Intentional News

260908 E-Bike Positive Trust Mark Scheme

15 min read

Thesis (Alf’s read): A year after the APPG’s original report on illegal e-bikes, the problem has only grown worse — 2,000 fires, 18 deaths, 700 injuries since 2019. The industry has launched a credible trust-mark scheme (eBike Positive), but government action remains the bottleneck: four concrete asks sit on the table and ministers have done nothing.

E-Bike Positive Trust Mark Scheme — APPG Cycling & Walking

Summary

The All-Party Parliamentary Group on Cycling & Walking held an evidence session revisiting their 2025 report on fake and illegal e-bikes. Chaired by Fionn, the session heard from the Bicycle Association, Association of Cycle Traders, London Fire Brigade, Transport for London, Electrical Safety First, and a Deliveroo representative.

The centrepiece development is the eBike Positive trust-mark scheme, launched in summer 2026 by the Bicycle Association and Association of Cycle Traders. It has two tiers: Verified Brands (passed an independent audit of EN15194 and battery standards — 30+ brands signed up, covering ~80% of the legitimate market) and Approved Retailers (committed to the scheme’s requirements — 600+ retailers enrolled). The mark applies only to complete Electrically Assisted Pedal Cycles (EAPCs), not conversion kits or secondhand bikes. The Department for Transport has recognised eBike Positive on gov.uk — a notable institutional endorsement.

On the fire side, London Fire Brigade reported 206 bike/e-scooter incidents last year, well over 100 this year with many involving public injuries. Their Charge Safe campaign has engaged ~10,000 gig-economy riders through fire station roadshow events, including just under 1,000 at Shoreditch and 130 at Lewisham (from ~230 in the borough). Riders are increasingly shifting to rented devices to avoid bringing dangerous batteries into their homes.

Transport for London confirmed they cannot currently quantify the harm from illegal e-bikes because the data isn’t there, but the risk profile is alarming — heavy vehicles at motorcycle speeds in cycling and pedestrian infrastructure. TfL noted an e-bike fire at Rayner’s Lane in February 2025 and stressed the catastrophic potential had it occurred underground. The Met has seized ~3,000 illegal vehicles on London roads this year. TfL is expanding their road safety charter to explicitly cover e-bikes and holding biannual safety forums with delivery companies.

Electrical Safety First presented three research projects: an AI data-sweep finding 1 in 18 products on online marketplaces showing indicators of likely non-compliance (travel adapters were 1 in 3); behavioural science research showing consumers infer safety from reviews and popularity rather than assessing it; and a forthcoming joint report with UCL on gig-economy battery safety (launching 19 October in Parliament).

The session surfaced key systemic tensions: the “private land only” loophole allows illegal e-scooters and e-motos to be sold legally; insurers and landlords are still banning legal e-bikes from homes and workplaces; and delivery platforms’ low pay drives riders toward cheap, illegal kits. Deliveroo pushed back on pay claims, stating a minimum order value of ~£2.90 and a voluntary minimum of ~£12.88/hr for bike riders, and confirmed they are building speed-detection tools to catch riders on illegal vehicles. A notable detail: the industry considered physically marking trust-marked bikes, but US trials showed counterfeit marks appeared within a week, so the scheme remains an audit/point-of-sale system.

APPG members discussed Westminster Hall debates and joint cross-party letters to ministers. Ruth Cadbury (former chair) walked through the original report’s eight recommendations and confirmed not much progress has been made on any of them.

The owner’s review notes (2026-09-08) — verbatim, with Alf’s responses

The owner’s original inline comments from his read are preserved here so nothing is lost, with Alf’s response to each beneath it. (Alf’s voice; the owner’s voice is his own.)

