8. 7. 87 Official Journal of the European Communities No C 180/11 
Opinion on the proposal for a Council Directive amending Directive 84/538/EEC on the 
approximation of the laws of the Member States relating to the permissible sound power 
level of lawnmowers(1) 
(87/C 180/03) 
On 14 January 1987 the Council decided to ask the Economic and Social Committee to 
deliver an Opinion, in accordance with Article 198 of the EEC Treaty, on the abovementioned 
proposal. 
The Section for Industry, Commerce, Crafts and Services, which was responsible for preparing 
the Committee's work on the matter, adopted its Opinion on 7 April 1987. The rapporteur 
was Mr Pearson. 
At its 246th plenary session (meeting of 13 May 1987) the Committee unanimously adopted 
the following Opinion: 
1. General comments 
1.1. The Committee understands the obligation for 
the Commission, to table, in accordance with the 
request of the Council of December 1984, the current 
proposal amending Directive 84/538/EEC on the per­
missible sound power level for lawnmowers. 
1.2. The basic Directive now being amended is based 
on the emission control principle. It sets a sound power 
level for lawnmowers: mowers exceeding this level can­
not be put on the European market. It is now proposed 
to amend this Directive with a requirement that has the 
character of an immission control: the sound pressure 
as measured at the ear of the sound recipient is fixed 
at 92 dB(A). Immissions are the sum of all emissions of 
a certain kind, after dispersion, physical interaction and 
degradation, as they affect the ecology and are, as far 
as sound is concerned, usually expressed as the sound 
pressure Lpa. The result however is confusion: the 
sound measurements in the Directive would be based 
on two different principles of which the dB numbers 
are not directly comparable. The Committee feels that 
the present proposal, as a result of using two control 
principles, will lead to confusion for the customer and 
limit the environmental effectiveness of the proposed 
measure. 
1.3. The Committee recognizes that the present 
Directive is intended to prevent barriers to trade at the 
point of sale for a particular group of lawnmowers 
— those having a seat attached with a cutting width 
exceeding 120 cm — rather than to limit the noise dose 
received by the operator. The limited scope of the 
amendment becomes apparent when bearing in mind 
that the basic Directive excludes inter alia motorized 
cylinder mowers and agricultural and forestry equip­
ment. 1.4. On the basis of the abovementioned comments 
the Committee questions the utility of the present pro­
posal: it would have preferred to see it integrated in a 
forthcoming proposal from the Commission dealing 
globally with the larger question of barriers to trade 
and noise emissions from lawnmowers of all categories. 
1.5. Though agreeing with the Commission that this 
particular noise category has to be enforced by local 
authorities, the Committee invites the Commission to 
initiate and support efforts at Community level aimed 
at informing the public as to the meaning of technical 
particulars used in describing noise, as to how to pre­
vent noise annoyance and not least, the consequences 
of exposure to excessive noise levels. 
1.6. Although the Committee recognizes that the 
requirements under Directive 84/538/EEC are appli­
cable as form 1 July 1987 it finds it unrealistic to expect 
the current proposal to become operative from that 
date. Many models will already be with the stockists 
for the coming spring-summer season and should be 
permitted to continue on the market. Likewise this date 
does not permit the individual Member States enough 
time to make the necessary amendments to national 
legislation. The Committee therefore proposes the nor­
mal two-year implementation period for the present 
Directive. 
2. Specific comments 
2.1. If the Directive is to be adopted by the Council 
in the present version the title of the proposed Directive 
should be changed in accordance with the comments 
under 1.2, as it refers only to 'permissible sound power 
level of lawnmowers' although both sound powers and 
sound pressure levels are now involved. 
(!) OJ No C 20, 27. 1. 1987, p. 2. 2.2. The proposed Directive states in Annex I that 
the methods of measurement are applicable to lawn-
No C 180/12 Official Journal of the European Communities 8. 7. 87 
mowers with a cutting width in excess of 120 cm 'and 
having a seat attached'. Article 1.1 of the new proposal 
should be worded accordingly, i.e.'... lawnmowers with 
a seat attached and with a cutting width ...' 
2.3. The 'mark model' label as shown in Annex II 
needs to be modernized to accomodate both sound 
power and/or sound pressure limit level of the machine. It should be specified that the label must be sited so 
that it is visible at the operator's position. 
2.4. The 'certificate of conformity' form as laid 
down in Annex II of the basic Directive (84/538/EEC) 
needs to be amended to include a line to accommodate 
the now introduced 'guaranteed sound pressure level'. 
Done at Brussels, 13 May 1987. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT