Micro-Mobilty for Europe (MMfE) was invited to present its views in the workshop on ”technical requirements and road safety of Personal Mobility Devices (PMDs)’’ on 14 September, organised by DG GROW and DG MOVE.
Road safety data shows that the number of e-scooters incidents in Germany were limited
Besides MMfE, representatives from Member States presented their views and provided information on the applicable national rules on technical requirements for light electric vehicles (LEVs). Member States also shared road safety data from their respective countries. Patryk Dudek from the German Transport Agency highlighted that their official national statistics show that e-scooters caused a very limited number of incidents compared to other transport modes, based on data from 2021 (i.e. bicycles and cars). MMfE welcomes the fact that EU Member States are monitoring road safety data on new modes more structurally, and would welcome the opportunity to contribute to these efforts.
The need for horizontal legislation for personal light electric vehicles
MMfE’s representative emphasised the need for a unified approach and called for horizontal legislation that is innovation-friendly, i.e. not too strict, to avoid hampering innovation and limiting the offer of sustainable mobility solutions. Furthermore, MMfE called upon the EU not to allow for deviation on a national level to offer legal certainty to producers.
The main issue discussed was the absence of central legislation setting technical requirements for “personal light electric vehicles” – which should include e-scooters and e-bikes with a design speed of up to 25 km/h. In the absence of horizontal legislation at European level, regulatory divergences at national level are expected to intensify. This will lead to barriers in the internal market, which is contrary to the principles on which the single European market is founded.
Hence, MMfE strongly supports the adoption of a common regulatory framework that creates a new dedicated category and that will establish technical requirements for personal light electric vehicles.
In the creation of a new central regulatory framework, it is essential that the EU does not impose measures that could be detrimental to the uptake of sustainable mobility options, like an obligation to homologate vehicles. There is no evidence that a type approval procedure involves an increase in security levels for users and third parties, in comparison to the current system based on self-certification, as identified by a TRL report. If a sort of type approval procedure is deemed necessary, the EU should propose a light procedure that is not too burdensome in terms of time and cost for the micro-mobility industry.
Furthermore, the imposition of regulatory measures to which motor vehicles are subject should be avoided such as the obligation of motor insurance and of the license plate for shared micro-mobility devices. These measures are designed for heavy vehicles (passenger cars and vans) and do not reconcile with the nature, size, and purpose of light electric vehicles.
Finally, MMfE seizes this opportunity to thank the European Commission for the invitation to the stakeholder dialogue. MMfE would also like to reiterate its willingness to work together with the decision-makers and other relevant players, for the establishment of an EU legislative framework that favors the healthy and continuous development of sustainable transport solutions across Europe.
Micro-Mobility for Europe (MMfE) welcomes the overall objectives of the proposal for a Battery Regulation put forward by the European Commission in December 2020. Our sector fully supports the need to accelerate the transition towards a more electrified transport system as clearly stated by the first recital of the proposal: “A shift from the use of fossil fuels in vehicles to electromobility is one of the prerequisites for reaching the climate neutrality goal in 2050”. The importance of the announcement of the Commission regarding the modernisation of EU legislation on batteries was underlined by the fact that the European Commission listed it among the actions in its new Circular Economy Action Plan. Micro-Mobility for Europe believes, as well as the European Commission, that more sustainable batteries throughout their life cycle are essential in achieving the decarbonisation of the transport sector, and the EU economy as a whole.
We believe shared micro-mobility solutions have the potential to generate a modal shift away from car trips to more sustainable modes, and complement public transportation, which will ultimately reduce GHG emissions and increase quality of life in urban areas. To support this vision, Europe needs a robust, coherent and clear regulatory framework around batteries. Batteries are essential for micro-mobility solutions that support the EU’s decarbonisation objectives, which is why MMfE fully supports the inclusion of specific provisions for batteries for ‘light means of transport’ such as e-scooters.
