# Electric bike users should be aware of this for Spain



## Penquin

I can offer no advice other than to read what is being talked about on another forum concerning potential fines for electric bike users not in possession of a Certificate of Conformity;

http://www.outandaboutlive.co.uk/forums/Motorhomes/Motorhome-Matters/E-bikes-In-Spain-Beware-/36515/

Read and consider whether you MIGHT be affected IF it is true.......

I can see a considerable number of e-mails winging their way to the manufacturers of the bikes as a result.......

Dave


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## nicholsong

Dave

I do not have a CofC for the MH.

Maybe I could be fined too? And is it just Spain or could that apply anywhere?

I understand that the law changed so that there is now a Type CofC, but I think that was after the build of my MH in 2003.

Geoff


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## Telbell

Like many others on here we sourced our bikes from AS Bikes. I don't remember receiving any COC so I've emailed Peter to see what the situation is,especially given that his bikes can be used "throttle only"

I don't really fancy a 2000euro fine-I'll let you know of any reply


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## rayc

It looks like they are looking for proof that it complies with the rules for 'electrically assisted pedal cycles' (EAPCs).
The CoC should give the power output.

How many of the EAPC's in use meet the UK requirements? They should not be on sale unless they do.
https://www.gov.uk/electric-bike-rules


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## DABurleigh

Throttles are only legal in the UK, and only for now, though it won't be retrospective when they ban them.

Dave
Edit: Throttles are OK ONLY if they work when the bike is being pedaled.


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## erneboy

Given that both power and speed are restricted you would think that these legislators could find something more important to keep themselves amused, Alan.


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## BillCreer

So too avoid a 2000 euro fine I have to show my COC to the Spanish police?


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## Telbell

DABurleigh said:


> Throttles are only legal in the UK, and only for now, though it won't be retrospective when they ban them.
> 
> Dave
> Edit: Throttles are OK ONLY if they work when the bike is being pedaled.


Re your last line Dave. AS Bikes are able to be ridden Throttle-only. Are you suggesting they are illegal??


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## Telbell

rayc said:


> It looks like they are looking for proof that it complies with the rules for 'electrically assisted pedal cycles' (EAPCs).
> The CoC should give the power output.
> 
> How many of the EAPC's in use meet the UK requirements? They should not be on sale unless they do.
> https://www.gov.uk/electric-bike-rules


But we are talking here of the requirements in Spain- not UK (in any cae I understand UK is considering a change which would include allowable power of 250w))


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## DABurleigh

Telbell,

In the most of Europe the motor can only legally work when the pedals are turning forward. If the AS-bike's throttle is truly independent of pedaling, then that is legal in the UK but generally not in Europe.

Dave


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## Telbell

DABurleigh said:


> Telbell,
> 
> In the most of Europe the motor can only legally work when the pedals are turning forward. If the AS-bike's throttle is truly independent of pedaling, then that is legal in the UK but generally not in Europe.
> 
> Dave


Hmm-in which case a lot of us are using Peter's bikes illegally- irrespective of COC issues

..and I assume "capable of..." is the salient expression, rather than "using the throttle" ??


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## DABurleigh

They are cheap and a branch of "AS-Toys" .... :-(


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## nicholsong

One Europe - hurrah!

Just like MOT  :lol:


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## DABurleigh

Tell me about it - only recently got a refund of the second lot of VAT I had to pay on the van. So much for seamless trading across borders :-(

Perhaps AS-bikes could offer a pedal sensor. I'll be getting a Nano electric conversion for my Brompton folder and a pedal sensor is available as an add-on to make it EU legal.

Dave


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## wakk44

I would like to get some clarification on the throttle rule as we want to use our e-bikes in Spain soon.

Ours bikes are imported by a company called Gee bikes and do have a throttle control which is switchable.

DAB-are you saying that providing the throttle is switched off so the bike is in pedal assist mode only it would be legal to use in Spain?


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## Mrplodd

I am pretty sure that there was a date some time in the not too distant PAST after which electrically assisted pedal cycle could ONLY operate on "pedal assist" (I.e. Not having a twist grip throttle) anything sold BEFORE that date could operate on pedal assist AND twist grip.

I will attempt to find the info.


