It is not a requirement of the legislation that it is stated from what I can tell - it is a obligatory to be able to sell within the EU?
I think only apple truly tested the limits by selling without acknowledging 99/44/EC. They payed about 3 millions Euro in Italy, something of similar in Netherlands and backpedaled very, very fast in Germany. In your case, the dealer will also be involved in the lawsuit.
On one of the forumslader pages it is talked about adding a capacitor on the input to tune efficiency. He uses 220uF (have to stay within the protected range because a 100v 220uF is too large!).
He uses several sets and switches depending on speed. Basically a discrete form of MPP-tracking.
Assuming you have the CE paperwork and include the mandatory state warranty into your terms... what about
german product liability ? Maximal fine is 85 million Euro, realistic fines in your case are about the value of the phone charged by the device or maybe the bikeframe if it goes all wrong. It is independent of product value and it applies by default. There are insurances against this, but they are only valid if the other paperwork is absolutely correct and documented. In practice, the british CPA should have similar worst case scenarios. I guess that's why you registered a Limited in UK?
And read
https://fahrradzukunft.de/archiv/ , the "Steckdose" series. Sending them a sample would help your case a lot.
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