Regulations for End Consumers of Bafang BBS DIY Motor Systems

Belief, Hope — or Certainty?

Reprogramming the performance parameters of a motor controller yourself is not automatically illegal. However, without verifiable evidence—or a proper Declaration of Conformity—showing what power limit has been set and how reliably it is enforced, a Bafang BBS motor system may be treated as requiring registration / approval rather than being considered a standard, compliant pedelec setup.

In addition, attaching a power label that cannot be substantiated (e.g., “250 W”) can be interpreted as intentional deception. For this reason, a self-made, purchased, or counterfeit CE label marked “250 W”—without supporting documentation such as the manufacturer’s Declaration of Conformity—is highly problematic and can, in serious cases, lead to vehicle seizure.

A CE marking confirms that the essential requirements of the applicable EU legislation (e.g., the Machinery Directive) have been met. In order to apply a CE marking, the manufacturer (or an authorized representative) must issue a Declaration of Conformity, confirming that the product complies with the relevant rules and standards. A video record of an installation or an assembly guide alone—without confirmation from a qualified specialist business—is generally not sufficient.

Under German product liability principles (ProdHaftG), anyone who retrofits a bicycle with an electric drive can be considered the “manufacturer” of the newly created product and may be held liable accordingly. From a legal point of view, the conversion can result in a new product. As a consequence, original manufacturer warranties may become void—especially regarding safety-critical issues such as frame failure or brake malfunction.

That said, the conversion does not automatically make you the manufacturer of every individual component involved (motor system, battery, frame, wheels, accessories). Those parts remain independent products of their respective manufacturers.

If you intend to change the manufacturer-specified power rating or other core functions, you will typically need one of the following:

• a written statement from the manufacturer, or

• an additional certified product supplied with manufacturer documentation, or

• a declaration from a qualified company confirming and certifying the modifications carried out.

Furthermore, the system must not allow the maximum limits to be changed during operation and should be designed to be tamper-resistant.

Important note on Bafang BBS CE marking

Bafang BBS motors usually carry a CE marking for Electromagnetic Compatibility (EMC) only. This means there is no additional CE Declaration of Conformity covering power rating or operational safety in the sense required for a compliant 250 W pedelec classification.

Where to get reliable information

For binding clarification and official guidance, you may contact, for example:

• the manufacturer

• the local registration authority

• a technical inspection body (e.g., TÜV)

• a certified expert / assessor

• a lawyer

• competent regulatory authorities

• specialist dealers and technical committees

As a long-standing specialist dealer and manufacturer, we are of course happy to help with factual questions and provide practical guidance.

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