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## bognormike

so the easy answer is to either not use the "power" mode , or to disconnect the wiring for the "throttle", so it only works on power assist. 

or completely ignore this like everybody else will - including the police. Are they remotely interested, or do they even know that these bikes have such a gizmo?


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## bognormike

Mrplodd said:


> I am pretty sure that there was a date some time in the not too distant PAST after which electrically assisted pedal cycle could ONLY operate on "pedal assist" (I.e. Not having a twist grip throttle) anything sold BEFORE that date could operate on pedal assist AND twist grip.
> 
> I will attempt to find the info.


\

s
does this all sound a bit familiar (a-frames etc) :roll:


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## HurricaneSmith

Now that manufacturers are freely publishing their electric bike CoCs on the web I find myself wondering how European bobbies would differentiate between a genuine one and some rapscallions forgery?

For myself, I'll wait to see what my bike manufacturer comes up with, particularly as I only ever use mine on pedal assist as it goes so much further.

Looking to the future, it can't be too difficult to cosmetically modify a bike currently deemed illegal in Europe. I wonder if a simplistic mechanical elimination of the twist grip throttle would do? Removing the modification back home would restore normal use. :?


Edit:
I'm too slow typing..........Mike has suggested a similar side step.


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## Mrplodd

How long before some bright spark starts selling C of C's on EBay?

Whats the chances of anyone knowing if they were genuine or otherwise?

Come to think of it how difficult would it be to produce your own in Word/Publisher once you know what a genuine one looks like. If they are in the back of some manuals they clearly won't have any security measures like holograms so they certainly cannot be difficult to replicate can they :wink:

See below link for UK legislation (no mention of Coc!)

https://www.gov.uk/electric-bike-rules

See also

www.pedelecs.co.uk/electric-bike-guides/uk-electric-bike-law/


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## DABurleigh

"DAB-are you saying that providing the throttle is switched off so the bike is in pedal assist mode only it would be legal to use in Spain?"

No, not if you could switch the throttle back on. The bike must not have the capability of the motor being on without the pedals turning. (Though there is a subtlety below 4mph - but that's irrelevant in practice)

Dave


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## wakk44

Thanks for that,looks like I'll be removing the batteries and using them as conventional bikes-mrs wakk will be pleased. :roll:


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## Telbell

DABurleigh said:


> "DAB-are you saying that providing the throttle is switched off so the bike is in pedal assist mode only it would be legal to use in Spain?"
> 
> No, not if you could switch the throttle back on. The bike must not have the capability of the motor being on without the pedals turning. (Though there is a subtlety below 4mph - but that's irrelevant in practice)
> 
> Dave


 Not sure the 4mph is irrelevant-I often use the throttle just to move off from a standing start or start me off up a hill.


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## teemyob

Would Never Surprise me.

As I say on similar topics......

Meanwhile, Pedro in Spain chugs along in his 40 year old renault, Gitane in hand just about not puffing out due to his high breath alcohol content. 

300+ White Transit van driver tootle along with they convoy of femmes / hommes and feral kind, untroubled. Stopping ad lib. 

Not forgetting the piled high convoy of overloaded Blue Mercedes Varios from the 1980's with a hundred or so African Lucky men selling cheap One Pound Sunglasses at prices that would scare a Monacocanian Royal. 

It is you and I, legal or perceived to be illegal that will cop the Bill, if you will pardon the pun. 

TM


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## Telbell

I've had a lengthy email from AS Bikes-most of it seems to be an extract from industry communication but the bottom line is, to put a self-tapper into the underside of the throttle control so as to temporarily disable the "twist and go" capability. This can be removed for UK use.

Or of course take the risk, which I'm sure many will do.

He's sent me an attachment of a COC. I've tried to attach it here but I keep getting "Server error"-presumably because it's a 2.5mb file.

If any AS customers need a copy I'm sure Peter will send you one- or if you PM me I'll send one back by email.

Bear in mind the COC merely states it's UK compliant and doesn't provide an exception to the "No twist and go " rule when over the water.


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## DABurleigh

"Not sure the 4mph is irrelevant-I often use the throttle just to move off from a standing start or start me off up a hill."

No, because your earlier presumption of capability rather than use is quite correct.

