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Type Approval Track Record & Case Studies

Two cases that started with "there's no precedent, so it can't be done," and moved forward as we checked the basis of the rules and confirmed them through the proper channels. Neither involved confronting anyone.

Case 1 / 2026

Type approval applications for vehicles with saddles longer than 35 cm were not being accepted.

The situation

In 2026, when a type approval application was about to be made for an e-bike with a long saddle, the testing body said: "Vehicles with saddles longer than 35 cm cannot be accepted. Please make the saddle 35 cm or shorter when applying."

The long saddle is central to the design of this vehicle. Shortening it as requested would change the character of the vehicle itself. So we first set out to find where this "35 cm" came from.

What happened

  1. "We can't accept it because the saddle is over 35 cm."The testing body asked that vehicles with saddles longer than 35 cm be brought within 35 cm when applying.
  2. We researched the underlying standardThe basis was the standard for type approval of standard bicycles, set out in a National Police Agency circular. We also looked into why it was being applied to power-assisted bicycles, and how Article 57, paragraph (2) of the Road Traffic Act relates to prefectural rules.
  3. We checked with the JTMTAWhen we asked the Japan Traffic Management Technology Association (JTMTA), it replied that this practice was based on guidance from the National Police Agency.
  4. We made an inquiry to the National Police Agency through a former member of the National DietBecause the question concerned the standard itself, we made an inquiry to the National Police Agency through a former member of the National Diet.
  5. The National Police Agency explained its viewThe National Police Agency explained that 35 cm is a test method used in type approval for standard bicycles, and that not meeting this standard does not in itself mean a violation of the Road Traffic Act. (The vehicle must still separately meet the standards for power-assisted bicycles. A vehicle that is not a standard bicycle differs in some respects; for example, it cannot be ridden on sidewalks.)
  6. The JTMTA clarified how it handles such applicationsThe JTMTA clarified that applications solely as power-assisted bicycles would be judged case by case and accepted after confirming the National Police Agency's view. Applications that also cover standard bicycles are handled as before.
  7. The JTMTA sent external view drawings to the National Police Agency for confirmationThe JTMTA sent external view drawings of the vehicles to be applied for to the National Police Agency, and received a reply that there was no problem with applications as power-assisted bicycles.
  8. Type approval applications accepted, starting with models whose documents were completeThe JTMTA informed us that it would accept type approval applications for models as soon as their required documents were complete. As of November 2026, type approval test applications have been made for six models, five of which have saddles longer than 35 cm.

We didn't get here by confronting anyone. We checked the rules one by one, and a proper path emerged.

Where this case stands now

"Accepted" here means that the type approval applications were received for processing. It does not mean type approval was granted. These vehicles are now heading into testing.

What we did in this case

  • Traced the basis for "cannot be accepted" back to the wording of the standard
  • Asked the testing body for the basis of its practice, and referred the question about the system to the competent government authority
  • Recorded each step of the process and organized it so that all the bodies involved could decide on the same premises
Facing a similar situation? Contact us
Case 2 / 2022 (Reiwa 4)

We confirmed whether tandem (two-person) riding is permitted in Hyogo Prefecture.

Our starting point

How many people may ride a bicycle is set by each prefecture's Public Safety Commission in its rules, under Article 57, paragraph (2) of the Road Traffic Act. In other words, the treatment of two-person riding is not uniform across Japan; it differs from prefecture to prefecture.

What we looked into

At the time we checked in 2022 (Reiwa 4), Article 7, item (i), (a), (e) of the Hyogo Prefecture Road Traffic Act Enforcement Regulations (第7条第1号ア(オ); rules of the Hyogo Prefectural Public Safety Commission) covered "bicycles equipped with one riding device for use by a person other than the rider." This provision did not state that the rear seat must have pedals.

What we confirmed

In 2022 (Reiwa 4), we showed the vehicle's structure and confirmed the matter with the National Police Agency and the Hyogo Prefectural Police through a then-serving member of the National Diet.

The answer

Within Hyogo Prefecture, a bicycle equipped with a riding device separate from the rider's may be ridden by two people on public roads. There is no limit on the number of pedals.
However, whether the seat on an individual vehicle counts as a "riding device" is decided by the Hyogo Prefectural Police case by case.

What we did

Based on this answer, we prepared a vehicle built on a type-approved power-assisted bicycle, fitted with a rear seat modeled on the safety standards for two-wheeled vehicles (a rear carrier serving as a grab bar, and tandem footrests).
Note: A vehicle with a rear seat may not count as a standard bicycle (and cannot be ridden on sidewalks).

What it led to

The experience of examining the structure of the laws and regulations at that time became the foundation for researching the basis and making inquiries in the 2026 issue of saddles longer than 35 cm.

Note: Whether two-person riding is permitted differs by prefecture. This confirmation concerns treatment within Hyogo Prefecture only. Whether an individual vehicle can be said to have a "riding device" requires a decision by the Hyogo Prefectural Police. The rules may be amended; please check the current treatment with the Hyogo Prefectural Police.

We go and check what lies beyond "no precedent."

What we did in these two cases was not special negotiation. We simply looked into which laws and regulations each standard or practice was based on and what it was meant to confirm, and checked with the proper channels one by one.

Even when told "there's no precedent, so it can't be done," we don't let it end there. We see ourselves not as "paperwork handlers," but as a bridge between regulations and engineering.

We also write about our type approval work on the Zaki's Garage blog (in Japanese).

Read the blog

Stuck in front of a similar barrier?

Even if you don't know why you were told your application "cannot be accepted," start by telling us about your situation. We begin by checking the basis.

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