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EU: Electric Mini Scooters need Type or Single Approval

Type or single approval is required to legally sell and use small electric scooters on public roads in EU member states. The approval can be obtained at the German TUV and other institutions. Once approved, the end-user can ride the scooter with an insurance plate up to a helmet-free speed of 20-25 km/h depending on national regulations.
 

 
Electric mini scooters – the small sit-down and stand-up types – are about to enter the European market after they have achieved numbers of more than 80,000 sold in the United States in 2000. Unlike the US, selling these scooters for use on public roads in the European Union requires type or single approval.

Once obtained in one of the member states type or single approvals are valid in all fifteen EU countries.

Type or single approval allows the manufacturer to get the required authenticity papers in order to properly register the scooters, which the end-customer will need, to get the mandatory insurance plate.

In Germany, only electric scooters with a seat are allowed. Motorized stand-up scooters are illegal in any way.

Type or Single Approvals can be obtained at the German TUV
The German TUV, its competitor DEKRA or TNO in Holland and other institutions offer this service.
Most of the approximately 20 manufacturers who had their electric scooters type approved, went through the TUV Rheinland/Berlin-Brandenburg, Germany. Since the beginning of 2000 they have experienced about 250 tests in the field of two wheelers for single directive approvals (component approvals) and about 40 whole vehicle type approvals.
With an accredited test laboratory for all test items, the TUV Rheinland/Berlin-Brandenburg offers a whole vehicle type approval. This saves both time and money.
The TUV Rheinland/Berlin-Brandenburg closely cooperates with the “Kraftfahrt-Bundesamt“ in Germany (authority for transportation), the “Ministry of Traffic“ with its enforcement agency SNCH in Luxembourg, and the “Rikjsdienst voor het Wegverkeer“ in the Netherlands.

Products need to meet Safety Requirements
For type approval, products have to meet a number of requirements. These mostly refer to safety features. Unfortunately, there is no easy-to-use list of these requirements available. Details can be found on the internet under http://europa.eu.int/eur-lex/de/lif/reg/de_register_133010.html.

The first step is a pre-presentation of the product to the TUV to determine if changes have to be made. According to the TUV’s experience, most problems occur with brakes, lights, stand, rear mirror and EMC (electro magnetic compatibility, meaning the ability of a vehicle or one of its electrical/electronic systems to function satisfactorily in its environment without causing electromagnetic disturbances to anything in that environment and protection against interference from other electronic devices––such as, a sudden loss of power when a cell phone rings).

Type Approval requires one Month or more
From the moment the product conforms to all requirements, type approval takes roughly one month and costs 10,000 Euros (this includes pre-testing). This is the ideal case. However, says the TUV, the whole procedure usually takes 3-4 months longer because of necessary changes on the product and bureaucratic matters.

Type Approval: Manufacturer needs to be EN/ISO 9002 certified
The manufacturing company has to be EN/ISO 9002 certified as a vehicle manufacturer. ISO certifications for foreign manufacturers are only accepted by the Kraftfahrt-Bundesamt (KBA) if the auditing authority who granted the certification is approved by the KBA.

Manufacturers with no valid EN/ISO 9002 certification can get an Initial Assessment by the Kraftfahrt-Bundesamt to get this type approval. In this case the KBA or - in single cases - a delegated body (for example a TUV representative) would visit the production facility and check production method and quality control. This, of course, requires additional costs of 1,500-2,500 Euros.

Important: Helmet-free Top-Speed
One important thing to consider is the national legislation for helmet-free maximum speed. In the EU countries, the speed requiring a helmet varies between 20 km/h (Germany) and 25 km/h. The scooters themselves are allowed a maximum speed of 25 km/h, but in most countries a motorcycle helmet is necessary at a lower speed. This is very unattractive to the end-user. Therefore, products should be available in different versions corresponding to the national helmet-free maximum speed. Such versions are accepted within one type approval, e.g.
Version A – 20 km/h max. speed,
Version B – 25 km/h max. speed.

Single Approval: Recommended for Small Production only
As the name suggests every single product has to be presented to the TUV or to a corresponding institution and registered in a seperate procedure. If the scooter meets all requirements it can be approved in only a few days. Single approval cost app. 30 Euros per product. No EN/ISO 9002 certificate of the manufacturer is required in this case. For mass production single approval is not recommended since it causes high cost and a lot of bureaucratic work.

For more information you can contact
Thomas Rohr at the German TUV Rheinland/Berlin-Brandenburg.

List of EU-Member States

 
 

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21st June 2019, Westendorf, Kitzbühel Alps, Austria
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22nd and 23rd June 2019, Westendorf, Austria, E-bike Festival Kitzbüheler Alpen

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