awareness of and compliance with environmental and recycling legislation relating to WEEE and batteries, especially for e-bikes. E-bikes are durable products (with a service life of up to 10 years) and almost without exception they have battery packs which are easily removable.
We have some concerns that e-scooters may have a lower in-use life and that some batteries may not be easily removable – and also that there may be scope for awareness of producer responsibilities to be raised among some e-scooter suppliers.
This is perhaps a matter on which the Committee could consider consulting the various agencies responsible for these particular items of legislation, or simply consider ensuring that any messaging around eventual legalisation highlights these producer responsibilities for suppliers, to ensure good ‘level playing field’ compliance across both e-scooter and e-bike suppliers.
It is always a concern that any new regulated class of vehicle will be tampered with to increase its power, speed or other aspects.
This has been addressed very seriously by the e-bike industry, with the harmonised standard for e-bikes (EN15194-2017) containing a number of provisions aimed at preventing any unauthorised modifications. The BA is contributing to further development of this section, which obliges manufacturers to build anti-tampering measures in at the design stage.
However, it is impossible to prevent modification completely by technical measures.
The BA would therefore recommend that the Committee consider the merits of a new offence, which would make it illegal to modify either an e-bike or e-scooter so that it no longer meets the requirements for legal use in its original category by, for example, delimiting the speed or power.
We note that in France there is now a law which permits fines of up to 30,000 Euro or 1 year in prison for unauthorised delimiting of e-bikes. And that in the Netherlands, delimiting of the low-powered mopeds which are allowed on some cycle lanes is a significant problem.
So especially if e-scooters are to be legally allowed in cycle lanes, we suggest that robust anti-delimiting laws would be beneficial to deter speed or power derestriction or ‘tuning’ by users (or indeed suppliers). We would be in favour of these laws also applying to e-bikes, to help ensure that reputable companies trading within the rules can compete on a level playing field.
 Schleinitz, K., Petzoldt, T., Franke-Bartholdt, L., Krems, J.F., et al. (2015). The German naturalistic cycling study - Comparing cycling speed of riders of different e-bikes and conventional bicycles.