Table 32: Proposed L-category vehicle emission limits by European motorcycle industry association ACEM

ANNEX VIII: Background to the type-approval system

Before the EU developed the type-approval system most Member States (MS) used to have their own, differing national requirements for new vehicles to be allowed on the market. The directives for L-Category vehicles (2002/24/EC) were set up to counter the problems for industry created by these differences and separate approval procedures by harmonising the minimum requirements to be fulfilled. Execution of testing and approval activities was left to the MS. In the directives it is stated that other MS have to accept approvals given in one MS (mutual recognition, based on EU requirements; an approach of mutual recognition based on –differing- national requirements has been discussed in the past but has never been accepted by Member States).

Costs: the system has inherent costs: the directives have to be developed (meetings of experts, drafting by Commission services and experts from MS; procedural costs related to getting the draft approved by the co-legislators; cost of implementing directives in national legislation and its verification by the Commission; costs for manufacturers to get their product tested (including provision of products for testing) and approved; follow-up costs if product needs to be adapted and again approved. Available figures are in this report and the supporting external report.

Every Member State appoints a ‘Type-approval authority’. This TAA must be notified to the Commission and other MS to perform the necessary tests or other institutes (test houses) can be notified for this purpose.

A manufacturer, who proposes a new vehicle or component (e.g. headlamp) contacts the TAA and the test house, submits the prescribed completed information document, makes the vehicle or component available for testing and pays the fees.

It may prove that the test is not passed; in such case the product can be adapted and resubmitted for testing.

If all is well the manufacturer obtains the test report(s) and approval form(s). These forms are defined in the Separate Directives (SDs). Then the manufacturer is able to sell his product everywhere in the EU, provided she / he puts the prescribed marking on the product and, for vehicles, provides a Certificate of Conformity (CoC) with every vehicle delivered.

In case of a vehicle, the manufacturer can obtain TA in one step (all testing etc in one go), or step-by-step (separate approvals for every component / system; in the end, for the vehicle as a whole, she / he submits the approvals given before. In the latter case, which is must usual, many part-approvals may have been obtained by other (component) manufacturers. Another option foreseen is that one manufacturer builds a basic but incomplete vehicle and the next finishes it by e.g. building the bodywork on it, or modifying it for a specific purpose: multi-stage approval.

A manufacturer can submit a product for TA only in one MS, to one TAA (no ‘shopping’).

The TAA must inform the other authorities about TA’s given, denied or withdrawn. The latter because the TAA is responsible towards the others in case it is found that products are marketed which are not in line with the TA given.

As long as the EU system allows options, this means that the manufacturer may choose to apply for an EU TA for the vehicle or component. EU requirements are often somewhat stricter than national requirements and thus the product may have to be somewhat more expensive; on the other hand if his markets are in more MS she / he can choose his best option.

The approval procedure for a vehicle may be time-consuming, often starting in the first year of development, lasting 3 to 4 years. It’s important for the manufacturer not to have to repeat this number of times in different countries.

ANNEX IX: The Market for L-category vehicle in the EU

1. The structure of the EU market

The powered two-wheeler (PTW) segment of the L-category market is the most important in terms of manufacturing, turnover and employment. However, in order to keep the analysis in line with the structure of other sections of the impact assessment, the analysis is carried out in the following order:

(1) Electrical cycles

(2) Powered Two Wheelers: Mopeds and motorcycles. This also includes motorcycles with side car.

(3) Off-road Quads; also called All Terrain Vehicles (ATVs)

(4) Mini-cars

2. Electrical Cycles

Currently electrical cycles fall out of the scope of L-category vehicles (less than 0.25 kW, maximum vehicle speed of 25 km/h). More powerful electric cycles are categorised as mopeds and fall in the scope of type approval legislation.