Dave


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## Telbell

DABurleigh said:


> "Not sure the 4mph is irrelevant-I often use the throttle just to move off from a standing start or start me off up a hill."
> 
> No, because your earlier presumption of capability rather than use is quite correct.
> 
> Dave


Isn't that the purpose of the 4mph/6kph "tolerance" though?- moving off from a stationary position?- (assuming of course it's incapable of going over that speed on throttle only)


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## nicholsong

I thought recent CoC are EU-wide. Maybe that is for vehicles, not electric bikes.


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## DABurleigh

Context is everything. If the bike in question has a 4mph sensor so the throttle is incapable of working above that, that throttle is legal in Europe.

As to a self-tapper crippling a throttle, I won't hold my breath awaiting case law to prove its acceptability to Spanish police. I'm sure AS Bikes are confident enough in their advice to underwrite any fines.

Dave


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## ned

*Electric bikes*

Hi,
Anyone who has a freego bike or whisper can contact them at HQ in southampton and they will send you a COC by email. Job done

Ned


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## SNandJA

I have an electric scooter with a plate that contains what I assume is the contents required in the CoC which I don't have as a paper document. We have just returned from a month in Portugal and Spain and certainly in Portugal have been riding past various kinds of police! Pretty sure they have also seen it being ridden with pillion passenger.
We dropped off in the large Carrefour in Sestao near Bilbao just before the ferry back and there was an almost identical model for sale at around 500 Euro..... It has pedals which operate the throttle if you make around 5 or 6 turns. However it mainly operates with throttle as it is just about 40kg with battery and scooter. Purchased from a dealer at Motorhome Show in Stafford who is based in Nottingham.

Should I be worried?

Steve


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## SNandJA

Aforementioned plate!


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## SNandJA

Guess this is my problem from Pedelecs via Mr Plodd

"Assistance

In most of Europe the motor can only legally work when the pedals are turning forward, in the UK this is not the case and the throttle can work independently. If the UK laws change and outlaw independent throttle control, the new law will NOT be backdated so any bikes bought prior to new legislation will not be affected.

Throttle control

Throttles operating independently of the pedals, enabling a bike to be ridden on power only are legal in the UK under the 1982 EAPC regulations. They are illegal under European regulations if they enable the bike to be propelled at more than 6kph (4mph) without the pedals turning forward.

Throttles operating under pedelec control, only permitting regulation of power whilst the bicycle is beeing pedaled forward are legal everywhere in Europe and the UK."


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## jeffro

*electric bikes*

We are off to Spain next month and we are taking two electric bikes both have throttles and were bought second hand a couple of years ago on ebay.So who has been nicked then ? Otherwise i am just going to carry on as normal


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## Telbell

Steve- the plate has the battery capacity shown which is a feature required as I understand things. Also the "Complience" number should I would think, satisfy the police but really , who knows??

It seems though, like many of us, using, or even having the capability of, a "twist and go" throttle would be illegal outside UK.

It would be interesting to see if there has been anyone stopped/fined for this-all I've seen is ..."I have seen somewhere that...." statements.

There must be many of us affected by this.

edit: perhaps the eg you saw in Bilbao would need a Spanish Driving licence holder/Insurance to use it???


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## rosalan

I offer myself up to the Spanish and French police/legal system as guilty.
To say that I am disappointed would be an understatement. Until now I had only heard rumours of this legislation, so when my wife and I saw or passed a policeman, we peddled like fury. Covering more than 300 miles this summer up the steepest hills and busiest cities we were kings and queens of the road, something to be mourned unless we risk all and break the law..
We met a Dutchman in Spain with a 45watt motor and throttle, bought in Spain but it was a tricycle and looked otherwise, identical to AS bikes. He used his bikes but we only saw him off-road; still....
Perhaps if we wear our helmets, they may take no notice of us (the Police) but encouraging my wife to wear the silly looking plastic jazzy thing, may not be so easy. This, in spite of them filling valuable boot space every year without getting used at all.    

Alan


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## SNandJA

Telbell said:


> Steve- the plate has the battery capacity shown which is a feature required as I understand things. Also the "Complience" number should I would think, satisfy the police but really , who knows??
> 
> edit: perhaps the eg you saw in Bilbao would need a Spanish Driving licence holder/Insurance to use it???


Sadly I can't comment on this last observation but from memory there was no reference to the need for any such things. Given it is a huge Carrefour and as a chain they are likely to be reasonably careful with what and how they sell products then you'd assume some kind of warning would be on show?


