StVZO/s-pedelec/e-scooter consultation: email

I've dealt with several companies (in the UK, EU, USA, and other continents) for their projects of bicycle lighting, e-scooters for the German market and pedelecs/s-pedelecs for the EU-market. Some of these companies are: Exposure/Ultimate sports engineering in the UK, Superpedestrian in the USA.
What I can I provide:

• A complete analysis + summaries of the rules + approval procedure for bicycle class lighting, and for various vehicle types such as e-scooters in Germany, s-pedelecs, pedelecs.
• for various EU countries I gathered the user rules/requirements for such vehicles (manufacturers need to know this)
• made a good overview/analysis of the additional requirements, including of most of the standards such as ECE regulations that are used, with references to the sections in rules, explanations, and information about test labs and much more, so for such vehicles I can help get them approved.
• I also analysed the rules for bicycle trailers which in the EU vary per country, which, just like the rules for bicycles and pedelecs (25 km/h) are not even uniform across the EU.

In more detail, this consists of:

1. A body of information that is continually updated:

   • Translation/analysis of German-only rules such as the bicycle class lighting in StVZO/TA. The analysis of bicycle class lighting in StVZO/TA is applicable to bicycles, pedelecs, e-scooters, self-balancing vehicles.
   • Summaries and analysis of ECE requirements for vehicles such as s-pedelecs.
   • Translation of German-only texts such as StVZO/TA, eKFV (e-scooter rules in Germany), with interpretation to clarify unclearly written passages, and analysis of these rules
   • How to get around some issues in StVZO
   • Which test labs to avoid because of incompetence. This is especially important for the approval procedure of any vehicle or part that is not strictly according to the rules, but has deviations that are allowable. It is further important for unclear sections in standards of which some test labs do not realise the correct interpretation. I describe why I don't trust these test labs, which comes from giving incorrect responses to queries about interpretation issues in the rules and from lack of knowledge on there even being interpretation issues, but that's not all, there are more issues that I encountered,
   • Explanation of various interpretation issues in the rules (because of unclearly written rules) that I found (StVZO, ECE, s-pedelecs, etc.) and that you need to know to design a conforming product. The issues I found while doing my translations/analysis on lighting/vehicle rules I sorted out in discussions with various official sources such as KBA, researchers working on the rules, etc. to determine what is really meant, but if anything new pops up I will discuss such things with researchers, KBA, test labs etc.
   • Discussion of additional standards used alongside and in certain sections in place of TA (those sections in TA are not used), how the rules will change in the coming version of TA, various related ECE standards,
   • Additional requirements and information that are not published in StVZO/TA nor in any other standards but which you need to know (and that will be a factor in the approval procedure)...
   • Examples of deviations to the rules that I know are allowed (with examples of StVZO lighting parts, ECE lighting parts, s-pedelecs, etc.).
   • CE mark requirements.
   • Information on the approval procedure, guide through the forms etc.
   • Information on whether approvals for non-standard lighting (such as lighting using non-standard power sources such as contactless rim dynamos and rim mounted lights, are likely to be succesful, with some requirements that the KBA will demand for any non standard lighting, and some examples as a guide for possible other projects that a company might wish to explore.
   This continuously updated work of analysis/translations (of StVZO/TA)/commentary and elucidations with comments included from the people who wrote and worked on the rules (in response to my questions and comments), is as of April 2021 ca. 350kB HTML on lighting, ca. 160kB HTML about e-scooters, and ca. 160kB HTML for s-pedelecs + many other files (in total more than 700kB HTML with files linking to each other where needed such as from the vehicle section to the lighting section, and to external sources), further including pictures, example manuals in German, examples on filling in the forms, etc.

2. Dealing with test labs, KBA and other regulatory bodies:

   • Help with the approval procedure where needed, including contacting people in KBA if needed (e.g. to see if it would be possible to get exceptions/non-standard solutions approved).

3. I can review prototype vehicles, give comments and suggestions on how to improve them:

   This means:

   • Suggestions about handlebars, tyres, user interface, etc. I've done this with one of the companies I worked for. If interested in this, email me to discuss what you want/need...

The whole process of getting an approval for vehicles and (lighting) parts is fairly involved and expensive (but that is a fraction of the actual development costs, in case of lighting compared to the development of a lens/reflector, and it's far less than that of the development of a vehicle such as an e-scooter). For lighting parts there are the following costs for services by KBA or test labs:

• the approval procedure: ca. €1000 up to €2000,
• company quality certification: ca. €1000,
• assigning the approval: ca. €500.
• Then you have the choice to get help or do it yourself, in the latter case you will need to get all standards and get all German text translated and then spend quite a bit of time to figure out what the requirements really entail (which is an issue for all rules, StVZO, ECE, and vehicle requirements) and keep track of how the rules change.

The cost of getting a vehicle approved by a testlab, which is needed for example for s-pedelecs, e-bikes (not pedelecs, but with a motorcycle style throttle control) and for e-scooters, is far higher than the cost to get vehicle parts approved. which include EM checks. Details are included in the sample of my analysis.