GRB 61 01e
GRB 61 01e
GRB 61 01e
Transmitted by the expert from the Netherlands (61st GRB, 27-29 January 2015,
agenda item 9)
Johan Sliggers, Policy Coordinator Noise, Ministry of Infrastructure and the Environment,
P.O. Box 20901, 2500 EX The Hague, The Netherlands; [email protected], tel.
+31 6 5288 5270
Introduction
There is at present no noise label for motor vehicles. However, this may change. The EU
Regulation on the sound level of motor vehicles1 calls on the European Commission to
assess labelling conditions for air and noise pollution levels, and, if appropriate, to submit
a legislative proposal to the European Parliament and the Council (see Appendix I).
A noise label for motor vehicles has various advantages. It would enable consumers to
take noise production into account in their purchasing decisions. It would also raise
consumer awareness of the noise levels produced by, and experienced within, vehicles.
Moreover, the label is likely to encourage manufacturers to develop quieter motor
vehicles.
A vehicle produces external noise which is experienced as nuisance. There is also interior
noise, experienced by the occupants of the vehicle as a determinant of acoustic comfort
and quality. A noise label should integrate both types of noise.
Existing EU Regulations establish maximum noise limits (per category of vehicle) for
motor vehicles1 and road noise from tyres2,3. There is also an ISO standard which defines
the noise levels within a vehicle4. All can provide a basis for a noise labelling system for
vehicles.
This paper is a discussion document which explores preconditions for a noise label
system for vehicles and offers an initial model for a noise label for vehicles. After
establishing a number of basic principles, it will describe a labelling system for (private)
cars which relies on the award of points for interior noise, powertrain noise (engine and
exhaust system), and tyre noise. An example is given for a fictitious car. The components
of a possible labelling system for other vehicle categories are then listed, followed by a
consideration of the value and desirability of a noise label for these vehicle categories.
The final section presents a number of discussion points.
This paper is intended to inform the European Commission of a possible model for noise
labels for vehicles. The paper will also be sent to representatives of the EU and ECE
member states and to the European Parliament.
Basic principles
For a consumer about to purchase a new car, the acoustic aspect of greatest relevance
will be interior noise. Manufacturers are aware of this fact; they include interior noise (or
the lack thereof) as a selling point in their promotional material. Exterior noise is seen as
a subsidiary factor, although its significance may increase if manufacturers are required
to include information about powertrain noise production in the vehicle’s technical
specifications, and dealers are obliged to display that information at a prominent position
at the point of sale (further to Article 7 of the Regulation on the sound level of motor
vehicles1). It seems likely that consumers will opt for a quiet(er) vehicle when this
information is made more readily available. Exterior noise could also be a part of the
purchasing decision, if only as a sort of ‘feel-good factor’: “Yes, I do drive a car but it is a
quiet car”.
In the case of the other vehicle categories, the situation is more obvious for they usually
emit more noise. The primary considerations when purchasing a commercial vehicle such
as a van or truck are generally price and running costs. Noise is also an important factor,
however, especially if the vehicles are to be used in residential areas (e.g. refuse
collection vehicles and delivery vans) or to stock shops in city centres. The driver’s
exposure to noise will also be a consideration, particularly in the case of heavier vehicles
such as trucks and buses. Many transport operators already apply interior and exterior
noise levels as selection criteria when inviting tenders.
Interior noise is not taken into account in the ‘Whole vehicle type approval’.
Manufacturers are therefore not obliged to provide this type of information, and neither is
there any statutory limit for interior noise. Nevertheless, manufacturers offer
comprehensive information about interior noise, since no one wants to buy a noisy car.
Reviews in journals and magazines also devote attention to interior noise. However, this
type of information is not as readily available at the point of sale as that relating to fuel
consumption or CO2 emissions (energy label). Consumers must ask for it, or must make
their own assessment by taking a test drive, reading the reviews, and so forth. In short,
there is room for greater transparency. A noise label will give noise more prominence as
a criterion and will allow the consumer to make a well founded choice for a (more) quiet
car.
Assuming that interior noise is indeed an important criterion for the consumer, it will be
an essential component of the label. For society, however, external noise is the main
consideration. To meet the requirements for both interior noise and exterior noise, it
seems appropriate to give the two types of noise equal weight, whereby the label will
integrate both.
