StVZO/s-pedelec/e-scooter consultation: email
Consulting for German-legal e-scooters, EU s-pedelecs and bicycle class lighting (which is also applicable to pedelecs, e-scooters/self balancing vehicles like segways):
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:
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.
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).
I can review prototype vehicles, give comments and suggestions on how to improve them:
- 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.
Additionally, for a company that wants a collaboration on producing better lamps, I have ideas for better beam shapes for headlights, better housing and mounts, better taillights/cable management, user interface etc.
If you are interested then:
- send me an email about your requirements,
- then I will provide a sample of the above work, with prices for certain types of services/support and more details about options, exceptions, etc. [ If after examing the information it turns out that you need something that doesn't fall under the examples, then the price for that can be discussed later but you will then have an idea of the costs of the procedure and requirements for production to get an approval, and my services. ]
- After you have gone over the information, and if your are interested in hiring me, then we can have a call via Telegram or Viber, or Skype (I'd prefer Telegram/Viber) to discuss details, and if needed, pricing.
Answers to FAQ: Why make StVZO lighting rather than non approved products, legal requirements and consequences and what I provide
- Why make StVZO lighting rather than non approved products?: Germany is a big market, and NL follows Germany. StVZO approved products are seen as a quality seal by sellers/buyers in other countries too (which is true in that a proper cutoff and light distribution is far more effective than a non cutoff beam, and in that quality control has to be present for production). In terms of performance, a cutoff light performs as a circular beam with 3-5 times the light (see my bicycle lighting analysis section and the lighting review section on my site) so such lights are much better.
- What is involved? The process to get bicycle/pedelec/e-scooter lights StVZO certified is not just making it according to specifications, but getting it approved and gettting the production of those parts certified. There are not just requirements on the beam, but on housing, materials, the manual, drawings to be provided with the samples for approval and much more.
- What are the consequences of selling non-approved lighting in Germany?: It is not allowed to sell non-StVZO bicycle lamps as being 'bicycle lamps' (to be mounted on a bicycle) to customers in Germany. I've heard of fines for bicycle shops of 5000 euro or more, and for distributors of 10000 euro or more. There is a strict check also for advertising in magazines or on the internet. Selling on amazon.de is also impossible for non-StVZO approved lights that are portrayed or said to be for use on/with bicycles (such offerings will be removed...). Customs in Germany can confiscate non-approved lights from sellers outside the EU (at least if the marketing materials suggest they are 'general bicycle lamps')... Customs related arms of the government can go to fairs and may confiscate non-approved lighting that is aimed in any marketing materials as being 'general bicycle lighting'. A similar example you can see on youtube with videos of "Achtung Kontrolle" where non-approved car lighting parts are confiscated...
- Could you sell a non-conforming light as a helmet light?: Helmet lights are not allowed in Germany, due to general rule StVO par. 17 which says that a search light (which is clearly any light with strong beam that can be aimed anywhere) may not be used to light up the road. Selling non-approved helmet lamps as e.g. MTB lights (for on specific MTB trails, not public roads) or camping lights is possible, but then you must make clear that these lights may not be used on public roads... You may not even call them 'bicycle lamps' (or show them used with/on a bicyle) in advertising or in the manual or on your website...
- What do you supply?: I supply a complete analysis of everything from written sources, standards, and from people in various places who deal with approvals in KBA. I give help with the approval procedure, paperwork, and as I speak German, I deal with people in the KBA (german ministry responsible for vehicles, and thus also for approval of vehicle parts such as bicycle lighting) in case there is a need in case of changing rules or for getting something approved that is not a standard lighting system, or if there are any interpretation issues etc.).
Email to me (Wouter Scholten): gambietfietsen @ xs4all.nl . (English / Nederlands / Deutsch / По-русски / Francais (mais, mon Francais n'est pas tres bon!)
N.B. remove the spaces in the email address! There is HTML in the email address to prevent spam, which works nicely, but note that if your email client copies that HTML code in the 'To' address, you will need to remove it or type in the email address manually...
A talk via Telegram/Viber/Skype is possible after you read my sample information. Messages preferably via Telegram/Viber/email. I prefer not to use Skype for anything other than calls (as it gives no notifications for messages for some reason) nor Whatsapp (it can only be used on a phone or tablet with phone capabilities, but I don't use my phone much, I use my wifi tablet much more, further, phones are too small to do serious work on so need to transfer information/files to a tablet or PC so whatsapp is just a hassle).
What I don't use or will stop using:
- I don't use facebook (= most unusable website in the history of the world)
- I don't use linkedin (= an acquaintance-collection site, I found it useless and deleted my account).
- I will not use Whatsapp for any future work from Feb. 2021... I used Whatsapp only for a few previous contracts, not really personally also because it doesn't work on WiFi-tablets,
Last modified: 2022-4-29