Also ECF and CONEBI have posted their feedback as an open letter in which they say “We are very much against the inclusion of Electrically Power Assisted Cycles (EPACs) within the revision of the Motor Insurance Directive because of the following reasons: EPACs are not motor vehicles: it is a matter of regulatory consistency. An EPAC is an Electrically Power Assisted Cycle that provides electrical assistance to the cyclist up to 25km/h only while pedalling. EPACs have maximum 250W and are excluded from the EU Type-Approval because from a regulatory point of view they are not considered motor vehicles.
“Power assistance is designed ONLY to complement rather than replace the main propulsion, which is by human muscle energy through manual pedaling: if an EPAC user does not pedal, he/she does not receive any assistance. Power is limited to 250W, which is a level perfectly achievable by riders without assistance.”
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