E-bike conversion kits should list safe batteries and chargers, OPSS guidance says
The product safety regulator has set out how machinery law applies to kits that turn a pedal bike into an e-bike, whether or not they are sold with a battery. Kits that go beyond 250 watts or 15.5mph make the bike illegal on the road without registration and insurance.
An e-bike conversion kit sold in the UK should come with information on which batteries and chargers are safe to use with it, including their voltage and power ratings, even when the kit is sold without either. That is one of the expectations set out in guidance published on Wednesday 11 November by the Office for Product Safety and Standards (OPSS), the national product regulator.
The guidance does not create new law. It explains how the Supply of Machinery (Safety) Regulations 2008 already apply to conversion kits, which OPSS treats as machinery: an assembly of linked parts, one of which moves, designed to work only once fitted to a means of transport, in this case a pedal bike.
Fire risk from mismatched parts
OPSS says converted e-bikes may pose a greater fire risk. It points to evidence from fire and rescue services and to research it commissioned, which found that mismatched parts, such as a battery and charger with different voltage ratings, are more likely to fail when used together and can explode or catch fire. Voltacle has explained how e-bike batteries catch fire and what safer charging looks like.
Every kit that includes an electric motor is covered, whether it comes with a battery, a charger, both or neither. Motors and drive systems built into a manufactured e-bike are not covered.
What a kit should come with
The business responsible for placing the kit on the UK market, meaning the manufacturer or its authorised UK representative, must make sure it meets the essential health and safety requirements, keep a technical file, follow the conformity assessment procedure, draw up a Declaration of Conformity and fix the UK marking to the kit or its paperwork.
OPSS expects the instructions to cover:
- which types of pedal bike, and in what condition, the kit can and cannot be fitted to
- clear and complete installation steps
- the batteries and chargers that are safe with the kit, with voltage and power ratings or safe ranges
- how to charge safely
Instructions should also recommend that users get professional help with fitting. If a kit is later fitted by a business or a competent person who follows the maker's instructions and makes no other changes, the maker remains responsible for its safety.
Speed and power limits
Kits that allow more than 250 watts of continuous rated power or powered assistance above 15.5mph are covered by the guidance too. Once fitted, they turn the bike into a motor vehicle. OPSS says that makes it illegal to ride on roads and public land unless it is registered and insured, and the rider holds a driving licence and wears an appropriate helmet. A converted bike that stays within the limits counts as an electrically assisted pedal cycle, which riders must be at least 14 to use.
OPSS, local authority Trading Standards, Environmental Health in Northern Ireland and the Health and Safety Executive can enforce the rules. Their powers include suspending the supply of products that do not comply and, where proportionate, prosecution.
