Machinery Directive 2006/42/EC

When developing mountain bikes and E-MTBs, officially known as EPACs (Electrically Power Assisted Cycles), bike engineers have to observe a wide range of standards and legal requirements. What the Machinery Directive 2006/42/EC is all about and how it affects the production of ROTWILD bikes is explained in this article.

Explanation of terms

The Machinery Directive of the European Parliament regulates a uniform level of protection for accident prevention for machines and partly completed machines sold within the EU. Since e-bikes (EPACs) also fall under "machinery" according to this directive, all manufacturers who want to sell products in the EU must comply with the directive's requirements.

The Machinery Directive as a uniform regulation within the EU pursues two goals: Firstly, it ensures the free movement of goods within the European Union. Secondly, a uniformly high level of safety applies to all products covered by the Machinery Directive, which ultimately also serves to protect health.

In Germany, the requirements of the EU directive have been implemented in the Product Safety Act and the Machinery Ordinance.

Impact for practice

Since e-bikes are machines according to the EU regulation, manufacturers must have approval from a testing laboratory for all add-on parts of an e-bike. This requirement does not apply to a conventional bicycle, which is not classified as a machine. In practice, this means that you cannot use any replacement parts or add-on parts on your e-bike that have not been approved by the bike manufacturer. This includes, for example, the headlights of the lighting system, child seats, child trailers, etc. In addition, the Machinery Directive clearly defines that all tuning measures on the motor control system are not permitted.

Consequences in bike development

Due to the requirements of the Machinery Directive, the documentation effort required for the development of an e-bike is significantly greater than for the new development of a conventional bicycle. In addition, all points of the specified standards must be taken into account by the engineering department in the design process. For e-mountain bikes, the specifications of the EN 15194 pedelec standard apply, which in turn refers to ISO 4210, the MTB standard. These standards define all test requirements necessary for product approval (e.g. frame and component tests) in order to ensure that a product marketed in the EU is safe to operate.

ROTWILD works closely with the independent EFBE Prüftechnik GmbH on these test procedures. The testing laboratory is one of the leading laboratories for mechanical testing of bicycles and components. In the load tests of frames and components carried out there for ROTWILD, the loads are significantly higher than the specifications of EN15194 and ISO 4210, as these only set so-called minimum requirements.


The overriding purpose of the Machinery Directive, the above-mentioned standards applicable to EPACs is to ensure safety in the use of the e-bike.

In order to provide the biker with a simple way to determine the area of use for which the respective bike is intended, there is also the international ASTM classification. Here, five different areas of use are distinguished, from the touring bike (category 1) to the downhill bike (category 5). Here, the intended use is defined on the basis of, for example, terrain characteristics and jump height - in short, what may be done with the product. This gives every biker a simple orientation for which loads the manufacturer guarantees the safety of the respective bike. At the same time, the ASTM classification can only provide a general orientation. Many manufacturers therefore describe possible remaining risks in the operating instructions of the bike.

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