20 December 2018: BA Technical Service year in review
Dear BA members, colleagues,
As 2018 draws to an end it's perhaps a good moment to summarise the main technical issues which we've covered this year.
This may be especially relevant for the many new BA members who have joined us this year - membership now stands at around 80 companies, up from around 60 just a year ago.
I would also like to thank all of the many colleagues from BA member companies who have contributed to the BA's technical work - with your insights, questions, advice, input at meetings and feedback on the many emails we've sent this year.
If you missed any communications, or only recently joined, a full archive of emails sent by the BA Technical Service in 2018 can be accessed here (under the "Lastest Updates" tab) in the members-only area of the BA website.
SUMMARY OF MAIN ISSUES COVERED
Brexit: The BA has provided members with regular, timely updates as the situation has developed over the year, including a 14-page analysis of the implications of a 'no deal' departure, a detailed look at the transitional arrangements outlined in the Withdrawal Agreement, and most recently analysis of the EU 'no deal' planning. A particular focus has been on clarifying the prospects for tariffs on imports and exports, and whether anti-dumping duties will continue to apply post-Brexit. We've provided recommendations about how to get informed, analyse the risk for your company and how to respond proportionately while uncertainty about the outcome persists. Positive feedback from BA members indicates that amid the mass of commentary around Brexit, this sector-specific and concise advise has been well received.
Anti-dumping: Many BA members have been impacted by the EU anti-dumping investigation against e-bikes imported from China, which is due to conclude early next year when 'Definitive Measures" are announced (by 19th Jan). Over the course of the year we have been kept busy informing members in clear language about the often opaque investigation process, when and how duties (provisional and definitive) must be paid, and the possible ramifications of 'registration'. We obtained definitive advice from HMRC about the degree of assembly which it is legitimate to complete before importing as frames/parts rather than complete bikes. Most recently we issued advice on the procedure for reclaiming any excess provisional duty paid, should the 'definitive measures' specify a lower level than the 'provisional measures' imposed.
Motor Insurance Directive/Vnuk: The BA has for many years now been working to ensure that reform of this European Directive does not mean that all e-bikes must carry motor-vehicle style third party insurance. We successfully lobbied the UK Government to oppose it at EU level, and we also assisted our colleagues at EU-level trade body CONEBI in their lobbying efforts. Most recently it seems that the threat of mandatory insurance for e-bikes is receding, as an influential report to the revising committee has recommended that e-bikes be excluded from this requirement. But until the final text is agreed (or the Brexit process makes it moot) we will continue to engage on this.
CWIS Safety Review: The Government set up this review in the wake of a tragic accident in which a rider with (illegally) no front brake hit and killed a pedestrian. The Technical Service consulted with members before contributing to the development of the BA's submission, and also provided swift analysis of the recent Government response (for example, noting the possibility of a future review of cycle lighting regulations).
Cargo bike grants: The BA's Technical Service developed a very well received consultation response to the DfT's "Last Mile Call for Evidence" and we understand that many aspects of this work will shape the implementation of the £2m grant scheme to boost cargo bike uptake. We expect to be heavily involved as the practical details (how to apply, what is eligible etc) of the scheme are developed in early 2019, and will of course keep BA members closely informed.
Standards work: The BA's Technical Service participates actively in standards development work at BSI, CEN and ISO, enabling us to give truly informed advice to members on all standards and testing matters. The main areas of standards work this year (and ongoing) are:
1) Revision of the ISO 4210 series: updating the most widely-used testing standards.
2) Luggage carriers: implementing more realistic fatigue tests.
3) Usage labels: standardised frame labels to indicate the terrain bikes are designed for.
4) E-MTBs: a new part of EN15194 with new mechanical loadings for e-MTBs.
5) Cargo bikes: work should start next year on an EN cargo bike standard.
8) Cycle locks: a revision of EN 15496:2008 is expected to start next year
9) Harmonisation and phase in of EN15194:2017
10) ISO 4210-10: the world e-bike standard, and possible future replacement for EN15194:2017, is still under development.
Handlebar end safety: A number of BA members drew our attention to a report of a child killed in the USA by a puncture wound from a handlebar with an open end, and proposed that as a low-cost solution, all bars shoudl be fitted with hard plastic end plugs as well as any grips which cover their ends. The Technical Service called for evidence of further similar injuries, and also raised the matter with the CEN and ISO standards committees which could incorporate such a requirement into future revisions of the relevant standards. This work is ongoing.
Carbon rims/pads safety: As you can read here, the BA was made aware of a possible safety issue and, after consultation with members, issued some public recommendations for low-cost measures which could prevent recurrence. We will follow up any feedback or further reports.
Lithium batteries: The Technical Service has continued to revise and refine the guidance we developed last year about the requirements, paperwork and best practice in lithium battery storage, shipping and handling. We are now working to update it to reflect the upcoming ADR2019 regulations.
CONEBI, MCWG and UNECE: Through membership of CONEBI, the European umbrella body for national cycle industry trade associations, the BA Technical Service monitors and where relevant contributes to developments at the EU's Motorcycle Working Group (responsible amongst other things for the type approval regulation 168/2013 and associated regulations), and on a number of committees of UNECE, the United Nations body responsible for many international traffic and vehicles rules and regulations (many of which are adopted by the EU, and which would also affect post-Brexit UK). Subjects include e.g. the details of approval tests for cyclist detection systems on HGVs, or the 'ground rules' about how autonomous vehicles should be able to cope with cyclists. We regularly update BA members on any relevant developments.
End use relief: This is a little-known provision which allows certain cycle frames and parts to be imported at a zero tariff rate, although sometimes with quantity limits and requirements for how and when they are to be used. We are developing guidance for importers on this, and have just received some very useful input from HMRC.
Knowledgebase: Many of the BA Technical Service advice documents are available to download here on the members-only part of the BA website. These are regularly updated and added to, so please do check back, or just contact us, if you need anything in particular.
Member support: One-on-one support (within reason) is included within BA membership, and queries from BA member companies handled by the Technical Service this year have included everything from questions about how specific standards tests are carried out to reviewing editorial about e-bikes for legal accuracy to investigating the legality of selling and using e-scooters in the UK (which, like many queries, resulted in findings we passed on to the wider membership - and followed up when the Government released updated advice).
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All of this work is carried out for members as part of the BA's key strategic priority of supporting and strenghtening the industry - we invite any company with a stake in the UK cycle industry to join the BA so as to participate in this work and the BA's wider initiatives.