Question about Micro Merlin X4

I have passed this on to our product manager and this has been checked with Micro, here is what I can now pass on to you:

"Micro says the scooter is legal. According to their information, however, the scooter travels at 25 km/h, which is not legal in Switzerland, but only at 20 km/h. Micro is of the opinion that it is legal as long as you don't drive over 20 km/h, but in our opinion it must be sealed at 20 km/h due to its design. Since we want to stick to the legal guidelines here, we leave the note "not approved" even if Micro officially communicates otherwise."

I contacted ASTRA today. According to this, the vehicle is presumably NOT approved for road use, and this because the scooter cannot be permanently throttled from 25 to 20 km/h. Here are a few excerpts from the reply from FEDRO (I was extremely impressed by how quickly and in detail the reply was given):

"Our office does not carry out any tests or assessments of vehicles. Consequently, we cannot give a final opinion on the product you mentioned. In general, we can answer you as follows:"

[...]

"The maximum speed must not exceed 20 km/h with purely electric drive and regardless of the selected riding mode. With pedal assistance, 25 km/h is permissible. It should be noted that any limitation (e.g. by firmware) must be permanent and tamper-proof (Art. 177 para. 2 VTS). If the installation can be done easily by the user, this is not the case.

In addition, according to Annex 1 paragraph 1.2 of the Type Approval Ordinance (TGV), light motorbikes are in principle exempt from the type approval obligation."

[...]

"Light motorbikes, like bicycles, may be placed on the market and put into circulation without type approval (i.e. without type approval and without registration with the Road Traffic Office). However, they must of course still comply with all the regulations that apply to them. The responsibility for ensuring that these vehicles are delivered or used in accordance with the regulations lies with the manufacturer/importer or ultimately with the person who uses them on public property. According to article 1 paragraph 7 VTS, the provisions of the Federal Product Safety Act also apply.

If you are not sure whether your vehicle meets the requirements, you can contact a test centre recognised by FEDRO (DTC AG/Fakt AG) and have your vehicle tested there. If necessary, the seller or the importer can also take this step to make sure.

So far I have not received any useful information from Micro, including whether the scooter's battery is replaceable. I consider it a bit tricky for a Swiss manufacturer to declare a product as being permitted for road use when this is not the case from a legal point of view. In the case of Galaxus, they probably acted correctly and labelled the vehicle accordingly, but a solution should actually be presented by Micro. In the end, the customer will be liable, and it is well known that the authorities like to make a fuss about unauthorised e-mobility devices. If necessary, Micro or Galaxus could have the scooter tested by such a test centre and inform us about the findings... It's a shame, because the scooter is supposed to be really good.

There is no product-specific "road approval". There are simply certain rules that must be observed. These are listed here in an overview:

https://eflizzer.ch/e-bikes-un...

- max. 500-1000W
- max. 20km/h
- 2 brakes
- Front and rear light

Then it is allowed to ride on cycle paths.

The manufacturer will not confirm this legally - but since these conditions are/will be met, I personally consider this "vehicle" to be approved.