Annick Roetynck
Managing Director LEVA-EU
August 20, 2025
I recently had the privilege of spending some time in Japan. While there, I came across the Yamaha
PAS. This electric bicycle is nothing less than the very origin of the European legislation governing
not only EPACs, but all electric cycles. Back in 1999, the European institutions were drafting Directive
2002/24/EC on the type-approval of mopeds and motorcycles. They were determined to exclude
electric bicycles, arguing that these vehicles did not belong in legislation designed for mopeds and
motorcycles. At that time, electric bicycles were still in their infancy. The Yamaha PAS was then the
most popular model, offering pedal assistance up to 25 km/h and a maximum rated power of 250W.
And so the EU decided—without much reflection—to adopt those exact figures as the criteria for
exclusion from the L-category. There was no in-depth analysis, no foresight for future developments,
no serious consideration of the implications. It was an easy, almost casual decision.
In 1999, I was there, working for ETRA, the European trade association for bicycle dealers, to protest
against this approach. My objections fell on deaf ears: 25 km/h and 250W would be the rule. Years
later, when the EU prepared Regulation 168/2013, I was there again to protest. On behalf of ETRA, I
argued for a broader exclusion: that all electrically pedal-assisted cycles with assistance up to 25
km/h should be exempt from type-approval, without any arbitrary motor output limit—because
speed, not power, is the real determining safety factor. I also argued that all very light electric
vehicles under 25 kg with a maximum design speed of 25 km/h should likewise be excluded, again on
the basis that speed, not power, determines safety.
The IMCO Committee of the European Parliament was convinced. They adopted all of ETRA’s
proposed amendments to broaden the scope of exclusion for LEVs. But then, at the very last
moment, the European Cyclists’ Federation and CONEBI, the European trade association for the
bicycle industry, intervened with their objections. They succeeded in swaying the Parliament to
overturn the committee’s decision and reject all the amendments in the plenary vote.
Now, 26 years after my first attempt to secure better legislation for LEVs, we remain bound by the
same outdated limits of 25 km/h and 250W. The result is that the development, market
introduction, and deployment of LEVs are still severely hampered by legislation that is, quite simply,
very, very, very outdated. The question we must ask is this: do we really want the EU market for
LEVs, five years from now, to still look essentially like the Yamaha PAS of the 1990s?
Incidentally, Japan has moved forward in the field of light electric vehicles. Electric kei cars are
omnipresent. These are small, lightweight cars to provide affordable, efficient mobility. They are
limited by law in size, engine capacity, and power output, which makes them cheaper to buy, tax,
and insure. Kei cars are popular in Japanese cities because they are easy to park, non-polluting, and
often come with lower tolls and fees. Yet another thing which the EU hasn’t achieved: the creation
of a proper legislative framework for micro-cars.
Europe is truly becoming a laggard in the world of sustainable mobility.
Do We Really Want Europe’s Light Electric Vehicle Future to Look Like the Yamaha PAS?
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