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## ettica

EAPAC Proposals for UK intend to up the max wattage to 250 (as in Europe) and to keep "independent" throttle

More here.
search for government consultations electrically-assisted-pedal-cycles-changes-to-regulations

Copy and paste into google, you should get the link on .gov.uk


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## greygit

Just to be on the safe side I have just taken the throttle of my leccy bike, had an error code come up on the screen to start with but seems to be ok now. I will take it with though in case I get problems later. :?


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## Zebedee

Bloody pathetic!

So 5 mph without pedalling is dangerous!

What about freewheeling downhill, or after a bout of pedalling on an ordinary bike?

Since they are restricted to 15mph anyway, *which is less than half the speed a fit person can pedal on a road bike,* I can only ask *WHY *it's illegal to use a throttle at more than 4MPH?

If someone walked in front waving a red flag, would that be OK?

You couldn't write the script! :roll:

Dave


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## Telbell

Just been looking again at this thread- and in particular Dave(Penquin's) Opening Post which in turn quotes a thread on OAL.

Have we all complicated matters here and persuaded ourselves that "throttle-only" e-bikes in Spain are illegal??

The Opening Post on OAL suggests they're only illegal if we don't have a COC or (some sort of...eg 3rd Party/Public liability...?)Insurance. (or is it both?

If we have one of those (or both?? :roll: :lol: ) they're ok.

Just saying :wink: 

But I agree with Zeb's last Post having many times seen lycra-clad-drop-handlebars-cyclists in Spain doing MUCH more than 15mph!


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## jiwawa

Your understanding is the same as mine Tellbell. 

Can someone explain, to a dummy, how to disable the throttle? 

I emailed ProRider more than a week ago about CoC - no response.


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## erneboy

If you're bothered about it jean just glue it in place so it can't turn, Araldite will do it. I'll have a look at mine tomorrow and see how if you like. Personally I won't be bothering though, Alan.


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## Penquin

Totally agree with Zebedee about how pathetic such a restriction is......

I wonder how the riders of the Tour de France would feel if restricted to a maximum of 15 mph?

Insurance? I believe that is difficult to find since the bikes are not registered (DON'T go there.......) but maybe that might be beneficial for ALL cyclists, not just those trying to continue a healthy activity in their latter years......

We are all encouraged to undertake exercise whenever and wherever possible, there are continued complaints about obesity and the number of "couch potatoes" developing and yet here once country unilaterally decides to make some related equipment illegal - to me it raises serious concerns about why Spain once again seems to be ruling the roost and has not be stopped in their tracks......

The simplest answer is AVOID SPAIN. Such a policy would rapidly affect their economy much more than any potential fines they might gain from enforcing it.......

Spain seems determined to fly in the face of European Laws - they should be stopped by the EC........

Dave


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## jiwawa

Alan, I hadn't really wanted to do something permanent. My husband can only manage riding the bike - at the moment - using the throttle and virtually no pedalling. Nor does he have a driving licence so you can imagine how I felt when I read this thread!!

Is there any other way to disable it temporarily?


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## erneboy

It might be best if the twist grip didn't twist, no possible doubt then. A little black Sugru would do that job and could be cut off again if required. It moulds very easily in your fingers and hardens into a very firm rubber which adheres very well. Done carefully it would blend in very well http://sugru.com/about it's simple to work with.

If that doesn't suit I imagine it can be disconnected. I can look at mine if you like, Alan.


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## Telbell

Peter (AS bikes) suggests a self tapper screw into the handlebar which can be removed to free up the throttle for use in Uk, France...or anywhere else :lol: 

May be worth checking household Insurance to see if non motorised bikes are covered for public liability-in which case you may not need to use the screwdriver!


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## charlieivan

If looking for insurance for your bike, try the Cyclists Touring Club (CTC)
Simply by joining as a member and paying the membership fee of £41.50, family membership £68and for over 65's £27. You will be covered for third party liability for up to £10 million. Several other benifits also. Have a look at their website.


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## jiwawa

Alan - thanks for the tip.

Tellbell - you say "May be worth checking household Insurance to see if non motorised bikes are covered for public liability-in which case you may not need to use the screwdriver!" - I don't really understand what you're saying here - if I don't use the screwdriver (or similar) then it will be a motorised bike rather than non-motorised. Or am I misreading this?

