Electric bikes imported or manufactured for the US market are subject to various standards, labeling, and testing requirements. These are primarily meant to limit various risks that concern mechanical safety, battery safety, and other areas.
In this guide, we cover 16 CFR Part 1512, 47 CFR Part 15, and other compliance requirements applicable both to the e-bike itself and its battery.
Content Overview
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16 CFR Part 1512 – Requirements for Bicycles
16 CFR Part 1512 sets requirements for bicycles, including bicycles that have an electrical motor. Specifically, it covers vehicles that:
a. Have two or three wheels
b. Have functional pedals
c. Have an electric motor of a maximum of 750 Watts (1 horsepower)
d. Have a maximum speed of 20 miles per hour or less, when operated on a level and paved surface by a person weighing 170 pounds
Your product should comply with the requirements regarding:
- Braking system
- Steering system
- Pedals
- Drive chain
- Protective guards
- Tires
- Wheels
- Wheel hubs
- Front fork
- Fork and frame assembly
- Seat
- Reflectors
- Testing
- Labeling
- User instructions
Safety requirements
16 CFR Part 1512 has several safety and mechanical requirements regarding:
a. Assembly – Consumers should be able to follow user instructions to assemble the bicycle easily.
b. Sharp edges – The assembled e-bike should not have any sharp parts that might be exposed to the hands or legs.
c. Integrity – Major parts of the bike such as the frame, wheels, or brake system components should not fracture as a result of testing.
d. Attachment hardware – Bolts, nuts, and screws used in attaching or securing various e-bike hardware should not come loose or fracture.
Labeling requirements
Bicycles subject to 16 CFR Part 1512 must carry a permanently affixed label on the bicycle’s frame that identifies the manufacturer and the month and year of manufacture.
Testing procedures
16 CFR Part 1512.4 identifies four tests that should be carried out:
1. The handbrake loading and performance test – which includes the loading, rocking, and performance test procedures
2. The foot brake and performance test – which includes the force and performance test procedures
3. The road test
4. The sidewalk bicycle proof test
General Certificate of Conformity (GCC)
Importers and manufacturers of products that fall under the scope of 16 CFR Part 1512 are required to issue a General Certificate of Conformity (GCC).
The general certificate of conformity provides information about the product and manufacturer and guarantees that the product complies with applicable safety standards.
47 CFR Part 15 – Radio Frequency Devices
47 CFR Part 15 sets requirements for electrical and electronic devices that emit radiofrequency energy and can interfere with devices operating in the 9 kHz – 3000 GHz frequency range. This would also include e-bikes, as many of their components are electronics.
Generally speaking, most e-bike components would be unintentional radiators. However, some components may be classified as intentional radiators. This would include, for example, GPS-enabled devices and Bluetooth enabled devices.
Requirements for unintentional radiators
Unintentional radiators are devices that send radio frequency signals inside the product via connective wiring to equipment associated with the device.
Here are some examples of unintentional radiators that do not intentionally emit radiation and are relevant to e-bikes:
- Battery chargers
- E-bike lights
Importers or manufacturers of unintentional radiators must:
- Ensure their product undergoes the Supplier’s Declaration of Conformity (SDoC) authorization procedure
- Provide an SDoC Compliance Information Statement
- Provide a product identification label
- Ensure their product undergoes lab testing
Recommended article: FCC Unintentional Radiators: A Practical Guide
Requirements for intentional radiators
Intentional radiators are devices designed to purposefully generate and discharge radio frequency energy via induction or radiation.