However, we have noticed with concern some inconsistencies in the proposal and misunderstandings about where the light electric vehicle industry is and where it is going. In order to safeguard the European Commission’s goals of increased safety and sustainability for batteries, while integrating coherently with the way light means of transport are evolving today, we wanted to share further insights about how the shared micro-mobility industry uses batteries today and may use them tomorrow. We believe these insights can help both the European Commission and, more particularly, co-legislators (European Parliament and Council) to review the current proposal for a coherent, accurate and future-proof framework on batteries in Europe.
The use of batteries in shared micro-mobility applications
Batteries used in e-scooters and other micro-mobility vehicles have undergone a huge development. Today most companies operating shared e-scooters undergo strict scrutiny by local governments regulated through licenses or tender agreements. That means all members of the coalition work to understand and limit environmental impact by optimising disposal, second life and recycling of batteries.
Battery production is one of the most carbon-intensive parts of e-scooter manufacturing, which in turn contributes the most to an e-scooter’s overall lifetime emissions. According to the latest reports on the environmental impact of e-scooters, their life cycle is highly impacted by the material used to manufacture the vehicles (incl. the battery). The use of raw material contributes to between 68% and 90% of their total carbon footprint. Proper disposal and recycling represent an environmental challenge, and our members have been working with first class recycling partners for responsible disposal and recycling to minimise this impact, adapting to various circumstances. According to the EIT MOBY report, future developments, especially in battery management and recycling processes, will substantially reduce the environmental impact of e-scooters.
Most e-scooters run on some type of lithium-ion batteries of capacity between 300 Wh and up to approximately 1500 Wh and have a battery pack composed of individual cells and electronics grouped in a battery management system. E-scooter battery technology is chosen for its light weight, its performance and long lifespan. For the purpose of the EU Battery Regulation, it is also important to note that the same battery pack can be used interchangeably for an e-scooter or an e-bike.
E-scooter and micro-mobility manufacturers have taken measures to tackle the carbon footprint associated with battery production.
In terms of average lifespan of batteries, this depends on the battery type used and the battery chemistry. Notwithstanding peak and lower performing batteries, in terms of average figures we have observed that the industry standard is approximately 400-700 cycles, which roughly equates to 14,000-25,000 km driven. Shared e-scooter batteries can achieve 14,000+ miles (22,500+ km) of expected battery life. Calendar time can be a misleading metric; for example, a consumer model that averages two rides per week might be able to market a 5-year battery life, where shared rentals would see much more use.
Concerning the management of end-of-life, once a battery is decommissioned our members will first consider it for reuse namely by disassembling the battery, testing individual battery cells, and passing the performant ones on to our partners for a second life as battery packs for other purposes. Moreover, members of Micro-Mobility for Europe have developed partnerships with recyclers to recycle lithium-ion battery cells, circuit boards, and e-waste. The industry has been working to reduce the percentage of cobalt used in battery cells by replacing it with nickel. Any batteries or cells that are not fit for reuse are collected by recycling partners for recycling via hydrometallurgical recycling systems.
When it comes to sustainability and waste management of batteries, members of Micro-Mobility for Europe have developed partnerships with recyclers to recycle lithium-ion battery cells, circuit boards, and e-waste. More concretely, the industry has been active in material substitution with the aim of improving the environmental performance of our operations – as it is the case of the current gradual reduction in cobalt for nickel.
Batteries for light means of transport should all be defined as portable batteries
We agree with the European Commission that light means of transport should fall under the portable battery category. This is clearly stated in recital 12 (p. 25-26) which reads that “batteries used in light means of transport, such as e-bikes and scooters, [should be] classified as portable batteries”.
However, we are concerned with the lack of accuracy when defining light means of transport in Article 2, which seems inconsistent with that recital. Indeed, the definition under Article 2 of light means of transport is very restrictive, and mostly limited to e-bikes. Such a narrow definition cannot properly account for the evolving variety of light electric vehicles, including e-bikes, e-scooters, and many other new innovative vehicles. Therefore, it appears that the content of the Regulation would not match the original intention of the European Commission.
