Deadline May 15, 2026! End of the transition period for the EN 15194 standard. Why is an EN 50604 compliant battery becoming a "make-or-break" issue for e-bike manufacturers?

The bicycle industry is currently entering a critical regulatory phase. The clock is ticking relentlessly, counting down to May 15, 2026. This is a date that marks the end of the "old order" for many Product Managers and Importers within the European Union.

On that day, the transition period and the presumption of conformity for bicycles certified under EN 15194:2017 come to an end. From mid-May, every EPAC placed on the EU market must comply with the updated requirements of EN 15194:2017+A1:2023. This seemingly minor change in designation triggers a fundamental shift in the approach to the bicycle's most expensive and hazardous component: the battery.

Gone are the days of discretion and reliance solely on transport certificates. The new regulatory framework is clear: Non-compliance with EN 50604-1 means non-compliance of the entire bicycle.

1. The Machinery Directive and the "Harmonized Trinity"

To understand the gravity of the situation, we must view the e-bike not as a "bicycle with an add-on," but as a machine under EU law. The foundation for placing an electric bicycle on the market is the Machinery Directive 2006/42/EC. It imposes the obligation on manufacturers to ensure safety.

However, the Directive provides only a general legal framework. To ensure manufacturers know specifically how to meet these requirements, and for market surveillance officials to know how to verify them, so-called Harmonized Standards are applied. This brings us to the core of the issue, which can be termed the "Harmonized Trinity":

• The Apex of the Pyramid (Law): Machinery Directive 2006/42/EC.

• Product Standard (Bicycle Requirements): EN 15194:2017+A1:2023.

• Component Standard (Battery Requirements): EN 50604-1:2016+A1:2021.

The "Presumption of Conformity" Mechanism and the Date 15.05.2026

The withdrawal date for the old standard, May 15, 2026, was confirmed in Commission Implementing Decision (EU) 2024/1329. After this date, manufacturers can no longer rely on the presumption of conformity for older versions.

The key change in EN 15194+A1:2023 involves tightening the requirements regarding batteries. The product standard for the bicycle explicitly references the EN 50604-1 standard.

For R&D and Compliance departments, this means one thing. The EN 50604-1 test report becomes just as critical as the frame or the motor. It is a mandatory safety foundation, without which, after May 15, 2026, the bicycle becomes a legal "outlaw" (non-compliant with the Machinery Directive).

2. EN 50604-1 vs. UN 38.3. Why "transport documentation" is no longer sufficient?

One of the most dangerous myths circulating in the European bicycle market is the belief that possessing a UN 38.3 test report "settles the matter" of battery safety. Many Product Managers, upon seeing a document with the header "Battery Safety Test," simply check it off their list and move on. This is a mistake that will cost them their CE certification.

We must draw a clear distinction between logistical safety and operational safety.

UN 38.3. Protecting the aircraft, not the cyclist

The UN 38.3 certificate was established for a single purpose: to ensure the battery does not explode during transport. While transport regulations (IATA) require a State of Charge (SoC) reduction to 30% for air freight, UN 38.3 tests are merely a snapshot, verifying only the battery's current condition.

In contrast, the EN 50604-1 standard mandates Functional Safety (in accordance with ISO 13849-1). This obliges the manufacturer to account for the reliability and aging of BMS components throughout the entire anticipated service life (Mission Time), not just at the moment it leaves the factory.

UN 38.3 does not account for what happens when a user connects a charger in a damp garage, when the BMS fails, or when the motor suddenly draws peak current during a steep climb.

EN 50604-1. Protection for "Daily Life"

The EN 50604-1 standard (dedicated to Light Electric Vehicles - LEV) ventures into areas uncovered by the transport-focused UN 38.3, concentrating on operational safety and integration with the BMS. A key difference also concerns the State of Charge (SoC).

While certification tests under UN 38.3 (tests T.1–T.5, T.7) are performed on fully charged batteries (100% SoC) to verify safety under the harshest conditions, actual transport regulations (e.g., IATA DGR for air freight) require that batteries physically handed over for shipment be discharged to a maximum level of 30% SoC.

In contrast, tests according to EN 50604-1 verify battery safety across its full operating range. This involves testing often at 100% charge, discharging during the test, and simulating conditions of emergency overcharge as well as deep discharge (over-discharge), which is crucial for end-user safety.

Although EN 50604-1 relies on the UN 38.3 transport standard regarding vibration, unlike standards for consumer electronics (EN 62133), it mandates the verification of the entire battery system within the vehicle architecture. This includes taking into account LEV-specific connectors, BMS communication, and current protection, which are not covered by other standards.

3. A Deeper Look into the Standard. Destructive Testing and the Role of the BMS

If the EN 15194 standard is the "Constitution" of the bicycle, then EN 50604-1 is its "Penal Code." Transitioning to this standard forces a paradigm shift in the design of battery packs. The BMS ceases to be merely a balancing circuit; it becomes a Safety Component.

A. The BMS as a "Digital Fuse"

The standard requires that the BMS meet the requirements of Functional Safety (often referencing EN ISO 13849). The designer must demonstrate that the BMS is resilient to internal faults, and that the failure of a single sensor will not lead to a fire.

I. The "Big Three" of Destructive Tests

The EN 50604-1 standard prescribes tests simulating worst-case scenarios:

• Overcharge Test: Simulates a charger failure (excessive voltage). The BMS must detect the voltage rise and physically cut off the charging path before the cells enter Thermal Runaway (uncontrolled ignition).

• External Short Circuit Test: The battery contacts are shorted at full power. The BMS must cut off the circuit in microseconds. A delayed response will result in contact welding and fire.

• Over-discharge Test: The BMS must permanently block the possibility of charging a battery that has been extremely deeply discharged (chemically damaged) to prevent internal shorts during an attempt at its "revival."

II. Mechanical and Environmental Tests (Real-world Usage Simulation)

In addition to electrical protection, the standard places significant emphasis on the physical durability of the battery pack under conditions that may occur during the daily use of the vehicle:

• Drop Test: Replicates a scenario where the user drops the battery, for example, while removing it from the bicycle. The battery is dropped from a height of 1 meter onto a hard surface. The enclosure must not crack in a way that exposes the cells, and the pack itself must remain sealed and safe (no electrolyte leakage or ignition).

• Crush Test: Simulates a traffic accident scenario where the battery is crushed by another vehicle or a structural component. The test verifies whether significant mechanical deformation will lead to an internal short circuit resulting in a violent fire or explosion.

• UV Resistance Test: Applies to external battery components exposed to direct sunlight. Plastics can become brittle and lose their mechanical properties under UV radiation. The test verifies whether, after long-term exposure, the enclosure still provides the required mechanical protection and Ingress Protection (IP) rating.

III. Climatic and Water Tests (Weather Simulation)

LEV batteries operate in a variable outdoor environment, therefore the standard requires confirmation of their resistance to atmospheric factors:

• Immersion Test: Verifies the Ingress Protection (IP) rating in extreme situations, such as riding into a deep puddle or temporary submersion of the vehicle. Water must not penetrate the interior of the enclosure, protecting the BMS system and cells against corrosion and dangerous short circuits.

• Dewing Test (Condensation): Simulates a sudden change in temperature, such as bringing a cold bicycle into a warm room, which causes water vapor to condense on battery components. The test checks the electronics' resistance to moisture, which could cause "hidden" short circuits on the BMS board or contact corrosion.

• Thermal Abuse Test: The battery is placed in a thermal chamber and heated to a temperature significantly exceeding its operating range (e.g., 130°C), verifying the chemical stability of the cell separators. The system must withstand this stress without rapid ignition for a specified period.

• Low Temperature Thermal Test: Verifies system behavior in freezing conditions. It is crucial to verify whether the BMS correctly blocks the charging process at sub-zero temperatures (which permanently damages Li-Ion cells) and whether structural materials (seals, enclosure) do not crack under the influence of the cold.

4. The Date May 15, 2026. What does this mean in practice for Business?

The date May 15, 2026, marks the moment of "Placing on the market." It is precisely this moment that determines whether your goods are legal.

• Goods "On the Water": If a container of bicycles (with old documentation) arrives at an EU port after May 15, 2026, the Customs Authorities may question the Declaration of Conformity. On the day of customs clearance, the goods will not meet the applicable requirements for the presumption of conformity.

• Time Constraints: Battery certification for compliance with EN 50604-1 takes 8-12 weeks. If the process has not yet started (January/February 2026), there is a huge risk of failing to complete production and shipment before the deadline.

• No "Grandfather Rights": The fact that a bicycle model has been on sale for years does not exempt new production batches from the requirement to meet the new standards. Every unit placed on the market after May 15 must be documentation-compliant.

5. End of the "Custom Assembly" Era and Implementation Checklist

Finally, we must address the issue of companies that design packs in-house or outsource this to local entities, using branded cells from Samsung, LG, or Panasonic.

The "Branded Cell" Trap

The belief that "I have LG cells, so I am safe," is a fallacy. The EN 50604-1 standard certifies the entire battery system, not the individual cell. Even the best cells, combined with an inferior BMS or within a poorly designed enclosure, will not pass the tests.

The Assembler (the company assembling the pack) becomes the battery manufacturer in the eyes of the law, and it is they who must provide the test report for the complete pack. A cell datasheet is not enough.

PRODUCT MANAGER'S CHECKLIST (Deadline: 15.05.2026)

Documentation Verification:

• Does the battery test report reference EN 50604-1:2016+A1:2021?

• Reject reports based solely on UN 38.3 or EN 62133.

Check the BMS:

• Does the report contain a section regarding "Safety Functions," and has the BMS passed functional tests?

Model Consistency:

• Ensure that the report applies to exactly this configuration (cells, BMS, enclosure) that is installed in the bicycle. Changing a single component invalidates the test.

Logistics:

• Goods with old documentation must be customs cleared in the EU before May 15, 2026.

The year 2026 marks the end of the "Wild West" in the e-bike industry. The requirement for full compliance with EN 50604-1 is a necessary market evolution. Safety is becoming the new currency,bmake sure you have enough of it in your wallet before May.