No C 319/22 Official Journal of the European Communities 30. 11. 87 
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 (!) 
(87/C 319/07) 
On 27 April 1987 the Council decided to ask the Economic and Social Committee to deliver 
an Opinion, in accordance with Article 100 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 8 July 1987. The rapporteur 
was Mr Pearson. 
At its 248th plenary session on 23 and 24 September 1987 (meeting of 23 September) the 
Committee adopted the following Opinion unanimously, less 1 abstention: 
The Committee accepts the Commission's proposal subject to the following reservations: 
1. General comments 
1.1. The Committee accepts that an amendment to 
Directive 85/538/EEC to include motorized cylinder 
lawnmovers in the provisions for maximum permitted 
sound power levels is necessary because of barriers to 
trade due to varying regulations in the Member States. 
It further agrees that the maximum permitted levels in 
that Directive remain unchanged. It doubts however 
whether the proposed amending Directive, as drafted, 
will bring about the results which it is intended to 
achieve. 
1.2. The Commission proposes to introduce two 
alternative methods of setting the cutting mechanism 
of cylinder lawnmowers prior to sound measurement. 
Both however can create serious problems in terms of 
reproducibility. Cylinder mower manufacturers might 
as a result of the wide variance of results (Annex I) of 
these methods be forced to aim at average noise levels 
as much as 5 dB(A) below the permissible limit of the 
basic Directive to ensure that all production complies. 
This could entail a significant cost increase not warrant­
ed by any increased noise protection and would place 
cylinder mower manufacturers at a competitive disad­
vantage. The Committee therefore believes that the 
proposals can have a discriminatory influence against 
manufacturers of motorized cylinder mowers, thus 
recreating new barriers to trade in this sector. 
1.3. The Committee would like to clarify the 
impression given in the Commission's Explanatory 
Memorandum that this proposal is accepted by virtually 
all parties involved. The Commission omits to point 
out that the advice of the 'parties concerned' in the 
manufacture of cylinder mowers [ELMF and CEMA (2)] 
was not accepted (they were critical of the proposal) 
(!) OJ No C 113, 28. 4. 1987, p. 5. 
(2) ELMF = European Lawnmower Manufacturers Association; 
CEMA = European Committee of Associations of Manufac­
turers of Agricultural Machinery. and that the delegates who were not in agreement were 
from those Member States most vitally concerned. The 
Committee's proposals set out below could remove 
these difficulties without causing those Member States 
who already have existing legislation to make any 
change in their method of sound level measurement. 
2. Specific comments 
2.1. 6.2. Annex 1, Directive 84/538 
As all petrol-powered cylinder mowers have a land-
drive of necessity, the question of the speed at which 
they travel must be taken into account if they are to be 
tested under normal working conditions, as required in 
the basic Directive. The walking pace of an operator 
of 5 km/h in the Committee's opinion constitutes a 
reasonable pace in this context. The speed of the motor 
corresponding to this pace can be ascertained and 
readily given by the manufacturer. (This factor is not 
generally relevant to rotary mowers which normally 
operate at a constant full speed.) The Committee there­
fore suggests that an additional sentence be added to 
the second paragraph of 6.2. Annex 1 of 84/538/EEC 
reading as follows: 
'Petrol-powered cylinder mowers however shall be 
measured with a cutter and motor speed equivalent 
to a land speed of 5 km/h.' 
2.2. 6.1.3. Annex 1 Amending Directive 
In expanding on 1.2. above, the Committee notes that 
the Directive places the manufacturers in a position 
30. 11. 87 Official Journal of the European Communities No C 319/23 
whereby every lawnmower placed on the market must 
comply with the maximum sound power level permit­
ted. This means that repeatability of test results must 
be obtained in each Member State. Accurate reprodu­
cibility within the terms proposed in the Directive, 
however, poses particular problems for cylinder 
mowers: test results generally show a large range of 
variance (see Appendix 1) when the proposed alterna­
tive methods are used. Therefore the Committee con­
siders it necessary that a third alternative setting for 
the cutting mechanism prior to sound measurement be 
introduced into the Directive and consequently pro­
poses that a third indent be added to the proposed 
6.1.3. Annex 1: 
'The cutting mechanism shall be adjusted until the 
blades touch and then backed off until contact just 
ceases when the cylinder is rotating at the test speed.' 
Done at Brussels, 23 September 1987. 2.2.1. Studies show that a form of setting whereby 
this 'no contact' method is used presents the most 
appropriate noise level equivalent with normal working 
conditions whilst cutting grass. Indeed, the cutting per­
formance, life and efficiency of the cylinder cutting 
system depends on there being a satisfactory cylinder 
to cutting edge gap and not on direct blade to cylinder 
contact. 
3. In accordance with an earlier Opinion on lawn-
mowers (l) the Committee finds the proposed appli­
cation date of July 1 1988 unrealistic and proposes a 
2-year implementation date from the date of the 
Council's adoption of the Directive. 
(*) CES, 13 May 1987 (OJ No C 180, 8. 7. 1987). 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
No C 319/24 Official Journal of the European Communities 30. 11. 87 
APPENDIX 
RANGE OF SOUND POWER READINGS 
FOR DIFFERENT METHOD OF SETTING ON CUT 
PETROL 
IALL METHODS 
ELECTRIC - SET ON CUT BY 0.15 MM FEELER GAUGE. 
ELECTRIC - SET ON CUT BY PAPER 
ELECTRIC 
SET ON CUT 
NO CONTACT 
METHOD 
87 88 89 90 91 92 93 94 95 96 97 
dB(A) 
Source: Qualcast Garden Products Ltd.