Defining batteries used in micro-mobility vehicles as portable batteries is important for several reasons. The first reason is that it allows for predictability for both the battery industry and the micro-mobility industry, allowing European production of battery cells and batteries to develop and flourish, and for the micro-mobility industry to operate under the same regulatory terms no matter the vehicle’s exact specifications.
We believe that the EU Battery Regulation should set definitions in coherence with other regulations and ongoing regulatory work in the EU. When it comes to light means of transport, weight and speed are the main elements used to categorise and define vehicles, and are also key parameters which define the battery capacity needed to propel the vehicle. This is for example illustrated in the study on personal mobility devices carried out by TRL. This should also be the approach in the Battery Regulation which will be the first legislation in the EU to provide a definition for batteries of ‘light means of transport’. Such a definition should be future-proof, accounting for the variety of vehicles that fall under this category. It should also account for how light means of transport can tackle transport emissions and develop more sustainable mobility in Europe.
A uniform approach for all vehicles similar in speed and weight is also justified by the fact that the exact same battery can be used in an e-bike or an e-scooter. That is, under the proposed regulation, the same battery might find itself classified in one week as a “portable” battery, and the next week as an “electric vehicle” battery. Should the current text remain, this would lead to a very incoherent and unpredictable regulatory framework. Additionally, it would be nearly impossible to manage for battery manufacturers.
Therefore MMfE calls on EU co-legislators to set a coherent, accurate and robust definition for light means of transport that provides an efficient framework for the sustainability and safety of batteries in support of more sustainable means of transport in the short and long run.
Our proposed amendments
Article 2 point 7
Article 2 point 7
Our proposal
‘Portable battery’ means any battery that:
‘Portable battery’ means any battery that:
• is sealed;
• is sealed;
• weighs below 5 kg;
• has a capacity limit of 2 KWh;
• is not designed for industrial purposes; and
• (weighs below 10 kg;)
• is neither an electric vehicle battery nor an automotive battery;
• is not designed for industrial purposes; and
• is neither an electric vehicle battery nor an automotive battery;
Justification
Micro-Mobility for Europe would welcome a classification made on capacity, as the coalition believes it to be a better way to classify batteries. The capacity limit the coalition proposes is 2KWh. A significant part of the weight is composed of material that protects the battery cells from damage, which should not be reduced from a safety and durability perspective. Larger batteries are also more environmentally friendly, as they allow vehicles to operate for longer before the battery is swapped. As battery technology is in continuous evolution, new cell chemistries and other innovations could soon make the legislation obsolete. Therefore, a limitation of 5 kg seems to be limiting to new possible technologies. In case of a weight limitation, Micro-Mobility for Europe would suggest a threshold of 10 kg. Finally, the legislation should concern itself with safety guarantees that are verifiable and backed by data, rather than setting arbitrary weight or vehicle power limits.
Article 2 point 9
Article 2 point 9
Our proposal
‘light means of transport’ means wheeled vehicles that have an electric motor of less than 750 watts, on which travellers are seated when the vehicle is moving and that can be powered by the electric motor alone or by a combination of motor and human power;
‘light means of transport’ means wheeled vehicles that have an electric motor of no more than 2,000 watts, taking into account that the range of vehicle defined as ‘light means of transport’ will likely expand over time, and that can be powered by the electric motor alone or by a combination of motor and human power;
Justification
Light means of transport include a large variety of vehicles such as e-bikes and e-scooters., etc. There is no justification to treat these vehicles differently and the EU Battery regulation should be future-proof as to which light means of transport can be developed in the future, particularly to tackle transport emissions and develop a more sustainable mobility in Europe. Coherence needs to be ensured between the work ongoing on Personal Mobility Devices (incl. TRL study) by DG GROW and the text of this proposal.
Article 2 point 12
Article 2 point 12
Our proposal
‘Electric vehicle battery’ means any battery specifically designed to provide traction to hybrid and electric vehicles for road transport;
‘electric vehicle battery’ means any battery specifically designed to provide traction to hybrid and electric vehicles for road transport, with the exception of batteries to provide traction to light means of transport;
Justification
To avoid any confusion as to what might constitute an electric vehicle battery, we propose clearly excluding light means of transport batteries from the scope of the definition.
