DOTr-LTO-Whole-of-Government Impounding Confusion: Why the Philippines Needs Smart, Data-Driven Rules for E-Trikes and E-Bikes
- TSE
- 5 days ago
- 6 min read
Updated: 3 days ago
Recent impounding directives by the Land Transportation Office (LTO) - Department of Transportation (DOTr) on e-bikes and e-trikes have sparked strong reactions from mobility advocates, including Representive Terry Ridon and several civil society transport groups, calling out unclear enforcement and outdated regulations.
At the core of the debate is a widespread misclassification problem. The public and sometimes authorities loosely refer to all 2-wheeler and 3-wheeler electric vehicles (EVs) as “e-bikes.” But the law and common sense distinguishes them clearly:
Vehicle Type | Wheels | Typical Weight | Licensing Required? | Should Register? |
LEV (e-bikes, scooters, personal mobility devices, electric unicycle) | 2 (or, 1 for electric uni-cycle) | ≤ 50 kg | No - Yes, under this crazy LTO regulation | No for ≤ 50 kg - under EVIDA exemption |
E-Bike (with pedals, ok?) | 2 | ≤ 50 kg | No - Yes, under this crazy LTO regulation | No for ≤ 50 kg - under EVIDA exemption |
E-Motorcycle (no pedals) | 2 | mostly > 50 kg | Yes (if used on public roads) | Yes |
E-trike | 3 | 85–1,200 kg (based on DOE database)** | Yes (if used on public roads) | Yes |
Light Electric Vehicles (LEVs) are any EVs weighing 50 kg or less--most 2-wheelers will fall under this category--and must be exempted under EVIDA (Electric Vehicle Industry Development Act) to be registered. LTO also used to have LEV users exempted from getting a license too, except when they issued AO-AVDM 202-044 last year, requiring all EV users, including LEV users, to have a driver's license when using LEVs on "public highways." (Who uses the term "public highways" anymore? Weird guys. Most highways in cities are urban roads anyway, since speeding on a highway is not exactly achievable anymore.)
Again! Under EVIDA, Light Electric Vehicles (LEVs) which are below 50kg are exempt from registration. Licensing of the user or rider was also exempted under the 2021 version of the LTO administrative order above, until it wasn't.
At the same time, some users and sellers of E-Motorcycles and E-Trikes inapproriately promote their EVs as being exempt from registration and licensing under EVIDA (as if they have no concept of what a 50-kg sack of rice looks like). Most e-trikes and e-motorcylces exceed that limit, and thus fall under motorcycle-with-sidecar or battery-electric vehicle classifications for registration.
The problem: numerous single-seat, slower, and lighter e-motorcycles and e-trikes--which are safely used on public local, city, and national roads--are now at risk of being impounded as if they were unregistered motorcycles and tricycles, even though their safety and operational profiles do not align.
What the Data Shows: Not All E-Trikes Are the Same
Using a 2024 SafeTravelPH's analysis of 44 accredited E-Trike models found in the official DOE-EVIDA information hub, we identifed three distinct clusters/types based on safety risk factors (tipping, weight, speed, seating capacity, dimensions, power):
E-Trike Cluster Type | Typical Weight | Height–Width Profile | Appropriate Operating Space |
Cluster 1: Lighter & Slower E-Trikes, single-occupancy/two-seater | 85–435kg | Highest tipping risk | Bike lanes / dedicated paths, 20 kph max |
Cluster 0: Mid-size, private-use | 520–800kg | Lower tipping risk | Urban roads/ Vehicle Drive Lanes, not on protected bike lanes, regulated speeds, drivers and vehicles |
Cluster 2: Heavy cargo/ Multi-seater utility E-Trikes | 985–1,260kg | More stable | Shared with Vehicle Drive Lanes, regulated speeds, drivers and vehicles |
So, there are e-trikes and e-motorcycles that can use the separated bike lanes for human-powered bikes and power-assisted e-bikes, as long as they do not exceed 20 kph by-design to reduce crash and injury risk with respect to other lighter bike lane users.
Heavier e-trikes, due to their height-to-width ratio, have a reduced risk of tipping and can be safely operated on roads alongside other motor vehicles. Also, because they can transport more passengers, other drivers must exercise caution around e-trikes, as these vehicles are slower and have less acceleration power.
Safety First: Science Must Guide Policy
We can also utilize the available mass/weight and occupancy data on E-Bike and E-Trike products and their classifications, applying simply the kinetic energy equation (KE = ½mv²) as a safety metric. The main concept is that the heavier and faster the vehicle, the greater the safety risk it poses to other road users during a crash, particularly pedestrians and cyclists, who are the most vulnerable "elements" on the street, unlike cars, streetlights, barriers, etc.
