Parallel Universe!

The Internal Market and Consumer Protection Committee (IMCO), chaired by Malcolm Harbour, MEP, met on Tuesday 22nd March 2011 in Brussels to discuss the proposed new regulations of two and three wheeled.

This “Public Hearing” steered admirably by the Chair aimed to consider the safety, environmental and economic issues relating to these proposals and various stakeholders, (some claiming to represent motorcyclists), were given the opportunity to speak.

At Right To Ride we have reported since January 2010 on these discussions which could change the world of motorcycling as we know it. We have given our opinions, reported on the issue and attempted to give space to others’ opinions.

However there seems to be a parallel universe that includes what the actual issues are, how we interpret these issues, how others interpret these issues and then how this interpretation is used to advance agendas, positions and even self interest.

Our agenda is simply to promote and protect motorcycling and all that it means as part of our way of life. Our position aims to protect the spirit and historic tradition of modifying motorcycles.

We report here what others are saying following the IMCO public hearing as well as our summary of this hearing.

ACEM – the Motorcycle Industry in Europe

We reported on ACEM’s latest statement from after the public hearing which in our view was calling on the EC to “Get Real” on the time scale for the implementation and ACEM’s revised position on the regulation proposals.

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Federation Of European Motorcyclists Associations (FEMA)

From the IMCO hearing, the Federation Of European Motorcyclists Associations (FEMA) have stated on their website that the FIA (Federation International de l’Automobile) agrees with FEMA on bike safety measures. Interestingly FEMA did not take part in public hearing, although discussions continued afterwards at the ACEM dinner debate in the Parliament building where MEPs and the Rapporteur in charge of the report in the IMCO committee Wim van de Camp brought up the issue of Repair and Maintenance Information (RMI) and gave FEMA the floor who claimed to speak on behalf of the riders in Europe.

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The recording of “the hearing” is still available to view on the European Parliament website – Click Here

However we have summarized the hearing below. Links to the documentation and presentations given at the public hearing can also be found below.

Parallel Universe – The Public Hearing

The rapporteur Wim van de Camp previously announced the fact that he is a motorcyclist, and he opened the hearing with his “state of play”.   He commenced by discussing ABS (Advanced Braking Systems) and when they should be introduced along with the timetable for the Euro emission standards, as well as the introduction of On Board Diagnostics (OBD) and so forth. He mentioned the incorporation of trial and enduro motorcycles within the legislation; Wim van de Camp commented on the safety concerns about AHO, “some bikers feel that this is a threat to their freedom.”  He also stated that “There is wider support for ABS than for AHO amongst bikers”.

With regards to the spare parts industry, Wim van de Camp said that “bikers want to be able to adapt their motorcycles, this needs to be discussed.  Market Surveillance hasn’t been discussed sufficiently and a strong package needs to be worked out”.


The hearing included input from “experts” starting with Mr Pascotto from FIA who declared that he was representing the “users”. The motorcycling community was also represented by a gentleman from KNMV, the Royal Dutch Motorcyclists Federation – (The rapporteur Wim van de Camp is a member of this federation).

Mr Pascotto (FIA) stated that ABS has a great potential in avoiding and influencing road accidents and used the example of trials in Germany and Italy. Mr Pascotti mentioned cost and suggested that mandating ABS may drive down cost, he also mentioned that the lack of information may be a reason why ABS is not more widely used.  He recommended that training is indispensable but the best performance is with ABS “as soon as possible”.

The representative from KNMV then spoke about ABS. He stated that his federation would recommend ABS although does not believe that it should be made mandatory, especially for trail and enduro motorcycles.  He noted that only 0.2% of accidents are due to technical issues, he also explained that although ABS is good, you need to understand how to use them.  He put emphasis on using hazard perception in training rather than relying on braking as a solution to emergency situations.


Bernd Lange MEP (motorcyclist) opened the questions from the MEPs.  He did not dispute the use of ABS, he queried the cost of ABS especially on smaller motorcycles – he said that competition in the sales of small motorcycles is high.  He asked if it would be possible to have different dates for the entering into force of ABS depending on the size of the motorcycles.

Other MEPs then commented, but this was mainly about issues that were irrelevant – e.g. Mr Mandez MEP, talked about visibility (conspicuity) of sidecars – which had nothing to do with the proposals. Another MEP seemed to think that mandatory ABS would drive down costs.

Advanced Braking Systems

However, the third MEP Mr Repo from Finland, asked to consider the freedom of customising motorcycles.  Malcolm Harbour, the chairman, then addressed the question that ABS would only apply above a certain size, particularly scooters – and suggested that an alternative form of CBS system should be available.  He mentioned that the dynamics and weight distribution of scooters are different from motorcycles.

