EGMF Position Paper on the Outdoor Noise Directive

Further to the evaluation of the Outdoor Noise Directive (OND), on 3 March 2021, the European Commission put forward two options for the future of this piece of legislation.

EGMF supports a revision of the OND Annex IIII to update the measurement methods, through a delegated act, rather than a full revision of the legislation. Although this approach will not solve all aspects to be revised, it will tackle the most urgent issue. It is necessary to update measure methods to better reflect technical progress in the industry and European standardisation.

Why does EGMF call to fix measure methods first?

1. Revising the OND Annex III through a delegated act will allow addressing the most urgent issue: outdated noise measurement methods, in a quicker and easier manner.
2. European resources and work on regulatory measures should support the recovery. Since a full revision process will take considerable time and a consume significant resources, we strongly question whether it would contribute to the EU recovery and support the competitiveness of our industry.
3. Considering the revision of OND measurement methods would take place in parallel to the revision of the Machinery Directive, this offers the opportunity to align references to standards. The revision of OND Annex III will contribute to the overall coherence and simplification of the EU legislative framework, in line with the EU Better regulation agenda.

Finally, the EGMF position paper provides some suggestions for the revision of measurements methods:

• listing references to up-to-date standards in Annex III amendment instead of detailed descriptions of test codes
• involving stakeholders in the drafting process of delegated acts to reflect the state of art of the standardisation work and assess impacts of changes
• updating only measurements methods when there is no impact on the measured noise value for equipment subject to noise limits (Article 12).