Charlievan, I think I did look at CTC but we need long-term cover abroad. I think they do up to 90 days abroad? Must check again!


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## Telbell

JWW said:


> Alan - thanks for the tip.
> 
> Tellbell - you say "May be worth checking household Insurance to see if non motorised bikes are covered for public liability-in which case you may not need to use the screwdriver!" - I don't really understand what you're saying here - if I don't use the screwdriver (or similar) then it will be a motorised bike rather than non-motorised. Or am I misreading this?
> 
> Charlievan, I think I did look at CTC but we need long-term cover abroad. I think they do up to 90 days abroad? Must check again!


JWW-now this is of course only my opinion but an e-bike is a Type of pedal cycle, according to the UK definition
https://www.gov.uk/electric-bike-rules

My own Household Insurance refers to "non-motorised" vehicle. The question is, does putting a battery on it make it motorised? I can't see how it can be an EAPC AND a motorised vehicle, and if "motorised" it would surely be a "motor vehicle" and Insurance would be needed as if it were a car??- another eg would be (most) mobility scooters which have a battery, but (most) don't requite Road Traffic Act Insurance.

AS I say, it's just an opinion-no doubt an Insurance co would enlighten us

(how did we get into this?
:lol: )


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## jiwawa

Telbel, I think the problem is that I'm thinking of this from the point of view of Spain, as that's where we'd hope to use them primarily.

And it seems as if they are regarding our type (can be used with throttle only) as 'motorised' and therefore needing insurance, driving licence etc

But again, I may be misinterpreting what I've read.


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## middman

charlieivan said:


> If looking for insurance for your bike, try the Cyclists Touring Club (CTC)
> Simply by joining as a member and paying the membership fee of £41.50, family membership £68and for over 65's £27. You will be covered for third party liability for up to £10 million. Several other benifits also. Have a look at their website.


As I understand this issue, the requirement in Spain seems to be that if the bike can be propelled without pedelling it either has to have a Certificate of Compliance or insurance. This means RTA cover such as that on a moped to cover you for use on the public highway, not just liability insurance. Household insurance covers limited public and personal liability up to a stated policy limit. RTA, or motor insurance has to give unlimited liability.

Hope this helps with the insurance issue.


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## Telbell

But we don't know this for sure. Under UK law its eapc not motor vehicle. I agree that coc saying it's eapc should be ok. All guesswork though!


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## nicholsong

Many Governments seem to have no concept of the law and the idea of insurance.

In most western Jurisdictions if a person causes injury or death to another they are liable, either in criminal or civil law or both, whether they have insurance or not, which is only an indemnity for their own personal liability.

It matters not whether they did it with a punch, a skateboard, an electrictic bike, scooter or a f.ing big truck.

If the person responsible has no insurance the victim, or estate, may be able to sue if the individual is rich. If not, and there is no insurance, there may be little chance of recouping any money.

If the individual has insurance there is more chance of recovery of damages.

Governments seem to require certain individuals, mostly those operating some sort of 'powered' machinery to have insurance.

Why only those people, and not pedal cyclists and skateboarders? or those walking around with knuckledusters and knives?

My answer is that most legislators could not even understand the question.

Geoff


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## rosalan

from the CTC Insurance

Unless I have misread the clause "3. Is my electric cycle covered? If so, what are the restrictions?
Answer: Where the main source of propulsion is electrical, the cycle would not be
covered as it would be classified as a motor vehicle and should therefore have Road
Traffic Act insurance. However, if it has pedals and is mainly used as a conventional
bicycle (unicycle, tricycle, tandem or triplet) and only has electric
assistance then it would be covered."

So no help there then.

Alan


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## Lifesabreeze

Telbell said:


> I've had a lengthy email from AS Bikes-most of it seems to be an extract from industry communication but the bottom line is, to put a self-tapper into the underside of the throttle control so as to temporarily disable the "twist and go" capability. This can be removed for UK use.
> 
> Or of course take the risk, which I'm sure many will do.
> 
> He's sent me an attachment of a COC. I've tried to attach it here but I keep getting "Server error"-presumably because it's a 2.5mb file.
> 
> If any AS customers need a copy I'm sure Peter will send you one- or if you PM me I'll send one back by email.
> 
> Bear in mind the COC merely states it's UK compliant and doesn't provide an exception to the "No twist and go " rule when over the water.


