To: Mr B. Madlener, Minister, and Mr C. Jansen, Secretary of State, of Infrastructure and Water Management, Government of the Netherlands
Subject: Request for the Withdrawal of the Proposed Light Electric Vehicle (LEV) Framework
We, the undersigned citizens, organisations, and stakeholders, hereby urge you to withdraw the current LEV Framework. The approach taken conflicts with established EU legislation, undermines European Single Market principles, disregards European technical standards, and has failed to engage key industry experts and stakeholders.
Background:
In the past years, the Ministry of Infrastructure and Water Management has prepared a comprehensive regulatory technical framework governing light electric vehicles (LEVs), including electric cargocycles, e-scooters, self-balancing vehicles, and other emerging forms of personal electric mobility. While we fully acknowledge the importance of road safety, the current LEV Framework plans, as they stand, will result in undermining innovation and the offer and supply of sustainable transport options.
1. Contradiction with EU Legislation:
The technical requirements proposed in the Dutch LEV framework are largely derived from the L-category homologation established by Regulation (EU) No. 168/2013. However, the vehicles covered by the LEV framework are explicitly excluded from that Regulation under Article 2.2, as these L-category rules are not suitable for them. By indirectly imposing L-category requirements on vehicles that have been expressly excluded by the EU, the Netherlands is acting counter to European law. This creates an unlawful barrier to market entry for both Dutch and foreign manufacturers, undermining the principles of the EU Single Market.
2. Ignoring Harmonised EU Legislation and Standards:
Throughout the EU, vehicles excluded from Regulation 168/2013 are instead regulated by the Machinery Directive/Regulation, the Electromagnetic Compatibility (EMC) Directive, the Restriction of Hazardous Substances (RoHS) Directive, and the Battery Regulation. Vehicles that fail to meet these safety standards can already be easily removed from the market.
The Netherlands currently applies this approach to illegal so-called "fat bikes", which should comply with the rules for all electric bicycles with pedal assistance up to 25 km/h and 250W, excluded from Regulation 168/2013. It is inconsistent to apply a sensible EU-aligned approach in these cases, yet ignore it for other LEVs—such as electric scooters, self-balancing vehicles with or without steering, and electric cargocycles.
Moreover, the sector has worked extensively to develop European standards for these vehicles. For example:
o EN 17128: Covering electric scooters and self-balancing vehicles, currently being revised.
o EN 17860 (7-part series): Covering electric cargo bikes, recently completed by CEN TC333-WG9 after four years of intensive work by dozens of European experts. This effort was led by the Dutch standardization institute NEN, with a Dutch convenor guiding the working group!
It is incomprehensible and disrespectful that this extensive, expert-driven work has been systematically ignored in the development of the Dutch LEV framework.
3. Evidence from Other EU Member States:
Numerous EU countries, including neighbouring Belgium, allow these LEVs on public roads without imposing additional technical requirements. Instead, they rely on the harmonised EU directives (Machinery, EMC, RoHS) and focus their national rules solely on conditions of use, not on technical conditions. These countries report no structural safety issues with these LEVs.
The Netherlands itself has successfully taken this approach for millions of electric bicycles with pedal assistance up to 25 km/h and 250W, also called EPACs, which remain safe and widely adopted without additional Dutch technical requirements. The same EU-aligned, pragmatic approach should also be applied to electric scooters, self-balancing vehicles with and without steering, and electric cargo bikes.
4. Recommendations of the Expert Group on Urban Mobility:
The following recent recommendation of the Commission Expert Group on Urban Mobility has been officially been endorsed by the Commission: "The Commission must develop harmonized technical legislation and mandate related standards, specifically for light electric vehicles in close consultation with the light electric vehicle sector.” A strictly Dutch initiative that imposes separate technical requirements for just a few categories of LEVs contradicts this recommendation. Instead of unilateral action, the Netherlands should collaborate with the European Commission and the LEV sector to create truly harmonised, future-proof European legislation.
5. Lack of Stakeholder Engagement:
In formulating the current LEV framework, essential stakeholders—industry experts, manufacturers, and relevant companies—have been systematically ignored. Effective, sustainable policymaking requires open dialogue and collaboration with those who understand the technology and the market best. We ask that you rectify this oversight and engage in meaningful consultations with essential stakeholders in the field of electric cargocycles, e-scooters and self-balancing vehicles. We herewith endorse LEVA-EU, the initiator of this petition, as a valid and essential stakeholder.
Our Request
1. Immediate Withdrawal of the Current LEV Framework Proposal:
Refrain from enforcing these national technical rules that contradict EU legislation, undermine harmonisation and the single market, and lack proper stakeholder input.
2. Proper Application of Existing EU Directives and Standards:
Align Dutch policy with the Machinery Directive/Regulation, EMC, RoHS, and Battery Regulation, and the established European standards (EN 17128 and EN 17860 series). These measures already provide clear, harmonised safety requirements and allow for the removal of unsafe vehicles from the market.
3. Close Collaboration with the EU and the LEV Sector:
Work with the European Commission and stakeholders to develop consistent, harmonised technical legislation for all LEVs, as recommended by the Expert Group on Urban Mobility. Ensure that the Netherlands, as a leader in innovation and standardisation, takes a constructive, cooperative role in shaping EU policy.
4. Inclusive Stakeholder Consultation:
Immediately begin an in-depth consultation process with sector representatives and involved companies. Their expertise and perspectives will ensure that future policy is both technically sound and economically feasible.
Conclusion
We respectfully call on the Dutch Minister and the Secretary of State of Infrastructure and Water Management to withdraw the current LEV framework proposal, engage with experts, adhere to EU law and relevant standards, and pursue a collaborative path toward consistent, innovation-friendly, and sustainable LEV regulation. By doing so, the Netherlands can maintain its position as a forward-looking, responsible leader in sustainable mobility.