Wim van de Camp then commented that there was agreement amongst bikers that, “we need to work on ABS and make it compulsory”.  However, he mentioned that the timetable needed to be considered and tightened.  With regards to including trail and enduros in the regulations, he suggested that they could be included in the regulations but without ABS.

(NB: What we have picked up from documents is that reference to trail and enduro bikes is apparently relating to “competition” machines and not as you may think, Yamahas XT Tenere or BMW, GS range or similar, which we would call dual purpose).

The KMNV replied that the most important thing about accidents is that 70 to 80% could be avoided if the behaviour of riders could be addressed.  He commented that in the Netherlands – riders only average around 3000 kilometres per year, he said “we are missing the safety training, if you instil safety behaviour in riders that will be reduce accidents”.  The FIA representative said that there needs to be more reliable data, with regards to cost. He said “we need to concentrate on the cost benefit analysis in terms of accidents and technology.  We know that ABS in cars that the cost reduces with use.  Users have to be put in the position to make the correct decision but this depends on the systems including training, but all systems must work in a consistent way”.


Environmental aspects were then discussed – the speakers Bertrand Olivier Decreux from the French environment agency (ADEME) then the representative Mr Bosteel from the Emission control by catalyst (representing catalyst manufacturers) AECC organisation, explained about emissions from various types of motorcycles, as well as the WMTC cycles and “real use measurements”.

The French speaker from ADEME stated that WMTC cycles were nearer to real world conditions and that on average Euro 3 motorcycles emit 6 and 10 times more pollutants that Euro 4 cars.  He stated that tampering with mopeds is very frequent in France and was a major cause of pollution.  Fuel consumption and emissions should be made clearer. Smaller engines have considerable variations in performance and are highly susceptible to tampering. Some carburettors are tuned by users which lead to bad results of emissions and fuel consumption.

The AECC representative explained that they had conducted examinations of motorcycles and technical specifications, some of the vehicles failed to meet Euro 3 emissions.  They tested European motorcycles comparing them to Indian motorcycles – four of the European bikes already meet Euro 4 standards and one within the Euro 6 standards (although they did not test for durability). The Indian motorcycle did not do well and went over the limits – therefore he suggested that durability needs to be included in the test cycle. Four stroke and two stroke mopeds were tested – all except the four stroke (which had a carburator) performed well and came within the required emission limits. Four of the five mopeds were within the required main emission stages.

Berdt Lange MEP asked whether it was necessary to have intermediary steps and put Euro 5 and 6 together to reduce the cost for manufacturers and asked whether there is a future for 2 stroke mopeds.

The AECC representative agreed that simplification would be better. He then stated “We showed that one four stroke failed but not the 2 stroke mopeds, although particulate emissions are higher with 2 stroke mopeds”.

Time Implementation

The next speaker Antonio Perlot from ACEM (the Motorcycle Industry in Europe) wanted to raise the issue of time frames and the challenges from the proposals and lead times and said that ACEM supports the main goals of the proposals. He stated that the requirements are a challenge for the industry but also member states that need to implement the regulations.

Mr Perlot said that higher costs are involved including technical, production and marketing points of view. Design research and development considerations are also present.  Mopeds and scooters make up the bigger part of the market.

With regards to lead times and calendars, Mr Perlot explained that the life cycle can be ten years and usually there are no changes for three years.  The best selling model is under 20,000 units per years, most under 5,000 units per year, some only 1,000 per year.  The average manufacturer can have 20 to 30 models, due to different licences leading to fragmentation of the sector.  He explained that planning took one year, then three years for developing, then four years with a minor change and further four years towards the end of life of the model.

Mr Perlot continued to point out the differences for new type approval and existing type approval, he said that OBD and ABS apply on all new vehicles which brings further complications.  There is a very short lead time partly due to delays.  Even so ACEM would not be able to meet the 2013 time frame.  ACEM would like to move the application by at least one year.  ACEM is already trying to compress the product development phase and having to compress further would be difficult.

Mr Perlot concluded that repair and maintenance does not consider the administrative issues and would be impossible to meet and ACEM requests to move forward to 2017 and 2020 in some cases.  The industry has suffered and has lost -25% of the market with no sight of recovery. This has put a lot of pressure on manufacturers and suppliers.

Mr Basset from the Automotive Aftermarket Distributors (FIGIEFA), explained that in terms of aftermarket, there are 37,000 points of sale and servicing and 100,000 employees in Europe.  He supported the introduction of OBD, repair information, spare parts and multi-brand tools.  He stated that the information is only available from the manufacturer but is needed by the spare parts manufacturers.  Therefore it is essential that all repairers have access to OBD information.  Vehicle safety and compliance must exist for the choice of consumers.  FIGIEFA would prefer introduction in 2013. Mr Basset said that the manufacturers already provide RM information access to repairers.  Mr Basset stated that independent repairers want to provide the right services and questioned the need to wait until 2016 or beyond.

