Protecting consumers, fair competition and Europe’s cycling industry
4 measures to address illegal and tampered products
Electrically power assisted cycles (EPACs) have revolutionised personal mobility, providing an affordable, efficient and sustainable alternative to short car journeys, contributing to healthier and more liveable cities, and allowing broader access to mobility, while supporting a strong European industry.
However, the rapid growth of the market is being accompanied by a growing challenge: non-compliant EPACs and products designed to circumvent EU requirements are increasingly reaching consumers in the European market.
This challenge is particularly visible in the rapidly expanding online market, where consumers can purchase products directly from sellers (often established outside the EU), through large online marketplaces. To circumvent high scrutiny by customs authorities, sellers usually declare lower value for their products. In 2025, the European Parliament has highlighted the scale of this broader problem in the INI report on Product safety and regulatory compliance in e-commerce and non-EU imports, stating that 4.6 billion low-value e-commerce items entered the EU in 2024, with 91% originating from China, almost twice the volume recorded in 2023. The EU Parliament has warned that the sheer volume of small consignments makes effective customs and market surveillance increasingly difficult.
For the cycling sector, this means that compliant European manufacturers, importers, distributors and retailers increasingly compete against products that may not meet the same requirements for safety, performance and regulatory compliance and are usually offered at a lower price.
The proliferation of non-compliant EPACs and tampering kits has consequences far beyond the individual product.
We call on the European Commission, the European Parliament and Member States to:
Tampering kits allow EPACs to exceed the limits that apply to bicycles and undermine the enforcement of the EU's regulatory framework.
The French legislation (road code L317-1) should be an example for Member States. Since 1999, tampering of any motorized vehicle is forbidden. Crucially, the current legal text not only covers type-approved vehicles but also includes “motorised personal mobility device or an electric-assisted bicycle”. This de facto banned the sale of any tampering kits for EPACs, reducing drastically this issue in the country.
In addition, the EU legislation provides a framework to support national regulations via the existing General Product Safety Regulation. Indeed, the GPSR already provides that a person substantially modifying a product can become subject to manufacturer obligations where the modification affects product safety.
We call for:
- effective removal of such products from online marketplaces;
- coordinated enforcement against sellers repeatedly offering such products; and
- clear consumer information on the consequences of modifying an EPAC
The European Commission and Member States should establish a coordinated system for collecting data on non-compliant e-bikes and tampering kits.
We call for:
- Identifying the number and characteristics of non-compliant EPACs,the types and sources of non-compliance, and online and offline sales channels;
- Measuring road-safety incidents involving non-compliant or modified EPACs;
- Evaluating the economic impact on the European cycling ecosystem (e.g., manufacturers, retailers, repair shops, etc.);
- Keeping track of the number of products removed from online marketplaces; and
- Measuring the effectiveness of enforcement actions.
This data should be shared between relevant national authorities and at EU level.
Such an evidence base would allow policymakers to quantify the road-safety and economic consequences of non-compliance and assess whether existing measures are delivering results. It would also support the evidence-based approach promoted by the European Parliament, which has called for improved data sharing, stronger cooperation and better enforcement of the existing EU product-safety framework.
The Market Surveillance Regulation already provides a common framework, including controls on products sold online and cooperation between national authorities. The European Commission itself stresses that market surveillance is essential both to protect consumers and to protect businesses from unfair competition.
However, enforcement remains uneven, products prioritisation fall short, and resources are limited.
The upcoming European Product Act should therefore strengthen the implementation of the Market Surveillance Regulation and address the gaps that allow non-compliant products to reach European consumers.
