This past month has seen a flurry of articles in both trade and consumer publications about lithium-ion battery fires and standards for “bicycles” as defined by the U.S. Consumer Product Safety Commission (CPSC).
Feedback about last month’s article discussing the definition of a bicycle was well received, with some concern expressed about the status of electric bicycles with performance specifications that are not within the language of the CPSC’s 16 CFR Part 1512.2.
We recommend that any questions about the definition of a bicycle be directed to the CPSC Office of Compliance and Field Operations: https://www.cpsc.gov/About-CPSC/Division-of-Field-Operations or you can call 1-301-504-7520.
The May 2022 print issue of Bicycle Retailer and Industry News (BRAIN) contains a cover story with the headline: “E-bike regulation discussion captures industry’s attention” that jumps to page 21 and a whole page with this quote: “That was a rather sobering discussion for probably 50% of the people in that room,” attributed to an industry attorney who sat in on the session, which was the closing presentation of the March 21-23 PeopleForBikes Bicycle Leadership Conference.
The author of the article, Steve Frothingham writes that it was “…not the flashiest or the best attended” but “…was the most sobering 60 minutes of the two-day conference.”
On April 26, several days before I received the May issue of BRAIN, an article titled: “Approximately none of the recent ‘e-bike fires’ in New York involved an e-bike” was posted on the BRAIN website.
I personally believe this headline is an example of poor journalism, and while I hold both the editor and managing editors of BRAIN in high regard, I don’t think this is an example of either their normal or best work.
With that said, this article does give clear and immediate direction to American bike shops. Larry Pizzi is the co-chair of the PeopleForBikes Electric Bicycle Subcommittee and chief commercial officer of Alta Cycling Group. He is quoted throughout the article including this: “Pizzi suggests that retailers and consumers only buy e-bikes that have been certified by third-party testing labs, to the UL standard or other relevant standards, followed by “All they (retailers) have to do is ask the brand to provide proof of the testing.”
There are two standards applicable to e-bikes as defined in Section 1512.2, covered in detail in last month’s article that you will find posted on the HPS website: https://humanpoweredsolutions.com/2022/04/11/what-is-the-definition-of-a-bicyclewhy-does-it-matter/
The first is the mandatory CPSC Requirements for Bicycles. The required third-party testing must be done by a CPSC-approved laboratory. The details of this mandatory testing are well established, and the brands, importers and domestic manufacturers and assemblers are aware they:
1. Must produce a General Certificate of Conformity (GCC), or if the bicycle is designed and intended for use by a child 12 years of age or younger, a Children’s Certificate of Conformity (CPC), and
2. The GCC or CPC must accompany the product or product shipment and be furnished to each distributor or retailer.
These requirements can be satisfied by either providing an actual hard copy or provided electronically.
While the frequency of mandatory testing is subject to interpretation by CPSC, it is generally accepted by the brands we have talked to as being annual, or with each model year, and is for each model type, again subject to interpretation by CPSC.
The point is that brands doing business with American bike shops have established third party testing and certification in place as standard operating procedure for all bicycles including the non-electric systems of e-bikes, as defined by Section 1512.2.
The second is the voluntary Underwriter Laboratory UL 2849 which PeopleForBikes helped develop through the participation of Trek, Bosch and SRAM, and promoted through a YouTube video in May 2020. This voluntary standard covers both Canada and the United States, and was promulgated to the global industry in January 2020.
UL 2849 – Standard for electrical systems for e-bikes, covers safety requirements of e-bikes powered by lithium or other rechargeable battery. It provides requirements with respect to the following:
- The electrical drive train system
- The battery system
- The charger system combination
- Interconnecting wiring
- E-bike power inlet
Third party testing and certification is conducted according to UL protocols by UL or accredited UL testing laboratories, most of which are also approved by the CPSC. Many brands we have talked to are having their e-bike products third party tested and certified by the same CPSC-UL approved lab located in China or Taiwan.
We are confident that the brands listed as having joined the PeopleForBikes lithium-ion battery recycling program are aware of the above, and have been since 2020.
HPS has a link to the YouTube video of the PeopleForBikes May 2020 webinar introducing and explaining UL 2849, and you can access it here: https://www.youtube.com/watch?v=yVicfT4X1Dk
Accordingly, bike shops should take immediate action to follow the direction given in the April 26 BRAIN article: “…that retailers and consumers only buy e-bikes that have been certified by third-party testing labs, to the UL standard or other relevant standards,” and that bike shops also take immediate action to ask the brands they do business with to provide proof of the third party testing of all “bicycles.”
If you have questions or comments, please contact me: firstname.lastname@example.org.