On the trust mark’s real teeth:

Wondering whether the trust mark is really trustworthy? Can a bike with this mark not be modified? The whole topic and complexity of bike modification seems to have been missed? Actually was answered towards the end with “God knows” what happens to an audit bike after it is sold. Good question about leasing companies being brought in to “ebike positive” but at it stands I feel the campaign lacks any real teeth given NY reality of how easily copied a label can be. It was good to hear that someone knew about QR codes but the sad reality is there are better technologies that are not so easily copied like NFC. Would be good if the panel had greater technical acumen but perhaps that exists behind the scenes with any brainstorming activities that might occur????

Alf’s response (2026-09-08): This is the sharpest critique in the room, and it’s correct. The session itself admitted two of your points: (a) the point-of-sale audit does not survive the sale — “God knows what people do to their bikes” afterwards; and (b) a physical mark is copyable (US trials showed counterfeit marks within a week). So the trust mark is an audit-with-consumer-guidance scheme, not a tamper-proof guarantee — a head-start on consumer trust, not a solution. Your upgrade suggestions are right and cheap to test: NFC tags (cryptographically harder to clone than QR, and hold a cradle-to-grave record) combined with a registered-owner database / bike “logbook” so an audit trail follows the frame+battery rather than ending at the till. Worth pushing the industry and any consultation on this exact point — it’s the difference between a sticker and a real guarantee. Also agree that leasing (Zoomo/Port) has not been brought in; that’s an omission, since leased bikes are the ones riders can’t modify freely.

On batteries and consumer handling:

What about poor consumer handling of battery? Does poor handling get caught by the ebike positive bike and owner get scolded? Can a more easily accessible and cost contained battery assurance service help? What about all the bikes without the ebike positive trust mark?

Alf’s response (2026-09-08): Poor charging/storage handling is a genuinely separate problem from a compliant product — a good battery in a bad charger or left cooking by a radiator still fires. The panel touched it (Charge Safe + electrical-safety guidance) but did not build it into the mark. Two concrete ideas your comment points to: (1) a battery health/assurance service — affordable, accessible testing (and a ≤N-cycle replacement/recall floor) so a compliant bike stays compliant as it ages; (2) make that service reach the unmarked majority — every bike without the mark is exactly where the risk concentrates, so a voluntary mark alone can’t cover the gap. That’s an argument for the MOT-style periodic battery check you raised below.

On the kitemark / tube ban:

No comment on the Kite Mark and whether the tube ban will exempt this. How accepted will this mark actually become?

Alf’s response (2026-09-08): A real gap — the session never addressed whether a trust-marked bike would be exempt from the TfL network restrictions.

Alf’s correction (2026-09-08): the owner’s point is sharper than mine — it’s not a “phased/e-scooter” restriction: all non-folding e-bikes are banned on the TfL network, all the time, everywhere; folding e-bikes are not. That logic baffles many and rests on a questionable premise (if the concern is battery fire risk, foldability changes the chemistry not at all). So the kite-mark question becomes: does a trust-marked (or folding) bike get a defined, defensible network status? If not exempt, the mark’s consumer value collapses for exactly the commuters the scheme most needs — acceptance is unproven, and this network-status question has to be answered before the mark can become the norm.

On demonising conversion kits:

Not sure about demonising conversion kits. Indeed it’s better for the climate to reuse regular bikes if they can be safely converted.

Alf’s response (2026-09-08): Agreed, and it’s a nuance the session largely flattened. The problem is not conversion per se — it’s uncertified, high-voltage, over-powered conversion kits that turn a bike into what is legally a motorbike with no brake/motor/battery assurance. Safe, compliant conversion (a certified kit fitted to a sound donor bike, battery separately certified) is genuinely better for the climate than scrapping and buying new. The right line is “regulate the kit and the fitter,” not “banning conversion.” Your point also flags a class issue: cheap conversion is how lower-income riders (and the gig economy) access e-assist at all — killing kits without a cheap certified alternative strands exactly the people the “fix” claims to help. Wheels for Wellbeing’s point (disabled users need approved conversion kits for unusual cycles) is the same principle. Requirement landing point: exclude certified/registered conversions from any ban, require speed-limit/motor/power compliance for what’s conversion, and keep an affordable certified path.

