California AB 2346, signed into law September 30, 2026, imposes a set of new obligations on e-bike manufacturers, distributors, and retailers. Here is what the law requires and key compliance dates.
What the law requires of the supply chain
The law imposes two categories of obligation: disclosure and labeling requirements, which are operative now, and hardware requirements, which take effect January 1, 2029.
On the disclosure and labeling side, manufacturers and distributors must permanently affix a label, in a prominent location, to each electric bicycle, printed in Arial font in at least 9-point type, showing the bicycle’s classification number, top assisted speed, and motor wattage. This is a product-level requirement; it applies to every unit and must be addressed at the manufacturing or distribution stage before goods reach retail.
The statute, while not defining “seller” and “distributor,” mandates that both must deliver a written disclosure at or before the point of sale covering the bicycle’s classification, maximum speed, continuous and peak wattage, applicable age restrictions, helmet requirements, a written description of California’s e-bike laws, a link to the CHP’s safety and training program, and a recommendation that riders under 16 should not exceed 15 mph. That is a model-specific disclosure, not a one-size-fits-all form, which means retailers carrying multiple classes and models need a systematic process to generate accurate disclosures across their inventory.
Sellers and distributors must also separately provide a disclosure in 12-point type warning that it is against California law to tamper with or modify an e-bike to change its speed capability, and that doing so may trigger requirements for an M1 or M2 motorcycle license endorsement, DMV registration, and motorcycle insurance.
On the hardware side, beginning January 1, 2029, all Class 2 electric bicycles manufactured, sold, or offered for sale must be equipped with a speedometer. All electric bicycles manufactured, sold, or offered for sale on or after that date must also carry an integrated or detachable front lamp emitting white light visible from 300 feet and a rear lamp emitting red light visible from 500 feet behind. Note that “offered for sale” likely captures online listings directed at California consumers, not just physical in-state inventory.
Penalties
Violations of the disclosure and labeling requirements come at a cost: a first conviction carries a fine of up to $500—with multiple first-offense sales counting as a single violation—a second conviction within three years up to $750, and a third or subsequent conviction within five years up to $1,000.
Planning for 2029
The disclosure and labeling requirements are operative now. The hardware mandates — speedometers on Class 2 bikes, front and rear lamps meeting specific visibility standards — apply to products manufactured, sold, or offered for sale on or after January 1, 2029. For manufacturers sourcing or producing inventory for global markets, that cutover requires product specification changes that take time to work through a supply chain.
Prudent distributors should confirm whether their supply agreements require California-compliant hardware well before 2028. Companies that handle these transitions well build their compliance frameworks early, while the requirements are clear and the timeline is forgiving.
If you have questions about how AB 2346 applies to your products or sales operations, the Transportation attorneys at Crowell & Moring are available to help you work through it.