E-bikes may contain components that are intentional radiators, such as:
- Bluetooth enabled devices
- WiFi-enabled devices
- GPS devices
Importers or manufacturers of intentional radiators must:
- Ensure their product is authorized under the Certification procedure
- Provide a compliance statement
- Provide an FCC ID
- Have their product lab tested by an accredited test lab that is FCC-recognized
Recommended article: FCC Intentional Radiators: A Practical Guide
10 CFR Part 430 – Energy Conservation Program for Consumer Products
10 CFR Part 430 contains design requirements and performance standards for consumer products designed to use energy. This also includes parts that can be found on e-bikes, such as battery chargers and lighting products. Specifically:
a. Appendix BB to Subpart B contains test methods that concern the energy consumption of several types of lighting products, including LED lamps.
b. Appendix Y and Y1 to Subpart B establish uniform test methods that measure the energy consumption of battery chargers.
Finally, 10 CFR Part 430 also incorporates by reference and thus requires adherence to test standards such as:
a. IES LM-84- Approved Method: Measuring Luminous Flux and Color Maintenance of LED Lamps, Light Engines, and Luminaires
b. IEC 62040-3 – Uninterruptible power systems (UPS)—Part 3: Method of specifying the performance and test requirements, which concerns battery chargers
10 CFR Part 429 – Certification, Compliance, and Enforcement for Consumer Products and Commercial and Industrial Equipment
10 CFR Part 429 sets certification procedures and compliance requirements for consumer products covered by 10 CFR Part 430, such as battery chargers and lighting products.
Importers and manufacturers must submit to the Department of Energy (DoE) certification reports containing a compliance statement and the following information for each model:
- Product or equipment type
- Product or equipment class
- Manufacturer’s name and address
- Private labeler’s name and address (if applicable)
- Brand name
- Basic model number, and manufacturer’s individual model numbers
- Submission information (e.g. for a new model)
- Test sample size
- The certifying party’s US CBP-assigned importer identification number
- Whether the certification is based on any waiver of test procedures, and dates of those waivers
- Whether the certification is based on an exception relief from a relevant energy conservation standard, and the date on which the DOE has issued the relief
- Product-specific information listed in 10 CFR Parts 429.14 through 10 CFR Part 429.63
Hazardous Materials Regulations (HMR)
The Hazardous Materials Regulations establish requirements for transporting dangerous items, including lithium batteries, which are usually included with e-bikes.
The Hazardous Materials Regulations require you to:
- Ensure lithium metal batteries adhere to the packaging requirements and quantity limitations or bans in the Hazardous Materials table
- Have your product tested
- Provide a UN 38.3 test summary
- Properly label your product
Documentation requirements
You must provide:
- A UN 38.3 test summary
- Shipping papers
- Shipper’s certification
Labeling requirements
According to Subpart D of 49 CFR Part 172, markings must generally be:
- Resistant, in English, and affixed or printed onto the package’s surface or on a label, sign, or tag
- Displayed on a background that has contrasting colors
- Not covered by any attachments or labels
- Situated away from other markings
The Hazardous Materials Table in 49 CFR Part 172 specifies special provisions for lithium batteries contained in equipment. You can find those provisions in 49 CFR Part 102.
Additional labeling requirements for lithium batteries can be found in 49 CFR Part 173.185.
UL Standards
UL standards are generally voluntary unless they are incorporated by reference by a regulation. However, you should test your products against their requirements to help ensure that your products are safe for use. This is especially true for products such as e-bikes, which can pose a great risk to the users due to their speed and the fact that they include a lithium battery.
Note that you may face recalls if your products are unsafe, and marketplaces such as Amazon may not allow you to list your product if you cannot prove its compliance with relevant UL standards.
Further, the CPSC has a list of recommended battery standards, which also include UL standards.
Below we list several examples of UL standards that may be relevant for e-bikes, personal e-mobility devices, and the lithium batteries that these products might incorporate.
UL 2849 – Electrical Systems for e-Bikes
This standard applies to the electrical system of Electrically Power Assisted Cycle (EPAC – pedal assist) and non-pedal assist e-bikes powered by a lithium-based and rechargeable battery.
The standard’s page notes that these systems contain at least the following components:
Note that this standard does not cover the mechanical structure of e-bikes.
