Over the past years, Ceemet has been preparing for a review of the Electromagnetic fields (EMF) Directive, in order to make it proportionate and simple. Whereas some progress has been achieved, we are still concerned that the proposed Directive may unintentionally prohibit processes that do not cause adverse physical effects. The Directive has to be workable.

• The proposal does not include enough information regarding how to use the values;
• There is confusion regarding the use of references to CNS (central nerve system in the head) and PNS (peripheral nerve system in the whole body, including limbs and hands), which results in contradictions on the health and safety requirements. In concrete terms, this could result in the prohibition of the manual operation of a series of commonly used welding equipment, without any benefits in terms of protecting the health and safety of workers;
• Current information regarding measurements, level of exposure and standardisation is based on the previous versions of ICNIRP recommendations. There is currently very little information that is based on the updated ICNIRP recommendations;
• There are errors in annex II (between 20 and 100 KHz). The action values for magnetic fields between 20 and 100 KHz do not correspond to ICNIRP recommendations, they are not justified, and thus have to be corrected.
• The proportionality of the Directive is not ensured, it is crucial that the due flexibility provided by article 3.6 is maintained.