Hi everyone! Keen to add my input as I am sure of what the rules are though they are a bit muddled it hopefully will make some sense
Basically, any e bike that Meets the EPAC rules is classed as an EPAC bike. The road traffic laws, for EPAC bikes and normal pedal bikes are the same, so you can ride an EPAC bike anywhere you can ride a normal pedal bike (cycling lanes, on road, don’t need tax/insurance/mot etc) For an e-bike to be classed as an EPAC, the technical rules are 1. 15.5 mph max assisted speed 2. 250w motor maximum and 3. Must have pedals that are capable of propelling. If it breaks any of the three rules listed then it is regarded as a moped. The use of a throttle is where it gets confusing, but you can have a full twist throttle and it still can count as an Epac! See next paragraph
Where it does get confusing is the 6 km/h throttle rule. Simply putting it, the 6km/h throttle has nothing to do with whether an E-bike is classed as an EPAC or MOPED. The 6 km/h throttle rule only affects whether the EPAC has to be type approved or not. Type approval can apply to EPACs too, it is not specifically for motor vehicles.
If you have an EPAC where the the thumb throttle is limited to 6km/h without pedalling (start assist mode) then the Epac is excluded from type approval, however, if you have an EPAC where the throttle can go faster than 6km/h without pedalling, then the e bike is still classed as an EPAC but has to be type approved as well to be fully road legal
The introduction to EN15194, states “This European Standard has been developed in response to demand throughout Europe. Its aim is to provide a standard for the assessment of electrically powered cycles OF A TYPE WHICH ARE EXCLUDED FROM TYPE APPROVAL BY REGLATION NO168/2013” The Bold writing is the key point. After that sentance, later on in the document, it lays down technical requirements for the thumb throttle, limiting it to 6km/h when used alone, and is known as start assist mode. So what en 15194 says with regard to the throttle, is that a 6km/h one excludes the EPAC from being type approved , not that the 6km/h throttle is an EPAC law.
For clarity The only rules that affect whether an e bike is an EPAC or moped are the ones listed in my first paragraph paragraph (point 1 - 3) If any of these rules are broken then the e bike is a moped.