The market is still very young and very fragmented. Most of the electric bike manufacturers who entered the market first, originally produced conventional bikes and gradually added the production of electric bikes to their activities. The number of vehicles produced is either not available or still very low. Only 6 companies produce relevant numbers, in 2009 ranging from an estimated 6 000 to 50 000 cycles. They have accordingly relevant revenues ranging from €350 000 to €2.7 million in 2009.

The electric cycle industry is a very international business, with companies located in Europe, America and the Far East. The overall majority of the companies are very small, often even micro companies. Quite a number of them have no prior history in the cycle business. All large companies are companies that are adding electric cycle activities to their original activities in the field of conventional cycles. The overall majority of the companies are active in various electric vehicle categories. The production of the overall majority of the companies is still in a very early stage. As a result production volume and revenues are low, whereas R&D costs are relatively high.

2.1. Sales of Electric Cycles

The European Commission has received the following data from professional organisations (ETRA) and the data has not been verified independently.

France:

Sales in 2008 were at 15 800 units, which is a 50 % improvement of the 2007 result.

In 2008, an estimated 100 000 electric cycles were sold, which is 2.5 % of total sales volume. Growth is considerable: +62.5 % in 2007, +54 % in 2008 and a forecasted +20 % in 2009.

Sales in 2008 are estimated at 10 000, whereas for 2009 they are expected to increase to 30 000. Sales may well be further encouraged as a result of the renewed cycling incentive scheme. The Italian government has allocated another €7.6 million euro to spur consumers to purchase (electric) cycles. In a first phase, the Italian government has already granted €11.4 million euro as incentives for buying (electric) bikes. The incentive was extremely successful.

In 2008, almost 140 000 electric bikes were sold at an average retail price of €1 900. Thus electric cycles have generated 1/3 of the total revenue from sales of new bikes in The Netherlands.

Sales in 2008 are estimated at 15 000, whereas for 2009 a 50 % increase is forecasted. Sales are reported to be mainly to commuters who are replacing car or public transport journeys by electric bike journeys. Sales have been bolstered by tax breaks on cycle purchases.

There are no statistics available but the most important suppliers all confirm the success of the electric cycle. Since 2007, Sparta, which is one of the most popular brands in Belgium reports growth of 10 to 15 % a year, with a +15 % prognosis for this year. With that, sales of electric bikes are reported to increase more than other types of bikes.

3. Powered two-wheelers (PTW)

This is the largest and most important sector of the industry and includes motorcycles, including those with a side car, mopeds and scooters. PTW market statistics

3.1. EuroStat data

The manufacturing of motorcycles is classified under the NACE activity classifications of 35.4 and 35.5. However, this particular classification does not disaggregate the manufacture of motor-cycles from the manufacture of cycles. In addition, the classification is so broad that a manufacturer which contributes in any way to the manufacture of a vehicle is included. Using this classification, EuroStat estimates that there are 2.300 companies manufacturing motorcycles and cycles. This would seem to be an over-estimate of the reality of the market-place. A study by the University of Bologna estimates that that stripping out the cycle manufacturing companies would yield an estimated 870 companies which manufacture motorcycles. However, in order to get a more accurate estimate of the number of manufacturing companies, data has been gathered from the ‘type approval’ authorities and analysed to produce a more accurate picture of the number of manufactures in the EU. The results are discussed below in chapter 3.2.

EuroStat also provides data for Prodcom classifications, which indicates the number of units produced and the production value for certain classifications of manufacturing activities. Motor-cycles and scooters are classified under subsectors 35.4 and 35.5, classified by cylinder displacement. The most recent full year data is for 2007.

The data indicates that for 2007, the EU produced 1.136 million L-category vehicles. Overall, the statistics indicate that the value of production of motorcycles and scooters in the EU was € 4.1 billion in 2007. The most important segment in terms of value is the large motor-cycle segment, where the engine size is greater than 800cc; the production value is € 1 billion for this segment. In terms of number of vehicles, more scooters are produced than motorcycles, but their overall value is less and was valued at € 840 million in 2007.

The production of ‘parts and accessories’ is also an important segment, with a production value of € 1.6 billion.