UL 2272 – Electrical Systems for Personal E-Mobility Devices
This standard sets requirements that apply to the personal e-mobility devices’ and electric-powered scooters’ electrical drive train system, which includes:
- The battery system
- Circuitry
- Electrical components
The standard is meant to be used to assess the safety of the following for hazards stemming from energy and electrical shocks:
- Electrical drive train system
- Battery and charger combination
UL Standards for Lithium Batteries
E-bikes may contain, and run on, lithium batteries. As such, UL standards for lithium batteries may be relevant to e-bikes.
Here are some examples of relevant UL standards:
a. UL 1642 – Lithium Batteries
b. UL 60086-4 – Standard For Safety For Primary Batteries – Part 4: Safety Of Lithium Batteries
c. UL 62133-2 – Secondary Cells and Batteries Containing Alkaline or Other Non-Acid Electrolytes – Safety Requirements for Portable Sealed Secondary Cells, and for Batteries Made from Them, for Use in Portable Applications – Part 2: Lithium Systems
ASTM Consumer Safety Specifications
ASTM standards are generally voluntary, but you can still use them to ensure your products are safe for consumer usage. We could not find any ASTM standards that cover e-bikes. However, we found two examples of ASTM Consumer Safety Specifications relevant to e-bikes::
a. ASTM WK88946 – New Specification for Electric Powered Balance Bike
b. ASTM F2641-23 – Standard Consumer Safety Specification for Recreational Powered Scooters and Pocket Bikes
RoHS
Various states in the United States have RoHS laws, which generally restrict the usage or presence of heavy metals in electronic devices. This would apply to e-bikes as their electronic devices (e.g. e-bike displays) and electrical wires may contain heavy metals.
California’s RoHS law, for instance, covers electronic devices such as video display devices with screen sizes exceeding four inches. The law restricts the following heavy metals:
- Lead – 0.1%
- Mercury – 0.1%
- Hexavalent chromium – 0.1%
- Cadmium – 0.01%
E-Bike State Regulations
Many states in the US have implemented specific regulations concerning e-bikes that include age restrictions, e-bike classification, operating licenses, and registration requirements.
Here we list several examples of US state-level e-bike regulations:
a. California – AB-1096 Vehicles: electric bicycles.
b. New York – Vehicle & Traffic (VAT) Chapter 71, Title 7, Article 34, Section 1238
c. Oregon – ORS 807.020 – Exemptions from requirement to have Oregon license or permit
d. Arizona – Arizona Revised Statutes 28-819. Electric bicycles; electric standup scooters
e. Georgia – Official Code of Georgia Annotated Section 40-6-300
f. Idaho – Title 49, Chapter 1, Section 49-106
Lab Testing
You often need to have your product lab tested to ensure safety and to prove compliance with various regulations and requirements. This could include electrical safety testing, mechanical safety testing, or testing to confirm that your products do not contain restricted substances above the allowed limit.
Here is a table that lists some examples of testing that is necessary for the regulations mentioned earlier in this article.
Regulation | Lab testing |
16 CFR Part 1512 | Bicycles, which include some types of e-bikes, should undergo testing such as the following:
|
FCC Part 15 | FCC’s 47 CFR Part 15 regulates both unintentional radiators (e.g. lighting products) and intentional radiators (e.g. GPS devices). Here are two examples of incorporated testing standards:
a. ANSI C63.4-2014 (for unintentional radiators) b. ANSI C63.10-2020 – (for intentional radiators) |
10 CFR Part 430 | 10 CFR Part 430 covers e-bike components such as battery chargers and lighting products and requires the product to undergo testing to standards that are incorporated by reference. Here are two examples of incorporated testing standards:
a. IEC 62040-3 b. ANSI/IES LM-79-19 |
Hazardous Materials Regulations | The Hazardous Materials Regulations set requirements for transporting dangerous products such as lithium batteries, which are contained within e-bikes.
