Understanding E-Bike Standard UL 2849: Commonly Asked Questions

Global markets for electric bicycles (e-bikes) are growing, but so are concerns over safety. We answer some commonly asked questions about UL 2849, the safety standard for electrical systems in e-bikes.

In November 2021, the US Occupational Safety and Health Administration (OSHA) adopted two e-bike-related standards for the workplace under the National Recognized Testing Laboratory (NRTL) program. These were:

• UL 2272 – Standard for electrical systems for personal e-mobility devices
• UL 2849 – Standard for electrical systems for e-bikes

Since then, the use of these standards has received wider recognition. In December 2022, the US Consumer Product safety Commission (CPSC) issued a letter to more than 2,000 businesses stating that failure to conform to relevant voluntary standards may pose an unreasonable risk to consumers. The letter specifically references UL 2272 and UL 2849, stating compliance with these standards, “significantly reduces the risk of injuries and deaths from micromobility device fires.”¹ Manufacturers and importers were warned that failure to conform to these standards could result in enforcement action. 

While this acted as a strong indication that UL 2272 and UL 2849 must be adopted by businesses manufacturing or importing e-bikes for non-work-related uses, the standards themselves remain voluntary. However, in September 2023, things changed when a new law came into effect in New York City (NYC) – Int 0663-2022. This made it illegal for anyone to distribute, sell, lease, rent or offer for sale, lease or rent a powered bicycle that did not conform to the following requirements:

• Electrical system must be certified as compliant to UL 2849 by an accredited testing laboratory (or similar safety standard established in consultation with the fire department)
• Accredited testing laboratory’s certification logo, wordmark or name must be displayed on either:
• Packaging or documentation provided at time of sale
• Directly onto the e-bike or e-bike battery

UL 2849 was recently revised and is now recognized by the Approved American National Standard (ANSI) and National Standard of Canada, making it applicable to both markets.

Commonly asked questions about UL 2849

1. Will battery certification to EN 15194 be accepted?

UL 2849 states the options for battery evaluation are as follows:

1. UL 2580/ULC-S2580
2. UL/ULC 2271
3. CSA C22.2 No. 62133/UL 62133
4. UL 2054

Additional testing is required for options c and d.

It should be noted that the requirements for certain city/state jurisdictions may be different. For example, New York City (NYC) mandates that batteries must meet UL 2271 without alternatives, but California will accept UL 2849 or EN 15194.

2. Have you seen an increase in brands and suppliers reaching out to SGS following the CPSC’s letter recommending adherence to UL 2849?

We have found many businesses are reaching out to us, trying to understand what the rules are and who the authority is. As most manufacturers and suppliers are aware, the CPSC requires the mechanical parts of a bike to conform to CFR 1512, but this does not address the electrical systems of an e-bike. The CPSC is currently looking into regulations for the electrical systems of bikes, which is where UL 2849 comes into play. This would make sense, as OSHA has already adopted UL 2849 and several cities and states are considering similar regulations.

3. I have heard UL tends to only accept test results from UL test laboratories. Is that true?

I cannot speak for what our competitors may accept, but I can say that SGS will accept any component certified by one of OSHA’s 21 accredited NRTLs. So long as a component is certified by an NRTL to the applicable standards in UL 2849, that is good enough for SGS.

4. What is the difference between compliance to UL 2849 and certification?

Certification must be provided by an ISO/IEC 17065 accredited laboratory or NRTL. To show compliance to UL 2849, testing must be performed by a facility with ISO/IEC 17025 accreditation.

5. Can you test e-bikes and e-mountain bikes (e-MTB) for CE marking in the US?

SGS can test e-bikes to EN 15194 and e-MTB to EN 17404 in the US, China and Taiwan.

6. Does SGS offer risk assessments or another service to review bikes and test reports? Even though our product meets all UL standards, we would like support in identifying shortfalls in bike designs and warnings.

SGS can perform a risk assessment as per the requirements in ISO 12100, as referenced in UL 2849. We can also conduct a protocol review for applicable requirements outside of electrical.

7. How long does it take to test an e-bike to UL 2849, and what are the associated costs?

This question often comes up, and the answer varies depending on several factors. Component-level approvals are a significant factor affecting both time and costs, and so is preparation. The first step involves a document review and meetings with clients and their suppliers (if requested) to ensure the components of the e-bike are certified and approved. If this proves to be the case, timing is much quicker.

