1. 10. 79 Official Journal of the European Communities No C 247/19 
2.1.4. As the research institutes involved in the 
proposed programme are highly qualified, the proposed 
programme should not only lead to improvements in 
productive capacity and guarantee jobs for the workers 
in the industry, but should also benefit consumers in the 
Community by making available better products. The 
results of the research should also help to solve 
environmental problems and bring about a more efficient 
use of energy, raw materials and water. 
2.2. The Committee would point out that the 
proposed programme serves to complement the textile 
research programmes of the Member States but is at the 
same time closely linked to the latter programmes. The 
opportunity should therefore be taken to decentralize 
both in the monitoring of the programme and the 
distribution of the research findings in order to cut down 
on the administrative costs of the programme. 
2.3. The Committee notes that the funds earmarked 
for the management and coordination of the programme 
by the Commission are high in relation to the sums 
earmarked for the actual research work. The 
Commission is asked to examine this matter to see 
whether it would be possible to devote a greater 
proportion of the funds to expenditure on actual 
research work. 2.4. The Committee considers that workers should be 
adequately represented on the proposed management 
council. 
3. To sum up, the Committee approves the 
Commission's proposal, notwithstanding the 
aforementioned comments, for the following reasons: 
— the programme represents a specific attempt to 
achieve industrial cooperation at Community level in 
an important economic sector, 
— it is a programme which conforms with the 
Community's industrial policy for the sector and will 
not distort competition since the results of the 
research programme will be available to all firms in 
the participating countries, 
— close cooperation between the research institutes in 
the individual Member States will lead to a saving of 
resources, 
— the programme should make a real contribution 
towards carrying out adjustments in the textile and 
clothing industries and bringing about job security, 
consumer protection, protection of the environment 
and more efficient use of energy, raw materials and 
water. 
Done at Brussels, 17 July 1979. 
The Chairman 
of the Economic and Social Committee 
Raffaele VANNI 
Opinion on the proposal for a Council Directive on the approximation of the laws of the 
Member States relating to noise emitted by lawn mowers 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 86 of 2 April 1979, page 9. 
A. LEGAL BASIS FOR THE OPINION 
On 5 January 1979 the Council referred the abovementioned proposal to the Economic and 
Social Committee in accordance with Article 100 of the Treaty establishing the European 
Economic Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
170th plenary session held in Brussels on 17 and 18 July 1979. 
The full text of the opinion is as follows: 
No C 247/20 Official Journal of the European Communities 1. 10. 79 
THE ECONOMIC AND SOCIAL COMMITTEE, 2. Specific comments 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Article 100 
thereof, 
Having regard to the request made by the Council of the 
European Communities on 5 January 1979 for an 
opinion, 
Having regard to the decision taken by its Bureau on 
23 January 1979 instructing the Section for Industry, 
Commerce, Crafts and Services to draw up an opinion 
and a report on the matter, 
Having regard to the opinion issued by the Section for 
Industry, Commerce, Crafts and Services at its meeting 
held on 4 July 1979, 
Having regard to the report submitted by the rapporteur, 
Mr Masprone, 
Having regard to the discussions at its 170th plenary 
session held on 17 and 18 July 1979 (meeting of 17 July 
1979), Article 1 (3) 
The Committee proposes the following wording: 
'Agricultural and forestry equipment and tractor-
drawn, non-powered cutting units are excluded from 
this Directive.' 
It is necessary to add tractor-drawn units here, since with 
this type of equipment it is the tractor that determines the 
general noise level and not the grass-cutting unit. 
Article 2 
The Committee accepts the noise levels specified in this 
Article, subject to the comments made on the measuring 
method (see point. . .). 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously: 
1. General comments 
1.1. The Committee approves the Commission's aim 
in presenting this proposal. 
1.2. It is important that the provisions governing 
noise emissions should be aligned; diverging 
requirements in this area lead inevitably to higher costs 
for manufacturers selling on foreign markets, and these 
higher costs are then passed on to the consumer. The 
Commission has also been guided by environmental 
protection considerations in taking this action. Article 3 
Application of the new noise limits to the 600 or so 
models at present on the European market will call for a 
considerable effort on the part of the 60 or so 
manufacturers in areas such as research, engineering, 
tooling, tool-proving, testing and piloting of new models, 
and at least four years will be needed for this. One 
cannot set too short a deadline for the finding of 
technical solutions (to make this second reduction 
possible), without impairing the chances of success. 
In order to guarantee effective supervision of the 
application of the new limits, it is absolutely essential to 
lay down that these limits will apply only to lawn 
mowers produced (or imported) after their entry into 
force. 
1.3. The Committee is pleased that the Commission 
has found the right balance between noise, performance 
and price. As at present designed, lawn mowers cannot 
be made quieter without impairing performance or 
adding considerably to their price, as the example quoted 
in the report shows. 
1.4. The Committee suggests that in the proposed 
study, not only the noise annoyance as related to the 
sound power is evaluated, but also the noise annoyance 
due to other characteristics of the sound emission, such 
as the frequency spectrum. The Committee accordingly considers it vital to bring 
forward the date for the fixing of the new limits to 
31 December 1982 and to amend the end of the Article 
to read as follows: 
'. . . in Article 2, which shall apply to lawn-mowers 
produced or imported after 31 December 1986.' 