Micro-Mobility for Europe (MMfE), the European coalition of shared micro-mobility providers, welcomed the new study on the European Commission review on regulation on PLEVs developed by TRL, a UK consultancy.
As personal mobility is evolving and electrification of all types of transport will be the main driver of decarbonization in Europe, the coalition believes that it is the right timing to understand the main markets and the influence of the existing legislations at EU and national levels. In this context, a representative of MMfE stated: “Our coalition is committed to understanding all kinds of trends to better service our customers. Users of our services are looking for options and we are fully aware of the importance that safety has for all of them. For this reason, we applaud the efforts of TRL in collecting and assessing available data on accidents involving personal mobility devices and safety aspects related to the road circulation of personal mobility. MMfE will always encourage this type of research”.
The vision of the coalition is to ultimately transform urban mobility by creating a sustainable transport ecosystem together with the cities in which they operate. To reach that goal, tailor-made regulation should support e-scooters as an alternative to car ownership and use placing people and the environment at the heart of mobility.
“Regulation will be decisive for our sector and the TRL study – which focuses on market development and related road safety risks for L-category vehicles and new personal mobility devices – addresses one of the cornerstones of our business: minimum safety technical requirements. The regulatory options featured in the report represent a good basis to engage as a coalition and take the European policy debate to the next level”, stated Catriona Meehan, co-chair of the coalition. She continued: “The regulatory options however are divergent and may imply different pathways to achieve the ultimate goal which is to ensure safety. For this reason, we still need to further analyse what it would mean and imply for implementation, enforcement, and viability for our business”.
Micro-Mobility for Europe (MMfE) was launched last February. It is a Pan-European coalition of shared micro-mobility providers of short-term rental electric scooters founded to ensure micro-mobility solutions flourish in European cities and to support the rapid transition to zero-emission urban mobility. It comprises 8 founding members operating in over 20 EU countries and across more than 100 European cities For further information:micromobilityforeurope.eu
Creating a sustainable transport ecosystem by reshaping urban mobility along with the cities in which e-scooters operate is at the core of Micro-mobility for Europe’s objectives. Recent studies have shown that micro-mobility has the potential to deliver significant benefits in cities including efficient and cost-effective travel, reduced traffic congestion, decreased emissions, and a boost to local economies.
On April 27th2021, Micro-Mobility for Europe met with Pedro Homem de Gouveia, Senior Policy and Project Manager, Governance & Integration, Safety & Security at POLIS Network.
The meeting was an important occasion for the coalition to share views on how micro-mobility solutions can make a valuable contribution to develop innovative technologies and policies to promote sustainable mobility across cities. The main points of discussions focused on:
How to accelerate the shift towards sustainable and urban mobility which is key for the success of the industry and should be prioritized among all policy efforts.
Having a consolidated system thinking approach which looks at ways to positively transform urban mobility by allowing a proper integration of micro-mobility solutions into the existing local transport system and build capillarity to serve transit along corridors
The need to push for financial support from municipalities and the EU to develop and integrate a solid infrastructure system which is the way to make micro-mobility industry to smoothly flourish in cities.
The importance of pushing for a data share harmonization among cities, enabling local authorities to profit from data our industry generates which alleviate the challenges faced by their residents (congestion, pollution, road quality and safety, as well as better environmental protection).
Further Information:
POLIS is the leading network of European cities and regions working together to promote sustainable mobility through the deployment of innovative transport solutions. Their aim is to improve local transport through integrated strategies that address the economic, social, and environmental dimensions of transport.
Congestion, air and noise pollution are serious challenges affecting cities and urban environments, as well as the people living and working there. Micro-mobility solutions and e-scooters can help alleviate such pressures on urban transport networks, boost sustainable mobility in cities, and contribute to improved air quality.
On March 10th 2021, Micro-Mobility for Europe attended a parliamentary hearing organised by MEP Ismail Ertug (S&D, DE), rapporteur for the TRAN Committee own-initiative report on the Sustainable and Smart Mobility Strategy (SSMS).