I had been looking at AS bikes but after reading this and their website I don't think I will.

Their website states "AS Bikes design all our bikes in house ", so they have designed one that is not compliant with European law.

Not much of a problem except they target motorhome owners, the majority of who travel in Europe.

Not such a brilliant design job!

I'm now looking for a fold up pedal assist bike.

.


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## Telbell

Alan. The answer surely is in ctc," s last sentence. In which case it would be covered. I can't see any way in hush t can be a EAPC AND a. Motor. Vehicle.


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## Telbell

Sorry. Using phone on mob mhf! Bike used mainly with pedals but having electrical assistance is surely EAPC


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## Penquin

> *Lifesabreeze said; *Their website states "AS Bikes design all our bikes in house ", so they have designed one that is not compliant with European law.


I do not consider those two sentences to be in conflict...... they do design all their bikes in house and their designs do meet UK and EU regulations BUT when one country (Spain) decides to reinterpret them differently to others it is them that is in breach of EC law, not AS Bikes.....

This seems to be something the Spanish authorities do frequently - it is a reflection on them not anyone else, there are numerous examples and I am sure we can all think of some; bikes, A frames, Gibraltar entry, Common Fishing policy and I am sure others will be able to add more.....

The problem lies with the Spanish so the answer is simple - *AVOID SPAIN AND THEY WILL QUICKLY REALISE THAT IT WORKS AGAINST THEM.*

Dave


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## nicholsong

Dave

I understand your sentiment, but I do not think the spend from you me and a couple of dozen MH drivers will make much of a dent in Spain's GDP.

Geoff


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## erneboy

I did wonder whether our doing a two person, two dog boycott would teach them a lesson, but then I decided it would be cutting my nose off to spite my face. I'll just ignore the warnings on here and carry on as normal. Will report in if I get nicked.


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## jiwawa

Are you in Spain now Alan? 

If you go quiet on here, we'll know you're behind bars! (but which kind?!)


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## Penquin

> *Geoff said; * I understand your sentiment, but I do not think the spend from you me and a couple of dozen MH drivers will make much of a dent in Spain's GDP.


I would agree with you there, but then the same could have been said over the idea that eating veal raised in the UK was unacceptable.....

It gained credence over time and has resulted (sadly IMO) in veal rarely being encountered in the UK......

but the same people are still content to drink milk - which of course can only come from female cattle, and sexing the foetus is impossible so can only be determined at birth - if female that is OK, if male what market is there for it?

So a small group has influenced National habits....... if many people believe that Spain is behaving unreasonably then more will avoid the country.....

The longest journey starts with a single step.......

Dave


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## erneboy

> Are you in Spain now Alan?
> 
> If you go quiet on here, we'll know you're behind bars! (but which kind?!)


Yes Jean. Here http://www.motorhomefacts.com/spaetzlefritz-campsite.html

Propping the bar up,

Alan.


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## nicholsong

erneboy said:


> Propping the bar up,
> 
> Alan.
> 
> 
> 
> Not much fun if he hasn't left you the keys :lol:
Click to expand...


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## erneboy

He's in hospital Geoff, not so well which is a pity.

On the bright side, the lady co-owner has gone to visit him and has left me all the keys. Hic.

It's amazing how the place changes when the miserable git isn't here, though I'm sorry he's ill, Alan.


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## Lifesabreeze

Penquin said:


> *Lifesabreeze said; *Their website states "AS Bikes design all our bikes in house ", so they have designed one that is not compliant with European law.
> 
> 
> 
> I do not consider those two sentences to be in conflict...... they do design all their bikes in house and their designs do meet UK and EU regulations BUT when one country (Spain) decides to reinterpret them differently to others it is them that is in breach of EC law, not AS Bikes.....
> 
> Dave
Click to expand...

It isn't just Spain though, it's in most of Europe that the motor can only legally work when the pedals are turning forward.

So no AS Bikes designs do not meet EU regulations.

.


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## Telbell

See Opening Post and subsequent link. A c of c or relevant insurance should satisfy Spain. Isn't that what it says??


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## jeffro

*electric bike in spain*

Well braved it to day shot down the indoor market in Benidorm on my e bike parked it with several others all with throttles even rode past a copper nobody paid me the slightest attention.there is thousands of e bikes out here in fact you will have trouble finding a normal push bike


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