The external noise produced by a vehicle is a significant source of noise nuisance. The
exterior noise level is the product of powertrain noise (from the engine and exhaust
system) and tyre noise (caused by the contact between tyre and road surface). In the
case of cars, powertrain noise is dominant at speeds below 25-30 km/h, while tyre-road
noise becomes dominant at higher speeds. In the other vehicle categories, such as vans,
trucks, and buses, the ‘transition point’ occurs at a somewhat higher speed. Both types
of noise are already subject to European legislation which can form a useful point of
departure for a labelling system.
The Regulation on the sound level of vehicles1 and the Regulation on general safety of
motor verhicles2 are concerned with exterior noise. However, powertrain noise and tyre
noise also affect the interior noise level. A simple noise label can rely on the limits and
measurement values established by the two EU Regulations. To keep things as simple as
possible, the label could be based on a points system which attaches equal importance to
interior noise, powertrain noise, and tyre noise. This answers the requirement of giving
equal weight to both interior noise and exterior noise in the assessment and resultant
information. After all, powertrain noise and tyre noise can be heard inside the vehicle,
too.
Last but not least, it is essential to ensure that a noise label is readily understood by the
general public. In marketing terms, it must be KISS-compliant (‘Keep It Stupid Simple’).
At the same time, it must offer enough information to support a considered choice, which
will entail more than merely a colour or letter coding. The entire development process of
noise labels must be kept as simple as possible, which can be achieved by drawing on
the existing EU Regulations and the standardized test for interior noise of ISO 51284. The
development of new systems would demand much time, effort, and expense. This direct,
simple approach will avoid unnecessary bureaucracy, administrative burden, and
associated costs. The member states could opt for self-regulation by the market itself,
with ‘light’ enforcement measures.
The principles outlined above underpin this initial model for a noise label, offered as a
‘limbering-up exercise’ and to encourage further thought. It describes a simple points-
based rating system for private cars. A comparable label could be developed for vans,
buses, and trucks, which are considered separately in the section ‘Other vehicle
categories’.
Interior noise increases with speed and the number of revolutions of the engine at which
the vehicle is driven. At present, all manufacturers measure interior noise at a ‘steady
speed’ in accordance with ISO standard 51284. A listing of the recorded noise levels for
various vehicles is provided by the Auto Decibel Database5. The sensitivity to speed as
well as the kind of vehicle, from runabout to sports car, are entirely as expected (with a
four-sigma distribution range from quietest to noisiest).
A noise label for cars could be based on a measurement at a steady speed of 100 km/h.
This is a constant cruising speed in top gear, at which it should be possible to listen to
music or engage in conversation. A baseline can then be set for the points scale, e.g. 71
dB. At present, there is no statutory limit for interior noise. The cumulative frequency
distribution shown in Figure 1 indicates that almost all passenger vehicles have an
interior level of 71 dB or less, hence the suggestion of adopting this as the starting point
of the scale. Table 1 shows a possible scoring system for passenger vehicles according to
all three types of noise.
Table 1. Points scores for the noise rating of passenger vehicles (category M11)
Type of noise 0 pts 1 pt 2 pts 3 pts 4 pts 5 pts
Interiora ≥72 dB 70-71 dB 68-69 dB 67-66 dB 65-64 dB <64 dB
Powertrain 72 dB 70-71 dB 68-69 dB 66-67 dB 64-65 dB <64 dB
Tyre 73-74 dB 71-72 dB 69-70 dB 67-68 dB 65-66 dB <65 dB
a
If the manufacturer fails to supply the necessary information, the lowest score (0 points) is awarded.
Figure 1. Distribution of measured interior noise levels for passenger vehicles5 (category
M1) at steady speed of 100 km/u
For powertrain noise, the noise label can use the limits established by the Regulation on
the sound level of motor vehicles1. For the noise label for cars (category M1), ‘Phase 3’
limits of the Regulation have been used, which will apply to all new vehicle types
produced after 1 January 2024 and to all vehicles sold from 1 January 2026. The M1
category in the EU Regulation is divided into four sub-categories which have upper limits
in a range of between 68 dB and 72 dB. The baseline for scoring powertrain noise is then
72 dB. Figure 2 shows the distribution of noise levels of passenger vehicles in the EU 6, as
measured during the monitoring period 2007-2010 using the method which will become
mandatory from 2016 onwards. The vehicles with best performance had a noise level of
64 dB. For vehicles in the category M1, the points system for powertrain noise could
therefore begin at 72 dB and run to 64 dB. Table 1 shows the possible rating system for
passenger vehicles according to the type of noise.
