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April 1, 2025 – A coalition of light electric vehicle (LEV) industry leaders, led by LEVA-EU, has published an open letter to European Commissioner for Growth Stéphane Séjourné and the full European Commission, accusing the institution of decades of regulatory neglect that has locked LEVs — a proven climate solution — into inappropriate, outdated legislation. The letter, supported by Guy Salens of THE PACK, warns that while the planet burns, politicians continue to protect the car industry, ignoring overwhelming scientific evidence that LEVs could cut passenger car emissions by 44% in Germany alone.
The core problem: wrong vehicle, wrong law
The open letter, sent to Commissioner Séjourné and all Commission colleagues, argues that LEVs—including electric scooters, speed pedelecs, and compact e-bikes—are forced into two inappropriate regulatory frameworks: the Machinery Regulation (for electric scooters) and Regulation 168/2013 on mopeds and motorcycles (for speed pedelecs). This mismatch means vehicles that are essentially bicycles with pedal assistance up to 45 km/h are type-approved as mopeds, forcing riders onto roads alongside cars and trucks traveling at 50–90 km/h, violating basic road safety principles.
88% emissions savings potential, but no action
The letter cites the 2022 German Aerospace Center (DLR) study, commissioned by LEVA-EU, which modeled replacing car trips with LEVs in Germany. The results: up to 76% of all car trips (and 50% of car mileage) could be technically shifted to LEVs, since 98% of trips are under 100 km and the average car carries only 1.4 occupants. For substituted trips, LEVs emit only 12% of the CO₂eq per kilometer of the passenger car they replace — an 88% reduction. Applied nationally, this would cut Germany’s passenger car emissions by 57 million tonnes of CO₂eq annually, or 44% of the sector’s total. The German transport sector emitted 143.1 Mt CO₂eq in 2024 and has consistently missed its legally mandated targets, overshooting by about 18 million tonnes.
Exclusive insight: regulatory discrimination against disabled citizens
A particularly damning section of the letter reveals outright discrimination in EU technical legislation. Under current rules, e-bikes where the rider must pedal to receive motor assistance can be self-certified. But if the motor can function independently (via a button or lever), the vehicle requires full moped type-approval — a framework 27 years old, introduced without any sector consultation. The result: zero such bikes are on the EU market. Of the roughly 90 million EU citizens with disabilities, several million are physically unable to pedal continuously, effectively barring them from e-bike access. The letter calls this “wholly nonsensical legislation that not only discriminates but also runs counter to technology neutrality.”
The "small car" hypocrisy: Jeep Avenger qualifies, Microlino does not
The letter highlights a stark example of regulatory inconsistency: the European Commission’s proposal to encourage “small” cars — defined as up to 4.2 meters in length and category M (passenger car). The Jeep Avenger Electric, at 4.08 m and weighing 1.52–1.57 tonnes, qualifies. Meanwhile, the Microlino microcar, just 2.52 m and roughly half a tonne, does not, because it is classified under category L. This illustrates how the Commission’s own services lack basic knowledge of LEVs, which lie hidden in moped/motorcycle regulations on one hand and machinery regulations on the other.
Battery Regulation: a looming disaster for SMEs
The open letter warns that the Battery Regulation, which introduced the term “light means of transport,” is creating a regulatory nightmare. The Extended Producer Responsibility (EPR) obligations, combined with the fact that the EU invested in car battery manufacturing (e.g., the Battery Booster Facility) but not LEV batteries, means most LEV SMEs must source batteries from outside Europe. The disaster scenario is unfolding: many small and medium-sized enterprises face existential threats as compliance costs skyrocket.
What LEVA-EU demands: a comprehensive legal framework for LEVs
LEVA-EU and its allies call for an immediate overhaul of EU technical legislation governing LEVs. They demand that LEVs be recognized as a distinct vehicle category, separate from mopeds and machinery, with appropriate safety standards, road access rules, and conformity procedures. The letter also calls for ending the discrimination against cyclists with disabilities by allowing throttle-assisted e-bikes under the same self-certification regime as pedal-assist bikes.
Industry reaction: “The world is on fire, and politicians keep looking away”
Guy Salens, founder of THE PACK, voiced strong support for the letter: “We stand fully behind this. LEVA-EU has been saying it for years, and they’re right: light electric vehicles are a climate solution sitting idle in the wrong legislation, while politicians keep protecting the car. Enough studies, enough reports, enough 'no time for LEVs.' The world is on fire, and the people who can act keep looking away. It’s time politicians grow a spine and actually change things — not next mandate, not after another consultation round, NOW!”
The bigger picture: LEVs as a social and economic good
Beyond emissions, the letter emphasizes that LEVs improve public health, social inclusion, and require few raw materials. They are already accessible to a large share of citizens and, with the necessary legislative changes, could become accessible to everyone. Yet from every corner of the political spectrum, LEVs are either attacked or ignored. Decisions on how and where they may be used are made on the basis of “sheer ignorance and gut feeling,” the letter states.
Conclusion: time for action, not excuses
As the climate crisis intensifies, the open letter serves as a direct challenge to the European Commission: either treat LEVs as a serious climate solution with a modern, coherent regulatory framework, or continue to be complicit in the status quo that prioritizes the car industry over the common good. The letter is not just a complaint — it’s a roadmap for immediate, low-cost emissions reductions that do not require changing current mobility patterns, only shifting the vehicle used for each trip.
The full letter was published on the LEVA-EU website on April 1, 2025, and is open for public comment. Industry stakeholders, disability advocates, and climate groups are urged to add their voices.