The Commission itself points out in the explanatory 
memorandum that a research effort will be required for 
optimum achievement of the objective set. The 
1. 10. 79 Official Journal of the European Communities No C 247/21 
Committee also thinks that the accuracy of the 
measuring method and the normal dispersion in the mass 
production of lawn mowers should be taken into account 
in fixing the new limits. 
The following text should therefore be added to 
Article 3: 
'In setting the new limits, account shall be taken of the 
results of new research, the dispersion that normally 
occurs in production, and the repeatability and 
reproducibility of the method of measuring the noise 
level.' 
Article 5 (1) 
If labelling is considered effective, a symbol would seem 
more appropriate than an inscription to enable lawn 
mowers conforming to the standards to circulate freely 
throughout the Community. 
The following sentence should therefore be added: 
'The inscription shall take the form of a symbol for 
lawn-mower sound emission in accordance with ISO 
standards.' 
For the sake of uniformity and the better identification of 
the origin and/or quality of Community goods, the 
Commission should also take steps to introduce a single 
EEC mark for all lawn mowers manufactured in the 
common market. 
Article 5 (3) (new) 
Since the manner of use has at least as much influence on 
the degree of noise nuisance as the sound power emitted 
by a lawn mower, the Committee considers that the 
following paragraph should be added: 
'The operating instructions shall include practical tips 
for minimizing noise nuisance due to the way a lawn 
mower is used.' 
These operating instructions could also include the 
following reminders: 
'— check the mower regularly for loose components; 
— keep the blade well balanced, 
— check with the neighbours when mowing annoys 
them least, — try to mow simultaneously with the neighbours, 
— do not mow when the background noise is low, 
— do not let the mower run unnecessarily (e.g. when 
emptying the grass catcher).' 
Article 7 
In order to limit the number of lawn mowers barred from 
the market because of a dispute and to enhance the 
effectiveness of the verification system, the Committee 
proposes that the following phrase be added at the end of 
this Article: 
'. . . before marketing and as soon as possible after the 
introduction of a new model.' 
Article 12 (1) 
Because of factors such as the effect of the weather on 
sales, it may not be possible to start production of the 
1982 model until November or December 1981 (in some 
years low sales may make it necessary to continue 
production of the year's model into September, October, 
November and possibly December in order to use up the 
stocks of components). To allow for this, the deadline for 
the application of the Directive should be put back to 
31 December 1981, which will also bring it into line with 
Article 3. 
General comments on the Annex 
The measuring method should be basically in line with 
the 'Third draft proposed test code for measurement of 
airborne noises emitted by powered grass-cutting 
machines' (ISO/TC23/SC13). It should, however, be 
simplified as much as possible, because the majority of 
lawn mower manufacturers are rather small enterprises, 
not equipped to do highly scientific complicated and 
expensive measurements in specialized laboratories. 
The measuring method should also be designed to ensure 
continuity with already existing and generally 
established measuring methods in Europe. Specifically, 
the measuring distance and measuring height should be 
equal to the ones used in current legislation and on which 
a large bank of industry data is based. This is necessary 
because measuring results cannot be 'translated' from 
one method to another by using theoretical conversion 
No C 247/22 Official Journal of the European Communities 1. 10. 79 
factors that do not apply to actual lawn mowers on an 
actual measuring site. 
For example, the sound power measured according to 
the Annex of the proposed Directive would be 
significantly higher than the sound power of the same 
mower calculated from the measuring results of the test 
method as used in existing German legislation. The data 
used to establish sound limits were all based on this last 
method. 
This discrepancy between the two methods has very 
serious implications. An analysis of 1978 model mowers 
on the German market e.g. shows 148 out of 149 
(100 %) models to comply with step 1 limits if the sound 
Done at Brussels, 17 July 1979. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Article 100, 
Having regard to the request made by the Council of the 
European Communities on 6 February 1979 for an 
opinion, power is calculated from the German test method, but 
only 114 (77%) would comply with the method as 
proposed by the Commission. 
To avoid these implications, the report accompanying 
this opinion provides a revised text for the Annex which 
ensures continuity with the German test method but 
which also provides for the application of the principles 
of sound power measurements according to ISO. 
The Committee considers it vital that this test method is 
used to control the step 1 limits of Article 2. When 
setting the step 2 limits of Article 3 the test method may 
be simultaneously harmonized with then-current ISO 
Standards. 
The Chairman 
of the Economic and Social Committee 
Raffaele VANNI 
Having regard to the decision taken by its Bureau on 
20 February 1979 instructing the Section for Industry, 
Commerce, Crafts and Services to draw up an opinion on 
the matter, 
Having regard to the opinion issued by the Section for 
Industry, Commerce, Crafts and Services at its meeting 
held on 4 July 1979, Opinion on the proposal for a Council Directive amending Directive 71/316/EEC on the 
approximation of the laws of the Member States relating to common provisions for both 
measuring instruments and methods of metrological control 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 42 of 15 February 1979, page 9. 
A. LEGAL BASIS FOR THE OPINION 
On 6 February 1979 the Council referred the abovementioned proposal to the Economic and 
Social Committee in accordance with Article 100 of the Treaty establishing the European 
Economic Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 170th 
plenary session held in Brussels on 17 and 18 July 1979.