TL;DR

If you manufacture or source lights for e-bikes sold in the EU, the rulebook that decides your fate is not European — it is German. Pedal-assist bicycles whose motor delivers no more than 250 W and whose assistance cuts off before 25 km/h are excluded from EU vehicle type approval by Article 2(2)(h) of Regulation (EU) No 168/2013, which means their lighting is regulated at national level. In Germany — the largest cycling market in Europe — that means §67 of the StVZO, the road traffic licensing ordinance. In practice: your front lamp must project a steady, non-dazzling white low beam; your rear lamp must burn steady red; both must hold KBA type approval with an assigned test mark; and if they draw energy from the e-bike’s drive battery, they must keep burning for at least two hours after the drive shuts down. I am Lily, Technical Director at Mengting, and after 15+ years in LED lighting I have turned these clauses into a repeatable OEM build process. This guide is exactly what I walk our European buyers through, clause by clause, mistake by mistake.

Two Rulebooks: Which One Governs Your E-Bike Light?

The decisive fork in the road is the e-bike’s assistance behaviour, not the light itself. Pedal-assist e-bikes up to 25 km/h follow national bicycle lighting law — StVZO in Germany — while speed pedelecs up to 45 km/h sit inside EU whole-vehicle type approval with UN lighting regulations. EU law treats “pedelecs” (pedal assistance up to 25 km/h, motor ≤250 W) as bicycles, while speed pedelecs (assistance up to 45 km/h) are category L1e-B vehicles that need full EU type approval under Regulation (EU) No 168/2013. Because an EPAC (electrically power-assisted cycle) falls outside that regulation’s scope entirely, its lights never pass through the EU type-approval machinery at all — instead, each member state applies its own roadworthiness rules, and in Germany that is the StVZO.

The StVZO is the Straßenverkehrs-Zulassungs-Ordnung, which is Germany’s ordinance defining the technical requirements a vehicle must meet before it may be used on public roads. §67 of that ordinance is the dedicated article for lighting devices on bicycles, and it applies fully to pedal-assist e-bikes. Because the German market is where enforcement is most concrete — police and municipal order offices actually check bicycle lighting in autumn campaigns, and the ZIV, Germany’s bicycle industry association, runs annual lighting awareness pushes — most OEM buyers treat StVZO compliance as their de facto EU baseline. That is a sensible strategy, and I tell our customers to design to StVZO even when the immediate order ships to the Netherlands or Austria.

Speed pedelecs are a different animal. Their lighting sits inside the whole-vehicle type approval, evaluated against UN regulations on lighting installation by a technical service, which makes the approval route noticeably longer and more expensive than StVZO conformity work, primarily because the whole vehicle — not just the lamp — is in scope. If your programme is a 45 km/h commuter bike, stop reading this article as a bicycle supplier and start reading it as a component supplier to a type-approval holder. Everything below applies to the mainstream 25 km/h EPAC market.

What StVZO §67 Actually Demands from a Bicycle Light

The full text of §67 StVZO is public, and it is worth reading the original because several details surprise even experienced product managers — I still catch assumptions that do not survive the wording. In one sentence, §67 demands a steady white low beam at the front, a steady red tail lamp at the rear, officially approved designs with assigned test marks, and mounting heights fixed between 250 mm and 1200 mm. The core requirements, in engineering terms:

• Front lighting: one or two headlamps for white low beam (Abblendlicht), aimed so that other road users are not dazzled. Flashing headlights are explicitly prohibited. An optional white front reflector and optional day-running or high-beam functions are permitted when they follow the relevant UN regulations on photometry and control layout.
• Rear lighting: at least one red tail lamp plus one red, non-triangular rear reflector of category “Z”; both may live in one housing. A brake-light function is permitted under the relevant UN photometric rules. Flashing tail lights are also explicitly prohibited.
• Pedals and sides: pedals must carry yellow retroreflectors facing forward and backward, and each wheel side must be secured by reflective white strips on tyres, rims or spokes, by fully reflective spokes or spoke sleeves, or by at least two yellow spoke reflectors mounted 180° apart on each wheel.
• Readiness: all lighting devices must be firmly mounted, secured against accidental displacement, kept unobstructed, and continuously ready for operation. Detachable lamps may be taken off during the day but must be fitted at dusk, darkness, or whenever visibility demands it.
• Power compatibility: the energy source may be a dynamo, a battery, a rechargeable energy store, or a combination, and its nominal voltage must be compatible with the lamps used.