This meeting was an important opportunity to position Micro-Mobility for Europe as a key player in the sustainable and smart mobility space, raising the contribution of the industry to cleaner, smarter, and more sustainable urban transport system. The coalition shared views on a range of topics which included:
How micro-mobility solutions and e-scooters can help alleviate pressure on urban transport networks and help cities redesignand rethinktheir usage of space by offering alternatives to car ownership and use.
The recognition of the need to develop a framework that ensures micro-mobility solutions flourish in cities and deliver on their potential for emission-free transportation.
The benefits provided by the data generated by operators and providers of micro-mobility solutions. These valuable data can help cities better understand traffic flows or provide useful insights into traffic bottlenecks and help future infrastructure planning. Best practices should be developed in the field of data collection, data sharing and data governance to further leverage the potential of these new data generated by micro-mobility solutions.
Concluding the hearing, MEP Ertug noted several recurrent issues and topics put forward by participants, including the need to pursue an emissions reduction agenda, the importance of infrastructure expansion for electric and hydrogen mobility through the revision of the Alternative Fuels Infrastructure Directive (AFID), the need to promote micro-mobility solutions and the growing importance of digital solutions within the transport sector.
Further information:
Sustainable and Smart Mobility Strategy
Published in December 2020, the Sustainable and Smart Mobility Strategy lays out the long-term vision for Europe’s mobility system and identifies policy tools and 82 actions to guide the European Commission in making all transport modes more sustainable, bolstering their resilience and inducing digitalisation.
European Parliament INI report
The European Parliament is currently preparing a non-legislative response to the SSMS. This response will outline the European Parliament’s perspective on the long-term decarbonisation of transport and give concrete feedback on the specific legislative actions outlined in the SSMS. The draft report from MEP Ertug is available here.
New micro-mobility coalition launches, creating one voice for providers of shared micro-mobility solutions to transform urban mobility in Europe
Brussels – 2 February 2021 – E-scooter operators have come together to form a new coalition, Micro-Mobility for Europe (MMfE), which launches officially today. Comprised of eight founding members1, the coalition aims to contribute to the development of a coherent policy framework in Europe that will ensure micro-mobility solutions flourish in European cities and support the rapid transition to zero-emission urban mobility.
At the forefront of the digital and transportation revolutions , members of MMfE work to address issues like congestion and the tailpipe emissions associated with urban travel, together with the cities in which they operate, to ultimately transform urban mobility. For Europe to meet its ambitious emissions targets, more will need to be done at a sustained pace. “Micro-mobility has revolutionised urban mobility and established itself as an essential alternative to personal car ownership and use ” said Catriona Meehan, Co-Chair of the coalition and representative of Wind. “The coalition is a key milestone in working together as one industry towards a healthier, more sustainable and less congested future for European cities”.
Members of MMfE operate in over 20 EU countries across more than 100 European cities. More and more local authorities are working to integrate micro-mobility into their transportation ecosystem. The data generated by micro-mobility providers helps cities to better understand, regulate, and plan for traffic flows, use of public infrastructure and space as well as necessary changes to improve road safety and mobility services in line with future mobility needs. “As the large majority of public space is dedicated to (car) infrastructure we need to rethink how public space in cities is used, and we look forward to contributing to this important discussion”, explained Alexander Jung, Co-Chair of Micro-Mobility for Europe and representative of Bird.
The launch of this coalition addresses a gap in the representation of the industry in the transport and mobility policy discussions, and will provide the views, expertise and experience of the shared micro- mobility industry. MMfE have identified urban mobility, data governance and circular economy as their top priorities to ensure that shared micro -mobility is an integral part of EU policy developments in the coming years. Following the publication of the EU’s Sustainable and Smart Mobility Strategy and given the changes in mobility the pandemic has triggered, Micro-Mobility for Europe is eager to engage with the Commission and EU policy makers to contribute to Europe’s recovery efforts as well as the green and digital transitions.
