Product Safety for Heavy Duty Cargo Bikes: What are the Advantages of a Cargo Bike DIN?
The bicycle auditors Dirk Zedler and Marcus Schröder discuss the applicability of the new cargo bike DIN to heavy-duty cargo bikes.
Commercial heavy-duty bikes with a pedelec25 drive and a total weight of up to 500 kilograms are becoming increasingly relevant. Moreover, the German federal government provides subsidies of up to 2,500 euros for their purchase.
The German traffic law does not set an upper limit on the weight of bicycles. From a legal point of view, heavy-duty cargo bikes are considered bicycles and are therefore not subject to registration nor do they require a licence if the electric pedal assistance remains within the scope of a pedelec25 drive. The bicycle status is an important prerequisite for making heavy-duty cargo bikes an attractive alternative to diesel vehicles for companies - an alternative that politicians would like to see come to fruition.
On the other hand, the increasing number of large heavy-duty cargo bikes on the road naturally raises a lot of questions. What consequences does this have for the width of cycle lanes? How can we prevent putting other cyclists and pedestrians at risk? The German Cycle Logistics Association (Radlogistik Verband Deutschland e.V.) is currently planning to introduce a code of conduct for its members.
One important question is the product safety for heavy-duty cargo bikes and setting a recognised standard with minimum requirements. Like any other e-bike with a pedelec25 drive, heavy-duty cargo bikes must comply with the EU's Machinery Directive under the Product Safety Act and require a CE marking. However, the responsibility of ensuring compliance solely lies with the manufacturer. The manufacturer is not obliged to commission a testing institute. The same applies to further tests to ensure compliance with all relevant points of the Product Safety Act. Optional industry standards (DIN, EN, ISO) often act as guidelines.
There has also been a cargo bike DIN since the beginning of 2020. However, the scope of application of the DIN 79010 is limited to a maximum weight of 300 kilograms for multi-track cargo bikes. Many heavy-duty cargo bikes exceed this weight.
The scope of application already caused irritation among manufacturers and users of heavy-duty wheels during its creation process. Finally, a passage was included in the DIN:
The members of the Working Group expressly welcome the latest developments in the logistics and mobility sector and the development of heavy-duty transportation bikes and cargo bikes with permissible total weights of over 250 kg and 300 kg. This standard is not opposed to the development of heavy-duty transportation bikes and cargo bikes with dimensions larger than those outlined in this standard or with a higher total permissible weight.
Meanwhile, a cargo bike working group at the European Committee for Standardisation (CEN) is also developing a European EN standard for cargo bikes. It is foreseen to cover heavy-duty cargo bikes with a total weight of more than 300 kilograms.
So what standard can manufacturers follow in the meantime to document the safety of their products? Can they apply the cargo bike DIN despite exceeding the 300-kilo limit? CCCB partner, cargobike.jetzt, asked two German bicycle auditors with cargo bike expertise: Dirk Zedler from the Zedler Institute and Marcus Schröder from EFBE Prüftechnik.
cargobike.jetzt: Can manufacturers of heavy-duty cargo bikes with a permissible total weight of over 300 kilograms apply the cargo bike DIN 79010 in a modified way and subsequently declare their cargo bikes as DIN-tested?
Marcus Schröder: Apply - absolutely! However, with the necessary adjustments and with a sense of proportion. Declare it as DIN-tested - no! I see it as "tested in accordance with DIN 79010".
cargobike.jetzt: In what way do manufacturers have to take the extra weight into account?
Marcus Schröder: The strength tests of components, the brake tests and other relevant elements of the DIN need to be scaled. At some point, the bicycle standard simply doesn't work anymore. We have tested tricycles weighing over 300 kilograms, and that was absolutely OK. But we have also turned down orders when we had the impression that we could not do justice to a heavy-duty cargo bike with standard bicycle tests.
cargobike.jetzt: What are the differences in liability for manufacturers and users of heavy-duty cargo bike that are "tested in accordance with DIN 79010" compared to DIN-tested cargo bikes that are within the scope of the standard?
Dirk Zedler: This is where it becomes a legal matter. From my practice as an expert, I can report the following:
The Product Safety Law explicitly states that standards can be used to assess the safety of a product. There are high-judicial rulings, which confirm that a judge does not have to take a standard into account in the case of a dispute but can apply other or higher standards if they can be justified. This can be applied to manufacturers.
Compliance with DIN 79010 does not shield cargo bike manufacturers from liability. After all, a standard is only an agreement between interested parties. In the case of DIN 79010, there is also the problem that it was only drafted by German experts. The situation is different for DIN EN 15194 for pedelecs. This is "harmonised" under the European Machinery Directive and therefore has "legal character". Nevertheless, here too, more testing must be done if the scope of application is exceeded, e.g. in terms of weight [Note cargobike.jetzt: DIN EN 15194 only applies to a maximum weight of 120 kilos].
This means: In every case of damage, the concrete situation is investigated and, ideally, competent experts have their say.
Therefore, there is no way around the due diligence of each individual manufacturer together with his chosen testing partner. In the event of damage, a final statement will usually have to be made by a court, as lawyers often have conflicting views.
In conclusion, this means for manufacturers of heavy-duty cargo bikes:
It is a good idea to follow the DIN 79010. However, the DIN must be checked for completeness (which it is not) and its applicability must be justified. A risk analysis must be carried out that relentlessly reveals the weaknesses of the design, all residual risks, areas requiring further improvements and assesses the applicability of the DIN standard.
As Marcus has already said: "Tested in accordance with DIN 79010" would be the correct term for the manufacturer to use.
cargobike.jetzt: Thank you for your insights!
About the interviewees
Dirk Zedler is a publicly appointed and sworn-in expert for bicycles and e-bikes and the Managing Director of the Zedler Institute for Bicycle Technology and Security. He is also a member of the DIN Standards Committee for Bicycles for General and Sporting Use.
Marcus Schröder is the Managing Director of EFBE Prüftechnik, a testing lab for mechanical testing of bicycles, e-bikes and their components. He is also a member of the cargo bike working groups of the DIN Institute and the European Committee for Standardisation (CEN).
Information for manufacturers: Contribution to the development of standards
Manufacturers and other "interested parties" can participate in the design and further development of industry standards for cargo bikes and especially heavy-duty cargo bikes at German and European level:
Finally, the European Cargo Bike Expert Group offers manufacturers the opportunity to network on a European level and to exchange views on issues relating to the standardisation and regulation of cargo bikes.
This article was originally published by CCCB partner cargobike.jetzt.