APPGCW.ORG link https://www.youtube.com/live/Xqy47uMfMj8?si=vlsYxjyB2vWwCSe_ - Not very good explanation of substitution in employment contracts. I had to contend with all of this when I was a contractor. Anyway point is exploitation of workers is a broader issue and focus of ebike regulation should control scope creep. - They acknowledge forging kitemark needs to be considered. Especially if modifications happen after. - In presentation the idea of delivery companies monitoring the speed of bikes was good. If these companies genuinely felt the pressure they could easily implement safeguards to control speed. However can you find a politician to take them on? - The NY pilot the delivery companies did was probably at the behest of US politicians? Can UK politicians, if motivated, offer up the same heat? - More comparison with other countries and how they handle it - Interesting question raised about Neo Slavery - Explore tie in with consultation being done on new categories for e mobility - Risk of outright bans on premises and estates including because of insurance providers - separating the battery from the bike makes a standard ebike safe to travel with? And is allowed on TfL? - Environmentally correct way of recycling illegal bikes was discussed briefly. No specific recommendation - Wheels for wellbeing - Topic of funding and the cuts on Trading Standards was raised. Response on the table clearly became murky on who is responsible etc Didn’t feel very encouraging - Other Videos from APPG https://m.youtube.com/@appgcw?ra=m
Summary and Critique of the Report: “Unregulated and Unsafe: The Threat of Illegal E-Bikes”
Summary
The report by the All-Party Parliamentary Group for Cycling and Walking (APPGCW) highlights the growing safety risks posed by illegal and unregulated e-bikes in the UK. While the majority of e-bike users and businesses comply with regulations, a growing minority of unsafe and illegal practices is undermining the sector’s credibility and public trust. The report identifies several key issues:
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Safety Risks:
- Most serious safety incidents (e.g., battery fires) are linked to illegal products, such as throttle-controlled motorbikes sold as e-bikes and high-powered conversion kits that breach legal speed and power limits
- These products often use uncertified batteries and chargers, creating significant fire risks in both residential and public spaces.
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Gig Economy and Unregulated Online Marketplaces:
- Delivery riders in the gig economy often modify their e-bikes to increase speed, making them illegal and unsafe.
- Poor working conditions and low pay push riders to use cheap, uncertified products.
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Enforcement Challenges:
- Police and trading standards face difficulties due to outdated or unclear regulations
- Limited tools are available to remove dangerous e-bikes from circulation, and enforcement resources are insufficient.
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Impact on Active Travel:
- Unregulated e-bikes undermine public trust in e-bikes as a safe and efficient transport option, threatening the UK’s active travel and decarbonization goals.
Key Recommendations
The report calls for urgent and coordinated action across government, industry, and platforms to address the issue. Key recommendations include:
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Stronger Product Regulation:
- Implement stricter product certification and kitemarking systems to ensure compliance with safety standards (e.g., EN15194).
- Require online marketplaces to verify sellers and product safety under the Product Regulation and Metrology Bill.
Question
What about online marketplaces that exist outside the UK? These will be a channel to procure from. As such its importers of these products (as indicated below) that needs key controls
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Enhanced Enforcement:
- Increase resources for Trading Standards and DVSA market surveillance to crack down on unsafe sellers and importers.
- Enforce compliance from delivery platforms by requiring real-time GPS/accelerometer checks and geotagged bike photos for riders.
Research
What are these techniques?
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National Scrappage Scheme:
- Launch a scrappage or swap scheme to remove dangerous bikes and batteries from streets, funded by delivery companies profiting from their use.
Question
Who and how is “dangerous” determined? Delivery companies hire their riders on a self employed basis potentially via sub contractors and so keep long arms length legally see Delivery Drivers - UK and Germany. Trying to get delivery companies to part with their profit margins maybe equivalent to getting pigs to fly?
Delivery drivers are not the only people who break the law?
Would one solution be defining and enabling ebike owners to voluntarily “MOT” test eBikes and their integrated batteries. These vehicles and parts do degrade over time based on handling and use, including charging method. Delivery drivers could be made to have mandatory MOT checks
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Immediate Withdrawal of Unsafe Products:
- Online retailers must immediately withdraw uncertified conversion kits, batteries, and chargers that exceed legal power/speed limits.
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Support for Gig Economy Workers:
- Improve working conditions and wages to reduce the demand for cheap, unsafe products.
- Implement geofencing and designated parking bays to encourage safe parking and reduce antisocial behavior.
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Protection for Disabled Cyclists:
- Ensure regulations do not disproportionately impact disabled users, who rely on e-bikes for mobility.
Potential Consequences of the Recommendations
Positive Consequences
✅ Improved Safety:
- Reduced battery fires and accidents from illegal e-bikes.
- Fewer injuries and fatalities linked to unsafe products.
✅ Increased Public Trust:
- Greater confidence in e-bikes as a safe transport option, boosting adoption.
- Reduced stigma around e-bikes due to association with unsafe products.
✅ Economic Benefits:
- A healthier e-bike market could boost sales, jobs, and innovation in the cycling industry (worth £7.5bn annually in the UK).
- Reduced healthcare costs from accidents and fires.
