GPSR, CE, CPSC and how they affects custom bikes
- Brock Smith
- Dec 6, 2024
- 4 min read
Here in the states, the governing bicycle standard is 16 CFR Part 1512. This standard explicitly carves out an exception for custom frame builders.
§ 1512.1 Scope.
This part sets forth the requirements for a bicycle as defined in § 1512.2(a)(except a bicycle that is a ‘‘track bicycle’’ or a ‘‘one-of-a-kind bicycle’’ as defined in § 1512.2 (d) and (e)) which is not a banned article under § 1500.18(a)(12) of this chapter.
The governing rules in the EU (And the UK, they just call it UKCA instead), EN ISO4210 does NOT include any verbiage outlining any exceptions at all:
1 Scope
This part of ISO 4210 specifies safety and performance requirements for the design, assembly, and testing of bicycles and sub-assemblies having saddle height as given in Table 1, and lays down guidelines for manufacturer’s instructions on the use and care of such bicycles.
This part of ISO 4210 applies to young adult bicycles with maximum saddle height of 635 mm or more and less than 750 mm, city and trekking bicycles, mountain bicycles, and racing bicycles that have a maximum saddle height of 635 mm or more including folding bicycles (see Table 1 and Figure 1).
This part of ISO 4210 does not apply to specialized types of bicycle, such as delivery bicycles, recumbent bicycles, tandems, BMX bicycles, and bicycles designed and equipped for use in severe applications such as sanctioned competition events, stunting, or aerobatic manoeuvres.
NOTE For bicycles with a maximum saddle height of 435 mm or less, see ISO 8124-1, and with a maximum saddle height of more than 435 mm and less than 635 mm, see ISO 8098.
I have always been curious about how custom bicycles are treated in the EU. It’s safe to assume that anyone exporting products from Asia will have gone through CE certification which includes testing to ISO4210 and REACH (chemical testing). Luckily, suppliers will often perform their own chemical testing and you can get a letter of conformance so you don’t have to double up on testing.
The ISO4210 testing needs to be done on a representative frame sample, I have quoted it at about $3000 each a few years ago with the US based ACT labs.
Most of these standards do allow for self certification, this is what most of the larger companies do.
Self-Certification
Possible for In-House Testing: Many manufacturers perform testing in-house if they have the facilities and expertise to follow the ISO 4210 procedures accurately.
Documentation: Proper documentation and traceability are essential to demonstrate compliance, especially if a regulatory body or customer requests proof.
My understanding of the GPSR is that it only applies if there is not another standard to apply, such as the toy safety directive or EN ISO4210 bicycle standard.
I interpret GPSR as saying customs is going to start cracking down on imports and ensuring they are CE compliant.
Frame builders do not have to worry about GPSR because their products are already defined under EN ISO4210. Frame builders whose products are not compliant with EN ISO4210 should probably start the process of self certification.
A large part of CE compliance the “Declaration of Conformity” this is a document controlled by the importer Showing the following information:
Key Components of the Declaration of Conformity (DoC):
Title:
"EU Declaration of Conformity"
Manufacturer's Information:
Name, address, and contact details of the manufacturer (or the authorized representative if applicable).
Product Identification:
Clear identification of the product, including:
Product name.
Model/type number.
Serial numbers (if applicable).
Applicable Directives:
List of EU directives under which the product is being declared compliant, such as:
General Product Safety Directive (GPSD).
Machinery Directive (if applicable, e.g., for electrically assisted bicycles).
Other relevant directives like REACH (for material safety) or RoHS (if electrical components are included).
Applicable Standards:
The harmonized standards used to demonstrate compliance, for example:
EN ISO 4210 for bicycles.
EN 15194 for electrically assisted bicycles (if applicable).
Statement of Compliance:
A statement declaring that the product complies with the essential requirements of the listed directives.
Test References:
Details of any tests conducted to demonstrate compliance, including references to accredited laboratories (if testing was outsourced).
Manufacturer's Responsibility:
A declaration that the manufacturer is solely responsible for ensuring compliance.
Signature and Date:
The name, position, and signature of the authorized person within the company.
The date of issue of the declaration.
Optional Information:
A reference to the technical documentation maintained by the manufacturer.
A list of additional applicable standards or test methods used.
If you are already exporting frames to the EU without a DOC then it may be fine, but there is a chance they will start asking for these documents.
The standard also covers frame and packaging markings and user manual requirements. They are all quite simple things that frame builders can handle.
I would suggest reaching out to a smaller test lab such as this https://www.biketesting.com/about and have the same conversation. Their test prices seem very reasonable and I think testing one representative frame sample would be enough of a CYA for independent frame builders.
Obviously, I am not a lawyer but I managed this process for Strider bikes for several years so I’m quite confident in my interpretations of the standards. Feel free to reach out with any specific questions.
The crappy part about this kind of stuff is that no one can really tell you for certain, even the test labs. Think of it like insurance, it’s there for if the worst case happens.