Then come the numbers that shape your mechanical design. §67(8) fixes the mounting heights:

Two details deserve special attention from OEM teams. First, wide vehicles: bicycles over 1000 mm wide (cargo bikes, in practice) need paired white headlamps and paired red tail lamps mounted symmetrically, and anything over 1800 mm wide must follow UN Regulation No 48 installation rules designed for passenger cars. Because the cargo e-bike segment keeps growing, we now run a separate installation check for wide-fleet programmes instead of assuming bicycle-class rules apply. Second, §67(6) ties the switching logic to the power source: on dynamo systems the head and tail lamps may only switch on together, while battery systems may use a parking-light function where the tail lamp burns alone. Your firmware and wiring architecture must respect that logic before it ever reaches a notified lab.

The E-Bike Battery Clause Nobody Quotes: §67(7)

The two-hour reserve rule in §67(7) is the single most overlooked StVZO requirement in OEM e-bike lighting projects. Here is the clause that separates suppliers who have actually read the law from suppliers who repeat second-hand summaries. For bicycles with electric pedal assistance, the lighting may be fed from the drive battery — but only under one of two conditions: either the lighting keeps running uninterrupted for at least 2 hours after the drive assistance has shut down because the battery is low, or the drive motor can temporarily act as a generator to keep feeding the light. The rule applies to e-bikes placed on the market from 1 January 2019 onward.

Because the drive battery is usually the largest energy store on the bike, OEMs almost always choose the 2-hour-reserve route — and that decision cascades into your light’s electronics design. Concretely, it means the lamp must tolerate the battery management system’s cut-off behaviour: when the drive controller starves at low state of charge, the lighting rail must stay alive. In our projects we solve this with a dedicated buck converter on the lighting feed plus a hold-up buffer, and we verify the behaviour end-to-end with the customer’s battery management firmware — not on a bench supply, because a bench supply will never reproduce a BMS brown-out. If you are an OEM buyer, ask any candidate supplier exactly how their lamp survives the drive cut-off. A blank stare at this question tells you everything.

KBA Type Approval and the K-Number: The Gate Every OEM Supplier Must Pass

A bicycle light may only be sold or used on German public roads when it carries the KBA test mark assigned to its exact approved design. §67 alone defines what a light must do; §22a StVZO defines how it earns the right to be sold. Bicycle lighting devices — headlamps including any high-beam, day-running or parking-light function, tail lamps including any brake-light function, white, red and yellow retroreflectors, pedal reflectors, and reflective strips or spokes — are listed in §22a(1) no. 22 as components that must be executed in an officially approved design type (Bauartgenehmigung). §22a(2) then closes the loop: such components may only be offered for sale, sold, acquired or used if they carry the officially prescribed and assigned test mark. That test mark is what the industry calls the K-number — a wavy line above the letter K followed by an approval number, granted by the Kraftfahrt-Bundesamt (KBA), Germany’s Federal Motor Transport Authority, after laboratory testing against the applicable photometric, environmental and durability requirements.

Three practical consequences for OEM sourcing:

• The approval belongs to a specific design. The test mark is tied to the approved design type, and §67(6) states that only the light sources corresponding to that design may be used inside the lamp. Changing the LED bin, the reflector geometry, or the lens material after approval is not a harmless cost-down — it is a new design that needs its own approval. We freeze the approved configuration in our bill of materials and treat any optical change as a re-approval event.
• The mark must physically exist on the housing. Enforcement officers and inspectors look for the moulded or printed sign on the product itself. Plan the marking into the tooling early, because adding it later means a mould change.
• Documents must travel with the product. The approval certificate, the test report reference, and the scope of approval belong in your technical file. When a distributor or a market surveillance authority asks, the answer has to arrive within days, not after an email chain to a subcontractor.

The EU-Wide Compliance Stack Around StVZO

StVZO gets the light onto the road, but it is not the only gate between your factory and a European shelf. CE marking with EMC testing, RoHS substance restriction, the EU Battery Regulation, UN38.3 transport testing and an IEC 60529 IP rating together form the horizontal compliance stack we verify on every programme. Because a battery-powered bicycle light is an electrical product placed on the EU market, it also has to satisfy the horizontal EU obligations that sit alongside national road law:

• CE marking with EMC compliance. Active electronics with switching converters must meet the Electromagnetic Compatibility Directive 2014/30/EU; we test our bicycle light electronics to the harmonised emission and immunity standards for lighting equipment and keep the declaration of conformity in the technical file.
• RoHS substance restriction. Directive 2011/65/EU limits lead, mercury, cadmium and the flame-retardant chemistry in every solder joint and cable — we verify this at incoming material level with supplier declarations and XRF spot checks.
• The new EU Battery Regulation. Regulation (EU) 2023/1542 phases in labelling, QR-code and due-diligence duties for batteries placed on the EU market. The 18650 cells inside a bike light fall squarely into its scope, and we build the coming data requirements into our cell documentation now rather than retrofitting them under deadline pressure.
• Transport safety. Lithium cells must pass the UN Manual of Tests and Criteria section 38.3 test suite before they may fly or sail; our cell suppliers provide current UN38.3 test summaries as standard shipping documentation.
• Ingress protection. Road use means rain, spray and pressure washing. We rate our bicycle lights to the IEC 60529 IP code scale, documented in IEC 60529, and run our own rain-test rig on every programme.

