In connection with the Trialogue process underway, a broad industry alliance wishes to present our view relating to the transposition date of the new ElectroMagnetic Fields (EMF) Directive.

• In order for businesses and notably SMEs, to adequately protect the health and safety of workers against electromagnetic fields, it will be necessary for them to have the practical guide (see Article 13) available to them, when they are preparing to implement the Directive.
• We note in the first paragraph of Article 13 “The Commission shall draw up practical guides before [the date of transposition] in order to facilitate the implementation of this Directive”.
• We consider that any decision on the transposition date should allow a period of a minimum of 18 months between the publication of the practical guide and transposition to provide sufficient time for employers to put in place all the provisions of the Directive.
• Therefore, if the practical guide takes, for example 2 years, to prepare from the time the Directive comes into force this implies that a transposition period of no less than 3 and a half years will be needed. Preferably 4 or 5 years should be given so as to allow effective implementation of the Directive by employers.