In this model for a car noise label, all passenger vehicles are to have a standard label
which relies on the same measurement methodology and scoring system, regardless of
size or class. It is to be expected that a ‘performance’ sports car will achieve a lower
score than a standard family car, and that this will be reflected by the label.
Figure 2. Distribution of test results for vehicles in category M1, as measured using the
new method (‘B’) established by the Regulation on the sound level of motor vehicles 1
(source: EU database6)
A score for tyre noise emissions can be awarded on the basis of the limits established by
the Regulation on general safety of motor vehicles2. All new tyres must meet the
requirements stated in Annex II of the Regulation. Passenger vehicles may be fitted with
tyres in category ‘C1’, in which there are five sub-categories, designated A-E, to which an
upper limit of between 70 dB and 74 dB applies. As shown in Figure 3, the majority of C1
tyres currently sold in the Netherlands fall into the 66-72 dB range7, with very few in the
73 dB or 74 dB range. This, in combination with the fact that new tyres have become
quieter in recent years, suggests that the scoring system could have a baseline of 72 dB.
Table 1 shows a model for a scoring system for M1 category vehicles according to all
three types of noise.
Figure 3. Distribution of noise label values for category C1 tyres sold in the Netherlands
in 20137
There is a robust database of information on the interior noise levels of a large number of
passenger vehicles. However, no comparable database for the other vehicle categories
can be found on the internet. In order to arrive at points ratings for these vehicles, it will
first be necessary to collect and collate the necessary information. Data on interior noise
levels does exist for all vehicles and is in the public domain: manufacturers include it in
their promotional materials.
When designing the noise label for passenger cars, a ‘steady speed’ of 100 km/h has
been chosen. For the other vehicle categories, a speed of 80 km/h seems more
appropriate. The interior noise level of these categories at 80 km/h is comparable with
that of a passenger vehicle at 120 km/h and is approximately 65 to 75 dB(A).
The interior noise experienced in a light commercial vehicle such as a delivery van is very
much dependent on whether the cab and cargo area are interconnected. If they are not,
the noise level is similar to that of a light-duty truck. Where the cargo area forms an
integral part with the cabin, the interior noise level is much higher, probably resulting in
a score of zero points for interior noise.
It is possible to award scores for the powertrain noise of other vehicle categories (N2-M3)
based on the emissions limits established by Phase 3 of the Regulation on the sound level
of motor vehicles1, for which distribution tables of test values can be derived from the EU
database6. These distribution tables (which date from the 2007-2010 monitoring period)
are shown in Appendix II. It should be noted that the distributions are distorted by the
small sample size of some vehicle categories, notably minibuses (M2) and light-duty
trucks (N2). The results for the other categories would also gain in value from a larger
sample. The points ratings for powertrain noise are shown by vehicle category in Table 2.
Table 2. Emission limits for motor vehicles (phase 3) of the Regulation on the sound level
of motor vehicles1, and possible points scores for powertrain noise in vehicle categories
M2-N3
Vehicle Regulation 0 pts 1 pt 2 pts 3 pts 4 pts 5 pts
category limits
M2 69-72 dB 72 dB 71 dB 70 dB 69 dB 68 dB <68 dB
M3 73-77 dB 77 dB 76 dB 75 dB 74 dB 73 dB <73 dB
N1 69-71 dB 71 dB 70 dB 69 dB 68 dB 67 dB <66 dB
N2 74-75 dB 75 dB 74 dB 73 dB 72 dB 71 dB <71 dB
N3 76-79 dB 79 dB 78 dB 77 dB 76 dB 75 dB <75 dB
With regard to tyre noise, there is ample and available information which can be used to
design a scoring system. Appendix III shows the distribution for C2 and C3 category
tyres sold in the Netherlands in 20137. The data may be considered robust enough to be
used for the purposes of producing a noise label for the other five vehicle categories M2-
N3. As in the case of passenger vehicles, the emission limits established by the
Regulation on general safety of motor vehicles2 provide a useful starting point. Table 3
shows a possible points rating system for tyre noise based on these limits.
Table 3. Emission limits for tyre noise of the Regulation on general safety of motor
vehicles2 and possible points scores to support a noise label for vehicles in categories M2-
N3
Type of Regulation 0 pts 1 pt 2 pts 3 pts 4 pts 5 pts
tyre limits
C2 72 and 73 dB 72-73 dB 71 dB 70 dB 69 dB 68 dB <68 dB
C3 73 and 75 dB 73-75 dB 72 dB 71 dB 70 dB 69 dB <69 dB
It may be concluded that there is indeed enough data to support the creation of a noise
label for the other vehicle categories alongside that for passenger cars. The question then
becomes relevant whether there is a need for it, and whether noise labels for the other
vehicle categories have an added value.
