It would appear that our correspondence with the European Commission has resolved certain issues surrounding motorcycles and sidecars (L4e vehicles) regarding their inclusion within proposals of a new framework directive for motorcycles.
The proposals we have previously outlined include new rules for emissions, ABS (Advanced Braking Systems), AHO (Automatic Headlights On), mandatory OBD (On Board Diagnostics), anti-tampering measures and so forth.
What we had found within these proposed limits for motorcycles was that there was a reduction of sidecar production (identified as L4e vehicles – motorcycle and sidecar – whole assembled vehicle) from 200 to 100 per annum per company, with stand alone sidecars defined as a Separate Technical Unit (STU) and also proposals for Type Approval.
Right To Ride wrote to the European Commission regarding these issues:
“While I understand that it is a necessary requirement to have type approval even for STUs, there are a wide variety of types of sidecars (STUs) and the implications of limiting production of these STUs (sidecars) will have devastating effects on the sidecar industry directly and of course indirectly it would have even wider implications. For example, if the production of sidecar ambulances for poor countries is halved because of the limitation of small series manufacturers, this would reduce the possibility of saving lives.”
“Would it be possible to re-visit the limitations for sidecar manufacturers – in consideration of the fact that they are not a vehicle and as there are an enormous variety of sidecars and their uses, perhaps this specific STU could be excluded?”
“I note that in the TRL study (L Category Vehicles: Powertrain tampering prevention and Durability) for example, L4e vehicles are excluded, so it appears that by implication these vehicles are not considered a problem (in fact in terms of safety the frequency of motorcycle sidecar casualties are rare). I refer to the comment ‘Harmless’ modifications – e.g. those with no adverse effects on safety or the environment will not fall under the scope of possible anti-tampering measures’ on slide 4 of the TRL presentation.”
We would like to thank the European Commission for their quick response to our queries which are as follows.
Article 40 and Annex III on small series only refer to complete assembled units (whole assembled vehicles) and are therefore not applicable for manufacturers who produce separate technical units, like sidecars only.
It is our understanding of this statement that Separate Technical Units (sidecars only) are not included in the reduction from 200 to 100 units per annum.
The sidecar manufacturer can produce as many separate technical units as they can place on the market, providing these are safe.
It is our understanding of this statement that there is no change in the way in which sidecars are produced at the moment, providing these are safe. Also the provision of “safe” is entirely up to member states to determine, i.e. how they define the safety of the sidecar that is being produced and placed on the market.
However, the customers that assemble the motorcycle and sidecar to one L4e vehicle have to ensure that whole vehicle type approval requirements are fulfilled, either as individually approved vehicle, as small series vehicle that fulfil alternative approval requirements or as mass produced vehicle complying with all requirements of type approval legislation
It is our understanding of this statement that whole type vehicle type approval refers to a whole assembled vehicle L4e that has been produced to be placed on the market, prior to registration in a member state.
In other words, a motorcycle that has been placed on the market and registered with whole type vehicle type approval and then is fitted retrospectively with a sidecar does not require to be whole type vehicle type approved.
The fitting of a sidecar to a motorcycle and any legal change of use is down to the legislation required in the member state.
It is not in any way the Commission’s intention to restrict business of small and medium companies producing side-cars or the assembly of motorcycles with sidecar.
In the contrary, we have included a number of mitigating measures, especially in terms of environmental requirements for manufacturers of L4e vehicles that will mitigate possible economic adverse effects of application of the new legal framework to type-approve vehicles.
We welcome the intention of the European commission in these statements but wait for the published environmental requirements for manufacturers of L4e vehicles that have been stated that will mitigate possible economic adverse effects.
In conclusion, cutting through the technical blah blah, it would appear that the status quo remains for riders who wish to fit a sidecar to their motorcycle and for manufactures that produce sidecars either for sale or for fitting to their customer’s pre registered motorcycle!
We will continue to follow the framework regulations through its progress in Europe and report any changes or updates that effect motorcyclists in that progress.
Download the full Regulation – pdf – Click Here
Motopodd Business Case – pdf – Click Here
Our thanks to Rod Young of Motopodd Ltd for his assistance on this issue – www.motopodd.com
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