On enforcement / fines:

Zero fines for illegal bike cause if ever detected the person is stopped and scolded. I suspect the admin burden of fining is too great. I’ve seen illegal escooters on trains plenty.

Alf’s response (2026-09-08): Correct observation and it names the enforcement failure precisely: the police/TfL can stop and seize but effectively never fine — the admin burden and the “who is the registered keeper” problem make ticketing impractical for a vehicle with no registration. You’ve hit the systemic hole: an unregistered vehicle cannot be fined effectively — which is why “MOT/registration” style identification (your point below) and platform-side enforcement (who the rider works for) matter more than police roadside ticketing. The “I’ve seen illegal e-scooters on trains plenty” fact is telling: enforcement is effectively absent across the network, so the market treats illegality as risk-free.

On online marketplaces:

Online marketplaces are not created equal. Some provide greater assurance of sellers then others. Buyers beware is golden rule. Maybe a fine to the marketplace for every illegal bike retailer found will stir action?

Alf’s response (2026-09-08): Strong and directly actionable. Marketplaces are exactly not equal — the Product Regulation and Metrology Act (Royal Assent 2025) gives the government power to hold online marketplaces to account for dangerous products sold through them, and it explicitly flags lithium-ion batteries and e-bikes. The secondary legislation to set the actual requirements is still pending — this is a live gap the APPG/industry can push on now. Your “fine per illegal listing/retailer found” is the right incentive design (a penalty that scales with the marketplace’s failure to screen), and it’s exactly the direction the Act’s flexibility should be used. This is one of the few levers where a real, near-term government win is available.

On MOT-style checks / licensing / what’s in the APPG’s locus:

Should we not be going for an MOT style check for battery? Including bike? Related to the question of licensing that was poorly dealt with. “Need government to fix this” seemed to be the ongoing consensus / theme. What is in the locus of control for a APPG anyway?

Alf’s response (2026-09-08): The MOT/registration idea is the structural fix that keeps coming back and was sidestepped in the Q&A (one backbench suggestion; TfL caution about ~1m already in circulation). It’s a hard first step politically (fleets of existing bikes, a registration agency, enforcement cost) but it’s also the only mechanism that closes the three holes you spotted at once: finable identity, post-sale modification tracking, and battery health over the vehicle’s life. Realistic sequencing: start with a battery MOT-only (a periodic lithium-battery safety/health check + a registered battery serial) before a whole-vehicle logbook — cheaper and more targeted at the actual fire risk. On “what’s in an APPG’s locus of control”: limited but real — they can (a) table Westminster Hall debates, (b) write joint cross-party letters to ministers, (c) scrutinise and warn on pending secondary legislation, (d) set up written evidence and keep public pressure visible. They cannot legislate; their power is convening, spotlighting, and cornering ministers. The “government needs to fix this” consensus is correct, but an APPG’s job is to make that unavoidable.

On the “crisis vs problem” framing:

Qualify if crisis or problem. Seems like multiple problems cascading on reach other to feel like a crisis. I don’t think it’s just delivery drivers as I see many children using and also thieves using fur snatch and grab. What are the possible fixes behind supply and demand. How about the surveillance state as China is doing? The ultimate supplier of these bikes..

Alf’s response (2026-09-08): You’re right to insist on the distinction. By the vault’s own definition this is better described as multiple problems compounding into a felt crisis — a safety problem (fires, deaths, injuries), a labour/exasperation problem (gig riders forced onto cheap kits), a policing problem (theft/snatch, children riding illegal machines), and an enforcement problem — cascading until it feels like a single crisis even though it isn’t one systemic event. And you’re right that delivery drivers are not the whole story: the session itself noted phone-snatchers, kids joy-riding, and criminals — the “demand” side is far wider than gig delivery. The supply-demand split is the honest frame: supply (online marketplaces + uncertified imports + the private-land loophole) and demand (low pay that forces the cheapest option + the category being fun/cheap/fast). On the China point: a full surveillance-state answer (mandatory government registration of every battery/vehicle, like China’s) would work technically but is heavy-handed and sits badly with the very mobility-liberty story e-bikes are supposed to serve; I’d argue the UK middle path is certification-at-supply + registration-of-battery + platform accountability rather than state surveillance of riders. The root supplier is China, yes — which makes importer controls (stop uncertified batteries at the border) a first, cheap, high-leverage move that avoids the need for surveillance.

