Our conclusion on the cycling industry’s initiative
No one knows exactly how many tuning kits are currently being sold in Germany. One estimate put sales for 2023 at 315,000 kits. This is not a recent market statistic, but it is a warning sign. After all, tuning does not only put individuals at risk. It could also damage confidence in pedelecs and intensify the debate over their status as bicycles. It is right that the industry wants to make tampering more technically difficult and to impose stricter controls on tuning kits and non-compliant e-bikes. But one question springs to mind: why haven’t bicycle and drive manufacturers protected their systems more consistently long ago?
A new approach to an old problem
Through a voluntary commitment, a position paper and a manifesto, the European industry association European Cycling Industries (ECI) aims to take action against e-bike tuning and non-compliant vehicles. The German associations ZIV and Zukunft Fahrrad have also joined the initiative. For Germany, they have announced their own version of the initiative and a joint package of measures against illegal e-bikes.
The documents have two distinct aims. On the one hand, they are intended to make standard pedelecs more difficult to tamper with. On the other hand, the ECI wishes to prevent the sale of vehicles that do not meet the requirements for a pedelec even in their factory-supplied condition. The association sees a particular loophole in this regard in online retail: Products are sometimes shipped directly from suppliers outside the EU to European buyers, whilst it is difficult to identify a single party that is clearly responsible. Post-purchase modification and an e-bike that is non-compliant from the outset are therefore not the same problem, even if their consequences may overlap.
The 25 km/h speed limit is often misunderstood
In everyday conversation, people usually refer to an ‘e-bike’, but legally speaking, the term ‘pedelec’ is the key one here: the motor only assists when pedalling, and this assistance cuts out at 25 km/h. The maximum continuous rated power is 250 watts. This does not mean that a pedelec is not allowed to travel faster than 25 km/h in total. If you pedal vigorously or are coasting downhill, you may exceed this speed. The crucial point is that the motor then ceases to provide assistance.
Tuning comes into play precisely at this threshold. If motor assistance is enabled beyond 25 km/h, the vehicle no longer meets the criteria for being treated as a bicycle. It may then be legally classified as a motor vehicle. However, this does not automatically mean that a tuned pedelec becomes a properly registered S-pedelec. For use on public roads, an operating licence, a suitable driving licence and motor vehicle liability insurance, amongst other things, may be required.
A module, an app or a hidden menu
How difficult is vehicle tuning in practice? There is no single answer that applies equally to all powertrain systems. Some modifications require interference with the wiring or electronics. For others, a retrofitted module, software unlocking or an app may suffice. The ECI position paper therefore does not merely describe traditional tuning chips. It also identifies modifiable region settings, unprotected software, weak access codes and manipulable speed signals as potential vulnerabilities, and sets out measures manufacturers can take to better secure their systems.
Tuning can be very expensive
The obvious risk associated with e-bikes is the risk of an accident. However, the available sources do not provide any reliable figures on the extent to which modifications increase the overall risk of an accident. The ZIV points out that riders and their equipment are subjected to greater stresses than those intended for normal use. This mainly concerns the brakes, fork, handlebars and frame, which are not necessarily designed to withstand a permanently higher level of stress. It goes without saying that this aspect carries greater weight for some categories of pedelecs than for others.
In addition, there are legal consequences. Anyone driving a vehicle that has been modified in this way on public roads without meeting the necessary requirements risks a fine. If the required driving licence or compulsory insurance is lacking, criminal offences may also apply. Private liability insurance is generally no substitute for the compulsory motor insurance required for a vehicle classified in law as a motor vehicle. If other people are injured or third-party property is damaged in an accident, this can have significant legal and financial consequences for the owner of a modified pedelec. Repairs and claims against the manufacturer or seller may also become contentious following any unauthorised modifications.
315,000 tuning kits sold? There’s a limit to that figure
It is difficult to put a reliable figure on how many tuning kits are sold in Germany each year. There are no official sales statistics. The expert Ernst Brust estimated that around 265,000 kits would be sold in 2022 and around 315,000 in 2023. His projection is based, amongst other things, on data from tuning companies and his own demand analyses. It therefore provides an indication of the likely scale of the market, but does not constitute a comprehensive market survey. No current sales figures for 2026 can be derived from this.
Similarly, the sale of a kit does not necessarily mean there is an additional modified bike on the road. This figure does not capture whether, when or on which vehicle it was fitted. It would therefore be misleading to compare the sales figures directly with the annual sales of new pedelecs and to deduce the proportion of modified bikes from this. Precisely because such data is lacking, the ECI is calling for a European-wide register of non-compliant vehicles, tuning products and their potential impact on road safety.
What manufacturers promise – and what they don’t
In their voluntary commitment, the ECI and its members declare their opposition to any tampering designed to increase performance or acceleration. They aim to comply with anti-tampering requirements, further develop drive systems, keep retailers and customers informed, and assist the authorities in identifying tampered e-bikes. The document provides for an annual review by the ECI of the measures taken.
There is a significant conflict of objectives inherent in the technology: on the one hand, the aim is to safeguard the systems against unauthorised interference; on the other, there is a need to ensure that necessary maintenance, repairs and updates to the bicycle are not unnecessarily blocked. The position paper therefore expressly states that protective measures should remain compatible with legitimate diagnostics, maintenance, repairs and independent technical inspections. How well this works in practice will be a key criterion for owners and workshops alike.
Calls for an EU-wide ban on the sale of tuning kits
However, the manifesto goes far beyond the manufacturers’ voluntary commitments. Firstly, the ECI is calling for an EU-wide ban on the sale of tuning kits, citing France as a model. Secondly, it wants better shared data on non-compliant e-bikes and their potential consequences. Thirdly, it calls for more uniform market surveillance, including tougher action against problematic listings on online marketplaces. Fourthly, the police and other relevant authorities should be trained and better equipped technically so that they can identify modified or non-compliant vehicles.
There is also an economic argument behind these demands. Manufacturers and importers who test, document and market vehicles in accordance with the regulations incur corresponding costs. If other suppliers are able to circumvent these requirements, the ECI regards this as a competitive disadvantage. However, the published documents do not provide comprehensive European sales or accident statistics to demonstrate the true extent of the problem with e-bikes.
The cycling industry’s initiative thus highlights a genuine area of tension: technical safeguards can make tuning more difficult, but do not, on their own, solve the problem of dubious online offers. Stricter controls may help, but they require trained authorities and reliable data. Whether these demands will ultimately result in new regulations, and whether the voluntary commitment will lead to e-bikes that are demonstrably better protected, remains to be seen.
Josh Welz
Editor-in-Chief