✅ Environmental Impact:
- Increased e-bike use could help the UK meet decarbonization goals by reducing car dependency.
✅ Better Working Conditions:
- Improved pay and safety for gig economy delivery riders, reducing pressure to use unsafe products.
Negative Consequences
⚠️ Increased Costs:
- Manufacturers and retailers may face higher compliance costs, potentially raising prices for consumers.
- Delivery companies could pass on the cost of scrappage schemes or compliance checks to riders (e.g., lower wages).
⚠️ Market Disruption:
- Immediate withdrawal of unsafe products could disrupt supply chains and lead to job losses in the short term.
- Smaller businesses may struggle with compliance, leading to market consolidation.
⚠️ Regulatory Burden:
- Stricter regulations could stifle innovation, making it harder for new e-bike startups to enter the market.
- Enforcement agencies may face logistical challenges in identifying and removing illegal products.
⚠️ Unintended Discrimination:
- Some measures (e.g., bans on high-powered e-bikes in public transport) could disproportionately affect disabled cyclists, who rely on e-assist for mobility.
⚠️ Black Market Risks:
- Stricter regulations could drive some consumers and sellers toward unregulated black markets, where illegal products persist.
Who Uses This Report and for What?
| Audience | Purpose of Use |
|---|---|
| Government & Policymakers | Inform new legislation (e.g., Product Regulation and Metrology Bill), allocate enforcement resources, and develop scrappage schemes. |
| Industry (Manufacturers, Retailers, Delivery Companies) | Guide product safety standards, ensure compliance, and adopt voluntary pledges (e.g., E-bike Positive Retailer Pledge). |
| Enforcement Agencies (Police, Trading Standards, Fire Services) | Prioritize resource allocation, improve inspection protocols, and collaborate with online platforms to remove unsafe products. |
| Gig Economy Platforms (Deliveroo, Uber Eats, etc.) | Implement real-time compliance checks, improve rider training, and enforce safety standards in service agreements. |
| General Public | Raise awareness of unsafe products, encourage purchase of certified e-bikes, and advocate for better regulations. |
| Advocacy Groups (Wheels for Wellbeing, Cycling UK, etc.) | Push for policy changes, support disabled cyclists’ rights, and campaign for fairer gig economy conditions. |
| Investors & Entrepreneurs | Identify market opportunities in safe e-bike technologies and compliance solutions. |
| Academics & Researchers | Study e-bike safety trends, regulatory impacts, and gig economy labor conditions. |
Critique of the Report
Strengths
✔ Evidence-Based: The report draws on 60 written submissions, 13 in-person witnesses, and desk research, providing a comprehensive and credible analysis. ✔ Clear, Actionable Recommendations: Proposes specific, implementable solutions (e.g., scrappage schemes, real-time compliance checks). ✔ Balanced Perspective: Acknowledges that most e-bike users and businesses are compliant while addressing the growing problem of illegal products. ✔ Multi-Stakeholder Approach: Recognizes that government, industry, platforms, and riders all play a role in solving the issue.
Weaknesses & Criticisms
❌ Lack of Implementation Details:
- Does not fully address how enforcement agencies will overcome legal ambiguities or how small businesses will afford compliance costs.
- No clear timeline or budget for proposed measures (e.g., scrappage schemes).
❌ Overemphasis on Illegal Products:
- While illegal e-bikes are a major issue, the report could better highlight the benefits of legal e-bikes to avoid stigmatizing the entire industry.
❌ Gig Economy Focus is Limited:
- The report mentions poor working conditions but does not propose detailed labor reforms beyond compliance checks.
❌ Potential for Over-Regulation:
- Stricter rules could stifle innovation (e.g., new e-bike designs) and increase costs for legitimate businesses.
❌ Global Comparisons Could Be Stronger:
- While comparing the UK to Germany and the Netherlands is useful, the report could explore how other countries enforce e-bike safety in more depth.
❌ Impact on Disabled Cyclists:
- Some proposed solutions (e.g., bans on high-powered e-bikes in public transport) could disproportionately harm disabled users, but the report does not fully address alternatives.
Final Assessment
The report is a strong, evidence-based call to action that effectively highlights the safety risks of illegal e-bikes and proposes practical solutions. However, its success depends on:
- Government commitment to funding and enforcing new regulations.
- Industry cooperation in withdrawing unsafe products and improving compliance.
- Balancing safety with accessibility, particularly for disabled cyclists and gig economy workers.
If implemented effectively, the recommendations could significantly improve e-bike safety, boost public trust, and support the UK’s active travel goals. However, policymakers must be cautious about unintended consequences, such as market disruption, increased costs, and regulatory burdens.
Who Should Care?
- Policymakers (for regulatory reform)
- E-bike businesses (to ensure compliance and protect reputation)
- Delivery platforms (to improve rider safety and legal compliance)
- Gig economy workers (for better working conditions)
- Disabled cyclists (to ensure regulations do not discriminate)
- Consumers (to make informed, safe purchasing decisions)
Next Steps? The report’s impact will depend on follow-through—will the government act on these recommendations, and will industry and platforms take voluntary steps to address the issue? The Product Regulation and Metrology Bill could be a key vehicle for change, but its success hinges on adequate funding, enforcement, and stakeholder collaboration.