We call for:
- Establishing a dedicated European market surveillance authority to strengthen cooperation and information exchange between national market surveillance authorities, and run coordinated cross-border audits and digital sweeps to prevent fragmentation of enforcement against illegal products and service offerings;
- Recognising online marketplaces legally as economic operators, thereby bearing direct joint liability for listing, selling, or facilitating the distribution of tampering kits, digital services for overriding legal speed or power limits, and EPACs that bypass EN15194 or similar compliance standards;
- Ensuring that online marketplaces rapidly remove identified non-compliant products and prevent their reappearance;
- identifying EU-based authorised representatives for any imported EPAC as legally liable “authorised recipient” subject to judicial and civil proceedings in cases of e.g. battery fires, structural frame failures, or when vehicles are found to have built-in, easily exploitable vulnerabilities that facilitate tampering;
- Introducing a safeguard system in case of direct-to-consumer drop-shipping, where the fulfilment centres and postal carriers are considered as default importer to strengthen traceability and liability requirements for non-EU sellers and responsible economic operators;
- Ensuring that repeat offenders are subject to effective, proportionate and dissuasive sanctions; and
- Providing market surveillance authorities with the technical and financial resources required to enforce the rules.
EPACs are increasingly diverse in their design, propulsion systems, software and technical characteristics. Distinguishing a compliant from a non-compliant EPAC is not always straightforward, particularly for local authorities and enforcement officers who may encounter these products in very different contexts.
The EU and Member States should therefore prioritise resources for enforcement at national, regional and local level.
We call for:
- Dedicated training for market surveillance, police and other relevant enforcement authorities;
- Practical guidance for distinguishing compliant EPACs from non-compliant or modified vehicles;
- Training on the identification of common methods of circumvention;
- Access to appropriate technical expertise and testing facilities where required;
- Coordinated training material developed at EU level; and
- Clear referral mechanisms between local authorities, market surveillance authorities, and the cycling industry.
This approach is consistent with the objective of the European Product Act to reduce differences in market surveillance practices between Member States by pooling resources and expertise and strengthening EU testing capacity.
Why are we calling for these things
Products that provide motor assistance beyond the applicable limits, or that can readily be modified to do so, create safety risks for riders and other road users. They may also blur the distinction between bicycles and motor vehicles in the eyes of consumers and enforcement authorities.
The issue is particularly important because consumers may purchase a product believing that it is compliant while its actual characteristics place it outside the regulatory framework applicable to EPACs.
European manufacturers and responsible importers invest significantly in product development, testing, conformity assessment, quality control, traceability and after-sales support.
When non-compliant products can be offered at significantly lower prices because they avoid these obligations, there is no longer a level-playing field between actors.
The European Parliament has explicitly identified this wider problem, noting that EU manufacturers face significantly stricter market surveillance than non-EU manufacturers selling directly to European consumers through e-commerce, and warning of the resulting loss of market share and jobs.
The European cycling industry provides 1.3 million jobs and contributes EUR 21 billion to the GDP of the European Union, and the EU cycling supply chain covers over 1 000 small and medium-sized enterprises, according to the report from the Commission on progress towards implementing the European declaration on cycling.
Allowing non-compliant products in the EU market undermines companies that invest in European production, innovation, skills and distribution networks. It also weakens Europe's ability to develop a competitive cycling industry capable of contributing to the EU's wider objectives for a decarbonised and sustainable mobility, industrial competitiveness and upskilling and reskilling EU workforce.
Finally, widespread non-compliance risks undermining consumer confidence in EPACs as a safe and reliable form of everyday transport.
Europe needs more active personal mobility. The answer to the rise of non-compliant products must be to protect the integrity of the cycling market and make compliant products the norm, rather than allowing illegal products to undermine confidence in the entire sector.
The regulatory framework is there but enforcement is lacking
The EU has established a comprehensive product compliance framework. The General Product Safety Regulation (GPSR), the Market Surveillance Regulation (EU) 2019/1020, the Machinery Regulation, the Batteries Regulation, the Cyber Resilience Act, the Radio Equipment Directive, the Digital Services Act, and the Regulation 168/2013 governing vehicle type approval provide tools to ensure that products placed on the European market are safe and compliant.
Yet the effectiveness of these rules is challenged by the rise of sale of non-compliant products and the easy access to tampering kits.
The aforementioned INI report from the European Parliament explicitly recognises this enforcement gap. It highlights insufficient resources and digitalisation, limited cooperation and data sharing between customs and market surveillance authorities, and difficulties in controlling products sold through online platforms and shipped directly to consumers.
The cycling industry therefore calls for a coordinated European response that makes existing rules effective in practice and closes the remaining enforcement gaps.
Supporting documents