Kinetic Energy of A Bike Lane User (65kg person on a 15 kg bike)
Speed (km/h) | Gross Mass (kg) | KE (Joules) |
15 | 80 | 9000 |
20 | 80 | 16000 |
25 | 80 | 25000 |
30 | 80 | 36000 |
Determined Speed Limits for LEVs and sampled small E-Trikes carrying a single 65-kg driver/user, with reference to the same/equivalent Crash Energy that a speeding cyclist will impact a pedestrian; i.e., a pedestrian will not suffer serious injuries when hit by these modes at these speeds.
Reference Bike Speed (km/h) | LEVs (50 kg) | E-Trike A (85 kg) | E-Trike B (115 kg) | E-Trike C (240 kg) |
15 | 12.79 | 10.95 | 10.00 | 7.68 |
20 | 17.06 | 14.61 | 13.33 | 10.24 |
25 | 21.32 | 18.26 | 16.67 | 12.8 |
30 | 25.58 | 21.91 | 20 | 15.36 |
We can see that, when loaded, and relative to the potential shared use of the road with cyclists and pedestrians:
A 50 kg LEV can safely travel up to ~26 kph
An 85 kg light e-trike or any EV should be limited to ~22 kph;
240–1,200 kg heavier e-trikes should not mix with walking/cycling road spaces if they need to speed up to more than 20 kph.
In his statements, Rep. Ridon highlighted how private-use e-bikes and e-trikes have “democratized transportation for marginalized communities” by providing low-cost, flexible mobility for short trips--from fetching children from school to buying goods at local markets. For many families, these E-Bikes/E-Trikes have become essential for daily errands and income-generating activities.
Impounding them especially without clear alternatives or safe infrastructure (like segregated bike/light mobility lanes) will disproportionately affect those least able to absorb the cost or disruption. It risks pushing people back toward low-quality transport options or forcing them to rely on more expensive paid rides.
(This article will not preach to the choir why heavier and faster cars are the main cause of our deadly road problems.)
What Mobility Advocates Propose Instead
Rather than blanket bans or impounding, mobility advocates urge:
A clear distinction between e-bikes (two-wheel LEVs), other LEVs, e-motorcycles, and e-trikes (three-wheelers), with regulations tailored to each category’s safety and usage profile.
For example, slower LEVs and even non-LEVs, but lighter three-wheelers/four-wheelers that are for a single occupant, should be allowed to use the bike lanes.
Recognition that light electric vehicles under 50 kg (LEVs) should continue to be exempt from heavy registration and licensing burdens, per EVIDA principles of promoting low-barrier EV usage.
Investment in appropriate infrastructure: segmented bike lanes, safer sidewalks, and road designs that accommodate low-speed EVs.
Focus on regulating for safety and equity, rather than suppressing mobility access for vulnerable communities.
The planned impounding of e-bikes and e-trikes raises serious questions not only about legal authority but about whose mobility is being prioritized. What is framed as a regulation for road safety may end up limiting access for exactly those people who rely on smaller electric vehicles for daily transport.
If transport policy is truly about inclusive mobility, then LEVs must be regulated with nuance and equity in mind--not penalized through blanket bans and confiscation. Upholding EVIDA’s intent means ensuring LEVs remain accessible, affordable, and safe, especially for those who need them most.
Final Thoughts
In practice, many heavier E-Trikes, such as the one depicted below, are quite simple to learn to operate (ask your Bunso, Tita, Lolo, Lola, and Mama). However, this does not mean that they do not pose safety risks to other road users. Meanwhile, the ease of access to both officially approved and informally distributed E-Trikes complicates the understanding among the public and government officials regarding how these vehicles can be integrated into our transportation system.
Improving the safety reputation of E-Trikes starts with addressing the realities behind current road behavior. Many riders today operate without formal training, which contributes to public mistrust and crash risks. Targeted education programs delivered through LGUs that already regulate local mobility (and schools!) can ensure even non-professional users develop essential road safety habits.
Complementing this with enforceable vehicle safety standards from DTI-DOE-DOTr (covering lighting, braking, and stability) and public campaigns highlighting responsible use can help shift perception and build confidence in LEVs and e-trikes as legitimate mobility options. When people understand that safe, well-regulated LEVs and e-trikes support mobility, livelihood, and sustainability, acceptance rapidly grows.
At the same time, safe integration into existing traffic requires a smarter and more nuanced approach to road sharing. Lighter and slower e-trikes that align with bicycle speeds can be permitted in protected bike or shared use lanes, provided speed limits and behavior are properly enforced--while larger, faster, and heavier e-trikes should operate on regular traffic lanes or dedicated facilities.
Clear lane design (ROAD DESIGN >>> ROAD SIGNS), appropriate classifications, safe products by-design, and consistent enforcement will minimize conflicts with cyclists and pedestrians. When safety training/education (for all users including motor vehicle drivers), engineering standards, and road-use policies move together, LEVs, e-bikes, e-motorcycles, and e-trikes can transition from being seen as road obstacles to becoming a practical and safe part of the Philippines’ evolving urban transport ecosystem.
