NBDA Retailer Comments- CPSC 
The Consumer Product Safety Commission (CPSC or Commission) is considering developing a rule to address the risk of injury associated with electric bicycles (e-bikes). Posted March 15, 2024, This advance notice of proposed rulemaking (ANPR) initiates a rulemaking proceeding under the Consumer Product Safety Act (CPSA) and the Federal Hazardous Substances Act (FHSA). They are inviting comments concerning the risk of injury associated with mechanical hazards of e-bikes, potential regulatory alternatives, the economic impacts of various approaches, existing voluntary standards, and plans to develop new standards to address these risks. The NBDA would like to submit comments reflective of the insight and opinion from retailers across North America. Posting here.

Request for Comments
This ANPR is the first step in a proceeding that could result in amended or new mandatory regulations to address mechanical hazards associated with e-bikes. For the purpose of these questions, e-bikes include electric balance bikes. The Commission requests comment on all aspects of this ANPR.

As e-bikes continue to grow in popularity, CPSC is refining its data collection and studies to analyze the incidents of injuries and fatalities associated with e-bikes. There was over 50 questions for comment, in which the NBDA extracted 6 of those questions we thought that retailers could provide great insight on.

We invite you to submit comments and information, that the NBDA will submit to CPSC on behalf of retailers at large concerning the following:
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What percentage or share of the market or how many products are solely human powered, low-speed e-bikes, versus higher speed e-bikes and children's e-bikes including electric balance bikes?
How prevalent are three-wheeled e-bikes as a percentage or share of the market?
What types of safety equipment are consumers purchasing with e-bikes?
How many additional manufacturer labor hours (if any) are required to assemble/install safety equipment (signal lights, taillights, headlights, reflectors)?
How much additional time (if any) is required to manufacture (assembly) an e-bike as compared to a non-powered bike?
Are e-bikes with higher top speeds (over 28 mph) marketed for off-road use currently being used on public roads, streets, or highways?
Thank you! 
The NBDA will include your comments in a response to the CPSC prior to May 14, 2024. Thank you for taking part in shaping future legislation. 
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