One honest limitation I want to flag: there is no single EU-wide bicycle lighting regulation, so a product that is fully StVZO-compliant may still meet different national details elsewhere in the Union. Our advice to buyers is simple — design to StVZO plus the horizontal EU stack, then verify national deltas for France, the Netherlands and Scandinavia before shipping. That sequence resolves the overwhelming majority of cases.

Inside Our StVZO-Oriented OEM Builds: How We Engineer to §67

Let me show you how these clauses translate into a real programme, because abstractions do not survive first contact with a production line. Our reference platform is the bicycle light programme we ship in several regional variants: a two-source architecture with two COB emitters rated at 50 lumens for wide, close-range flood and one XPG LED rated at 170 lumens for the forward beam, fed by a single 1200 mAh 18650 lithium cell. The whole head measures 91.5 × 44 × 33 mm and weighs 50 g without battery — small enough to disappear on a handlebar, which matters because §67 demands lamps stay unobstructed and cannot be hidden behind bags or cables.

Three engineering decisions in that build are direct answers to the law:

1. Steady-first mode logic. The lamp offers five modes — LED 100%, LED 50%, LED flash, COB 100% and COB 50% — each reachable through the motion sensor switch. The flash mode exists for off-road visibility use; for German road-legal configurations we deliver firmware that keeps the steady modes forward-facing and documented. Because flashing beams are prohibited on public roads, we refuse to ship a default-on flash configuration into the German market — even when a customer first asks for it. That refusal has cost us an order or two. I would make the same call again.
2. Beam discipline instead of raw output. §67 does not reward the brightest lamp; it punishes the one that dazzles. We shape the XPG beam with a cut-off-oriented reflector and verify the distribution in our integrating sphere and on our outdoor beam rig here in Ningbo. The legal test is not how bright the lamp is at switch-on, but whether it stays inside its approved beam window after thirty minutes of heat soak — so that is exactly what we measure. Thermal management matters too — a 220-lumen head in a 50 g ABS body needs its driver current tuned so the optics stay inside their approved photometric window after 30 minutes of operation, not just at switch-on.
3. The 2-in-1 mounting reality. The unit works as a headlamp or as a frame-mounted bike light with its magnetic base, which is exactly the detachable-lamp scenario §67(2) describes: remove it during the day, fit it at dusk. We test the retention force of that mount under vibration so the “secured against accidental displacement” clause survives a cobblestone commute.

Every programme runs through our in-house verification battery before it touches an external lab: integrating-sphere photometry, rain test, high-temperature and humidity cycling, and an aging test on running samples. We have exported from Ningbo since 2014, hold ISO9001 and BSCI certifications on the factory side, and our Certificates page shows the CE and RoHS conformity behind the products. If your end user rides at night near harbours or up mountain passes — the same conditions that shaped our safety headlamp designs — you already know why we over-test.

The 10-Document Checklist I Hand Every OEM Buyer

Request these ten documents before you sign any OEM bicycle light purchase order — they are the difference between a compliant product and an expensive recall conversation. I publish the same list for our own sales team — if we cannot deliver all ten, we do not deserve the order:

1. The KBA type approval certificate for the exact lamp variant you are buying, including the approval number that appears on the housing.
2. Photometric test reports showing the beam meets the dazzle and distribution requirements under the same test conditions used for the approval.
3. The EMC test report and the CE declaration of conformity under Directive 2014/30/EU.
4. The RoHS conformity declaration with material-level traceability for the solder, cables and housings.
5. The current UN38.3 test summary for the lithium cell, including the cell model actually fitted in production.
6. The IP rating report with the test standard, the test duration and the sample configuration stated explicitly.
7. The 2-hour reserve verification for drive-battery-fed variants: test setup, battery state of charge at start, and the measured lighting behaviour after drive cut-off.
8. The battery regulation data package for (EU) 2023/1542 readiness: cell chemistry, capacity, and the labelling artwork review.
9. The bill of materials freeze statement confirming that LED, optics and firmware versions match the approved design.
10. A quality plan stating incoming inspection, in-process checks, final audit sampling, and the warranty terms — ours starts at a minimum one-year quality guarantee from delivery.

Frequently Asked Questions About StVZO Compliance