Also, SGS can perform certification on the e-bike battery pack to UL 2271, but if you already have an approved battery pack, this will significantly reduce testing costs.

8. Does adherence to UL 2849 automatically mean the battery meets UL 2271?

9. Where does SGS perform e-bike tests?

We have e-bike capabilities in Atlanta (Georgia, USA), Taiwan and Shenzhen (China).

10. Around satisfying the NYC law, is complete bicycle UL 2849 testing required for e-bikes that use system parts that are individually UL compliant?

NYC requires certification of the finished e-bike to UL 2849, and the CPSC says e-bikes should be tested to UL 2849. Having approved components does not necessarily mean the finished e-bike will also meet the requirements in UL 2849. In addition, the electrical system itself needs certification to UL 2849.

11. As part of the testing and certification process, does SGS inspect system component manufacturer plants or are additional plant inspections required?

We only inspect manufacturing plants associated with the listing certification under UL 2849. Certified components that are used to construct the e-bike will have their own factory audits from their NRTL vendors. If we also certify the component, we would, of course, also be auditing those factories.

12. We deal with multiple e-bike models and so often, while the battery and motor will be the same, other components may differ. Can you test one e-bike using the battery, but different components to certify all models or would you need to test each specific bike with its individual components? Components would include the operator display, and similar, that could have alternate choices that are still certified to the appropriate standard, in most cases 62368. For us, the battery pack and motor controller are essentially integrated and certified to UL 2271.

It is okay to have alternate battery packs certified to UL 2271. For the motor controller, we would need to look at that because we do have to do the ISO 12100 risk assessment and functional safety testing to UL 13849. It therefore depends on the component, but we can usually list alternate components in our certification if requested, as we know supply chains are changeable.

13. We are talking about UL 2849, but where does EN 15194 fit in and is it acceptable in the US?

EN 15194 is the CE standard used for e-bikes in Europe. EN standards are generally not accepted in the US, although it should be remembered California does currently allow compliance to EN 15194.

14. We have heard that UL is receiving pushback from e-bike manufacturers, saying UL 2849 requirements are too strict. Is there any truth to this and do you foresee the UL 2849 requirements getting any easier?

I think some of the struggles might relate to the sourcing of components that meet the certification requirements. Also, traditional bike manufacturers are not used to having to source certified components for their bikes, but this is common practice for any other type of electrical product.

15. NYC is refining its language and I know San Francisco is considering passing similar requirements. Are there any other states or cities that require testing or are considering it?

California passed a bill in October 2023 calling for compliance to UL 2849 or EN 15194. Toronto, Canada, passed a ruling for battery compliance to UL or CE requirements, effective April 09, 2024. 

16. We have been struggling to get a complete list or a way to determine which brands have what certifications. Are there any labeling or documentation requirements for e-bikes following certification?

Brands providing certified complete systems or components should have those products marked with the certification company’s logo. You may also reference the certification company’s online certification directory to access information regarding the certification standard and alternate components that are certified by that company.

17. What are the chances of getting positive testing results to UL 2849 without close cooperation with the suppliers of the electrical systems?

It may be difficult to test components on your own against the component standard called out in UL 2849 without details of the component construction. Even if this information is provided for testing, moving forward may be risky as the e-bike manufacturer does not have control over the supply chain for that component. Therefore, even if the design alters slightly, they may find a compliance problem for the end product.

SGS solution

We offer a comprehensive range of testing and certification services to help manufacturers and suppliers of bikes, e-bikes and other e-mobility devices ensure compliance with market requirements in Europe, Canada and the US. In addition to being the first laboratory recognized by OSHA as an NRTL for UL 2849, we also hold accreditation to evaluate against UL 2271 – standard for batteries for use in light electric vehicles (LEV) applications and UL 2272. Our solutions encompass all forms of bicycles, bicycle accessories, personal protective equipment and components.

Learn more about SGS’s Bicycle and E-bike Testing Services.

Download our e-bike brochure.

We are at Eurobike from July 3-7, 2024 at Messe Frankfurt, Germany. Come by our booth A18a, hall 9.1!

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References

¹ CPSC Calls on Manufacturers to Comply with Safety Standards for Battery-Powered Products to Reduce the Risk of Injury and Death