(with apologies to 2 Unlimited)

ANEC, the European Consumer Voice in Standardisation, welcomes the European Commission decision to set sound levels in Personal Music Players (PMPs) that are limited by default. This was ANEC’s wish, bearing in mind it is difficult for consumers to know the decibel levels at which they are exposing their hearing, and that younger consumers tend not to be receptive to cautionary measures. However, we believe the decision not to set an absolute maximum sound limit (100dB(A)) leads to a crucial omission, despite such a limit already being law in some European countries. We are also disappointed that the decision does not pay special attention to PMPs designed to be particularly appealing to children.

The Commission has decided a PMP must limit exposure to 80db(A) to 40 hours per week, and exposure to 89db(A) to 5 hours per week. Higher exposure levels will be permitted provided they have been intentionally selected by the user and the product incorporates a means to inform the user of the risks.
“ANEC is particularly concerned by the risk posed by personal music players to children, the most vulnerable user group” says Stephen Russell, ANEC Secretary-General “We think child-appealing PMPs need to feature far lower maximum limits, ones at which the risk of damage to a young child’s hearing is considered negligible, regardless of how long the child listens to the music player. Furthermore, we need to be convinced that the solutions to be used by manufacturers to limit exposure cannot be easily circumvented. At present, some 10 million European users of personal music players are placing themselves at risk of permanent hearing loss, many unknowingly. That has to change.”

ANEC also questions the value of warnings as a means to encourage consumers not to risk hearing loss through excessive exposure to high sound levels. Although we recognise that consumers should be adequately informed about the risks posed by the products they buy, warnings and labels are increasingly used as substitutes for requiring a manufacturer to put safe products on the market, thus shifting the burden of protection on to consumers.

“Warnings must complement and not replace safety requirements” added Stephen Russell. “Manufacturers must not be released from their obligations to ensure PMPs do not present excessive and avoidable risks to consumers.”

29 September 2009

European Association for the Co-ordination of Consumer

Representation in Standardisation, AISBL Av. de Tervueren

32, box 27 – B-1040 Brussels, Belgium - phone +32-2-743 24 70 - fax +32-2-706 54 30

e-mail: anec@anec.eu - internet: www.anec.eu