The German Road Traffic Act (Straßenverkehrsgesetz - StVG) stipulates that all motor vehicles used on roads must be type-approved. However, there were no special technical regulations applicable to electric self-balancing scooter in Germany. Regulation (EU) no. 168/2013 of the European parliament and of the councilof 15 January 2013 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles, as well as Electric Power Mobility Ordinance (Mobilitätshilfenverordnung - MobHV), did not involve a seatless electric self-balancing scooter. Therefore, in the legal aspect, in Germany, electric self-balancing scooter were not allowed to be used on the public road.
The Federal Motor Transport Authority (Kraftfahrt-Bundesamt - KBA) plans to develop and implement Small Electric Vehicle Ordinance (Elektrokleinstfahrzeuge-Verordnung - eKFV) in 2019. eKFV incorporates the terms of the MobHV, adds provisions for electric balancing vehicles, and replaced MobHV after formal implementation. eKFV has detailed provisions for electric balance vehicles, including technical requirements, homologation requirements, compulsory insurance, vehicle registration and driver qualifications. The technical requirements relate to the power, speed, weight, brakes, handrails, lights and other parameters and components.
German eKFV was officially released and implemented on June 15, 2019. Persons using electric balance vehicles without type approval on the road will face a fine of 70 euros. Manufacturers of electric balance vehicles must guarantee electric balance vehicles sold to Germany type approved, an ABE type approval certificate is obtained to ensure that consumers can register and use the vehicle legally.
ATIC provides ABE type approval services according to eKFV including information document preparation, initial assessment follow up, as well as product testing.
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Information Sheet on Initial Assessment (MAB) shall be submitted by the applicant, initial assessment will be done by KBA auditor or external KBA partners, CoP report will be issued after the audit.
ATIC will support the applicant prepare drawings, information documents, business license and its translation, QMS documents, CoP control plan, etc.
ATIC will support the applicant to make a testing plan and conduct pre-tests if needed, send testing samples to designated testing labs in Germany and follow up testing.
After initial assessment and testing pass, all documents including MAB forms, CoP report, information folder, testing report will be submitted to KBA, KBA will review all the documents and issue the type approval certificate if all results satisfied. A typical lead-time for the review process is 4 to 6 weeks.
Other Key Points
- Product information document (including drawings) - Information Sheet on Initial Assessment (MAB) - Business license and its translation - QMS certificate, procedures, forms
- In order for the KBA to be able to issue manufacture with type-approvals an initial assessment must first be carried out. An initial assessment means that the manufacture company must verify who is behind it, how its production is carried out in conformance with the provisions of the approval and how it will fulfil its obligations as a future type-approval holder. For this purpose various pre-printed forms are provided that must be completed and submitted to the KBA. There may also be an on-site inspection in the facilities of the future type-approval holder. Such an audit is intended to provide the manufacture with a practical opportunity to demonstrate how the manufacture are going to fulfill their obligations.
CoP Report - The report on procedures guaranteeing conformity of production is a key part of the initial assessment as well as for the periodic checks of the approval holders. For the initial assessment a CoP-report must be issued for the on site inspection as well as for the verification and certification process.
- The type-approval holder is the person or body who is responsible for all aspects of the type- approval process and for ensuring conformity of production. Manufacturers, producers, authorised agents or exclusive distributors acting for the producer may become type-approval holders. Appointed representatives, makers or suppliers cannot become type-approval holders.
- The terms "authorised representative" or "exclusive distributor" are only used in association with type-approvals according to the german national vehicle safety standard (StVZO) (Allgemeine Betriebserlaubnisse - ABE and Allgemeine Bauartgenehmigungen - ABG).
- Authorised representatives or exclusive distributors may be entrusted by producers to submit type-approval applications. They must demonstrate to the KBA that they are responsible for matters pertaining to the type-approval procedure and for conformity of production and have made all the necessary arrangements for this.
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