The regulations require you to provide a UN 38.3 test summary regarding your lithium batteries. This means you must ensure your batteries undergo UN 38.3 testing. |
ROHS | You should have your product tested to ensure it does not contain any restricted substances above the permitted levels (e.g. heavy metals). |
E-bike testing companies
Here are some examples of companies that offer e-bike testing services:
- Intertek
- UL Solutions
- TÜV SÜD
- SGS
Additional Requirements
Regulation | Description |
CPSIA | The Consumer Product Safety Improvement Act (CPSIA) covers all children’s products, which includes electric bicycles for children |
California Proposition 65 | E-bike components may contain substances that are restricted under California Proposition 65. For instance, plastic components may contain phthalates. Additionally, electrical wires may contain lead. |
Country of origin | A country of origin marking is required for all consumer products in the US unless an exception applies. Thus, this regulation also covers e-bikes. |
Amazon requirements | Amazon sets requirements that cover e-mobility devices, including e-bikes. For example, before you start selling e-bikes on Amazon, you should ensure compliance with:
You should also include a model number, and manufacturer name, and submit:
|
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I understand the speed limit like it must under 20 miles per hour.But does US has specific rules
to forbid the possibility of tempering? If no rules that means I can make my 20 miles(shipped out) bike exceed 30miles.
While there is useful information here, there are quite a few inaccuracies and omissions, and you would be a fool to think this is all you need to do to legally import and sell ebikes in the US.
CPSC regulations are part of the Code of Federal Regulations, and are not at all optional. If you do not comply with them, your product will be recalled from the market, you will be fined, and if anyone got hurt while using your product, you will be sued out of existence.
The electrical safety aspects are not directly required through federal regulation, but they are generally referenced and required through the National Electric Code. The CPSC also expects that you applied them. There are end product (ebike) standards, as well as component standards (wireless, batteries, chargers, etc.) which must be complied with, and products are required to be evaluated by a OSHA approved NRTL lab (UL, ETL, etc.). Again, if these were not applied, your product will be recalled from the market, you will be fined, and if anyone got hurt while using your product, you will be sued out of existence.
The FCC guidance is also over simplified. If the ebike is not fitted with any wireless capability (Bluetooth, GPS, ANT+, etc.), then yes you only need to consider the EMC requirements and provide an SDoC. If you do have wireless capability, and many ebikes now do, even if it is just for servicers to flash firmware, it must be tested and certified by the FCC, ISED in Canada, and just about every other market in world requires wireless certification if you sell there. There are specific labelling requirements and user manual requirements. FCC violations are serious business, and require 3rd party testing and certification.
There are state level labeling requirements not addressed here. There are battery charger efficiency requirements that often apply …. and on, and on.
Ebikes are complex products, and the compliance requirements are many. The US is actually one of the lesser regulated markets, so Europe, Japan, Korea, Australia, Singapore, are all twice as complex in their requirements. You need to hire a professional consultant for this work, or you are putting your product/business at risk in the best cases, and risking jail time in the worst cases.
Hello JJ,
Thank you for writing this. This is one of our earlier articles and we will need to update this guide.
Unfortunately, the CPSC guidelines are just that, guidelines. The federal agency does not have any enforcement powers (at this time). This is the reason so many importers avoid any real penalties when they bring in these poorly produced products, often only claiming they have the proper certifications but are almost never called to provide legal copies of these documents during the import/customs process. A common issue with the damage caused by Lithium powered devices is not due to the battery cells themselves but to the poorly constructed charging devices. Chargers specifically produced for Li cells and packs often require intelligent communication between the pack and the charger to determine the state of charge and the volume of energy being pushed through. Few realize that California has its own charger standard and few if any of the low-cost chargers bundled with these bikes meet that requirement.
How about this requirement from Amazon
https://sellercentral.amazon.com/gp/help/help.html?itemID=RGJUZP9EXNBSU46