Bernd Lange MEP stated that there are points to look at in greater detail, in the last round durability is an important issue and will be a big challenge in terms of efficiency and guaranteeing durability.  He stated “there needed to be clearer rules. We should reflect on whether Comitology should be given credence, there was need for limits on Comitology.  With regards to lead times, whether there is the potential for harmonisation but the key points need to be discussed”.

Ms Ruhle MEP, stated that technology is already there and there is a need to harmonise times then there was a request to defer the time frame which she did not agree with.

Questions and answers

Mr Repo MEP from Finland, referring to the last presentation, asked “what is the risk that the spare part manufacturing might be transferred to third countries and whether there is the possibility that third countries might take over spare parts”.  Malcolm Harbour replied that was not part of the discussion for these proposals.

Malcolm Harbour asked FIGIEFA whether they can guarantee that the repairers have the appropriate training.  He then asked Antonio Perlot from ACEM whether therefore manufacturers would provide information if the repairers has the required training.  He then asked “Do we need Euro 4 if motorcycles are already performing to Euro 5 and 6?”

Mr Basset from FIGIEFA stated that regarding becoming members of authorised networks and issues of choice.  One key element is not only repairers but also parts distributors and tool manufacturers and road side rescue services – which would not be part of the authorised network.  He said “How do we know they will use the RMI correctly and continued there is a responsibility on their behalf but includes training and this relies on the association and trade groups.  We have done so for the last 100 years and there is no reason why we should not continue”.

Antonio Perlot (ACEM) stated with regards to the contradiction between ACEME and ACEM.  The measurements were achieved without durability requirements, manufacturers would have to type approve at least 50% which is a serious technological challenge.  Do we need three stages?  What is important is due to the delay, but we still need to have the lead time.  Each stage requires 25% reduction in pollution.

Cost Of ABS

With regards to the cost of ABS, Mr Perlot replied that the consumer cost “under 100 euros” is not right. He said that just for the hardware it is 250 euros, then software and calibration of the system and due to the wide variety of models, this requires more fine tuning due to the wheel bases (thus driving up costs even further).  He then stated “Also the comment that ABS was not widely used was incorrect, the penetration on the market is now 50% with ABS, the bigger bikes with ABS and translates into 35% of sales so economies of scale have already done, but even so getting down to 100 euros is not realistic.

With regards to anti-tampering, Wim van de Camp asked the ACEME representative “you stated that tampering is a big problem in France. I would like clarity regarding anti-tampering measures”.

The ACEME representative stated that tampering in France is 50% in 2006, 2007, he said that there are many ways to modify mopeds.  Fuel injections mopeds are very difficult to tamper with.

European Commission

Philippe Jean from DG Enterprise responded to the presentations in the hearing.  Mr Jean stated that he had learnt a lot with regards to cost of ABS. He said “we reflected on that in the impact assessment and had used an estimate for an average of vehicles – 3.1 ratio between cost and benefit”.   With regards to safety and behaviour he said that what they are looking for is accident avoidance irrespective of the behaviour of the drivers.  His opinion on Emissions was “this is surprising and the levels are very high and we think the best way is to tackle the source of the problem.  Timetable needs to be discussed, for Comitology (Describes a process in which the Commission, when implementing EU law, has to consult special advisory committees made up of experts from the EU countries.) but we at the Commission have committed to a certain timetable”.

On That Bombshell

Wim van de Camp, thanked the stakeholders, and he was leaving shortly to attend a dinner held by ACEM four floors down in the European Parliament. He then stated that if a bomb landed now, it would destroy the whole motorcycle community.  He concluded by stating that they will put out a draft report and what should we leave to Comitology, Mr van de Camp suggested that a lot should be left to Comitology.


Consideration of draft report – 13-14 April 2011

Deadline for amendments – 4 May 2011

Consideration of amendments – 24-26 May 2011

Vote in IMCO – 15 June 2011

Plenary (tbc) – September 2011

The Plenary Sessions represent the culmination of the legislative work done in committees and in the political groups.

These sessions are where the Parliament formally sits to vote on EU legislation and adopt its position on political issues.

Documentation of the Meeting

Documentation of the meeting are available – Click Here – or download directly the available presentations:

Jean-Ludovic BASSET, Senior Advocacy Officer, Automotive Aftermarket Distributors (FIGIEFA) – pdf 938kb

Dirk BOSTEELS, Executive Director, Association for Emissions Control by Catalyst (AECC) – pdf 712kb

Bertrand-Olivier DUCREUX, Agence de l’Environnement et de la Maîtrise de l’Energie (ADEME), Service Transports et Mobilités, France (Not Available At Present)

Luca PASCOTTO, Director Mobility, Federation International de l’Automobile (FIA) – pdf 590kb

Antonio PERLOT, Public Affairs Manager, Association des Constructeurs Européens de Motocycles (ACEM) – pdf 394kb

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