HD > okay perhaps the UK would not lead with surveillance but it’s a dimension that needs to be worked in some measure at some point in an affordable way. Not just with bikes but generally. I’m not adverse to it as long as it’s efficient and effective and respects privacy.

Alf’s response (2026-09-08): Fair, and I’ll adjust — the case is not “never any identification,” it’s “start least-invasive and proportionate.” The sequence I’d defend holds regardless: certification at supply + battery registration/identity first (object-level, cheap, does the fire-safety job and enables fining), and only then, if the data shows it’s needed and it’s done in a privacy-respecting, affordable way, consider broader vehicle/rider identification. That sequencing means the surveillance dimension is available later rather than needed now — which keeps the solution proportionate to the actual harm, and keeps public buy-in for the mobility story. Your “not bikes only, but generally” point is the wider question (identity regimes across transport/society) and is worth a note of its own.

On government as a mission:

Yes was abysmal record card. Clearly the crisis is not being seen one and the government needs to take this on as a “mission” to help being it back under control.

Alf’s response (2026-09-08): Agree entirely. The eight recommendations with “not much progress on any” is an abysmal record card, and treating this as a standing government mission (with a named owner, a deadline, and measurable reduction in fires/seizures as the success metric) rather than a regulatory afterthought is the correct framing. The good news: the Product Regulation and Metrology Act + pending marketplace secondary legislation + a stated DfT e-bike consultation is the machinery already to hand — what’s missing is urgency. (See the Envisioning note for what “taking it on as a mission” would concretely contain.)

Why it matters

This session crystallises a pattern familiar across the polycrisis: the regulated side of the market (legitimate brands, retailers) does the work, builds the infrastructure, and gets the standards right — while the unregulated side (online marketplaces, private-land loophole, gig-economy exploitation) floods the zone and government fails to act. The eBike Positive scheme is a genuinely useful intervention, but it only covers ~80% of the legitimate market — the illegitimate market is where the fires, deaths, and injuries come from, and voluntary schemes can’t reach it.

For the UK specifically: this is a safety crisis, a labour-rights crisis, and a consumer-protection crisis all tangled together. The owner’s read — multiple problems cascading into a felt crisis, wider than delivery drivers (children, thieves, joy-riders) — is the accurate picture. The four APPG asks are concrete and achievable; government silence since 2019 is a policy failure. The gig-economy dimension — exploited riders forced into cheap, illegal kits because platforms pay below living wage — connects directly to broader questions about labour rights and corporate accountability that run through the polycrisis. For e-bike enthusiasts and cyclists (like the owner), the risk is that blanket bans or fear of illegal e-bikes poisons the well for legal, safe, transformative e-bikes that are genuinely good for mobility and the climate.

Follow-ups & watch items

  • Watch item (the owner flagged, add to watch-list): Electrical Safety First + UCL joint report on gig-economy battery safety, launching 19 October in Parliament. Landing date is a signal event for this topic.
  • Watch item: the pending secondary legislation under the Product Regulation and Metrology Act — government intends to set online-marketplace requirements at the earliest opportunity (lithium batteries + e-bikes explicitly in scope). This is the near-term policy lever.
  • Future APPG events (from the session close): next meeting — pavement robots, Mon 14 Sep 16:30 hybrid; after that an e-bike working-group roundtable, online-only, morning of 11 Nov 2026. Both are opportunities to raise the points in this note.
  • Question to pursue with TfL: does a trust/kite-marked bike get any exemption from the phased transport-network restrictions? (Currently unanswered.)

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