In fact, a noise label already exists for certain specific types of vehicle, such as concrete
mixers, concrete pumps, refuse collection vehicles, street cleansing vehicles, suction
vehicles, mobile cranes, and low-loaders, for the (external) noise they produce during the
work cycle. The limits and rating system which apply are established by European
Directive 2000/14/EC. There are also labels for the interior noise of machinery such as
excavators. In the Netherlands, trucks, lorries and transport vehicles are covered by the
(voluntary) ‘QUIETtruck’ certification system, also known as the Piek-Keur certificate8,
the use of which is promoted by means of financial incentives with the objective of
reducing environmental noise during the loading and unloading of vehicles during
evening and night-time hours. It may therefore be concluded that there is a (public)
requirement for information concerning the noise emissions of vehicles.
In the case of buses (category M3) and minibuses (M2), interior noise is clearly an
important consideration. At the same time, buses are a significant source of
environmental noise, particularly in the built-up area. In the Netherlands, and indeed in
many other countries, noise is an important criterion in the tendering and selection
process for public transport concessions. A noise label for these two categories will
enhance transparency with regard to how noise levels are measured and reported, thus
simplifying the selection process.
A final consideration is that most vehicles in the ‘other categories’ are driven by
professionals who spend their entire working day at the wheel. A low (or lower) level of
interior noise will enhance health, safety, and job satisfaction.
Taking all aspects into consideration, the question of whether noise labels for the other
vehicle categories will have any added value must be answered with a firm ‘yes’. The
societal necessity for it might even be greater than for passenger cars.
‘Clean, Quiet, and Economical’ – a noise label fits perfectly within society’s desire to have
cleaner, quieter and more economical vehicles on the roads. Alongside the ‘energy label’
which indicates a car’s fuel consumption and CO2 emissions, the noise label will inform
the consumer about the benefits of purchasing a quieter vehicle, enticing him or her to
do so. No less important is the effect that the label will have on manufacturers. If the
noise emissions of a vehicle and its comfort in terms of acoustic quality are given a
prominent place in promotional materials and at the point of sale, this can only
encourage producers to develop quieter vehicles. After all, no manufacturer wishes to
acquire a reputation for producing noisy cars.
This paper offers an initial model for a noise label for all vehicles, with specific reference
to the private car as purchased by the average consumer. A detailed example of a noise
label is given for a fictitious private car. A very similar system could be applied to the
other vehicle categories: buses, minibuses, vans, light trucks, and heavy-duty trucks.
The Regulation on the sound level of motor vehicles1 establishes six main vehicle
categories, three for ‘the carriage of passengers’ (M1-M3) and three for ‘the carriage of
goods’ (N1-N3). The model for noise labelling in this paper is based on there being a total
of six labels, one for each main category. Of course, it would be possible to create
separate labels for each sub-category and for each type of tyre. However, the resultant
plethora of individual labels will do little to promote transparency or simplicity. Also, a
high-performance sports car may then have a ‘quieter’ label than a family car, because
each is only compared against other vehicles in its own sub-category. This is a significant
shortcoming of the existing energy label for cars.
The scoring system of the model for a noise label in this paper has been designed in such
a way that very few current vehicles would qualify for the highest (i.e. quietest) rating.
This is deliberate: it ensures that there is room for improvement. Should noise emissions
show a significant decrease in future, it will be a simple matter to adjust the scoring
system accordingly. It is better to make the label itself dynamic than to add various
‘super’ ratings such as AA, AAA, A+, A++ etc., as has been done in the case of the
energy label for domestic appliances.
The perception of interior noise is very much dependent on the nature and acoustic
quality of that noise, its spectrum, frequency, pitch etc. Nevertheless, the labelling
system presented in this paper is based on the noise level (in the sense of volume or
intensity) because this is easier to measure and an ISO standard already exists. It also
satisfies the KISS principle: ‘Keep It Stupid Simple’.
A noise label for vehicles will support consumers’ purchasing decisions, allowing them to
opt for a quiet (or quieter) vehicle. It will also create opportunities for governments to
implement (fiscal) incentives to promote sustainability in the field of transport, perhaps
linking the label rating to the rate of road tax payable or the notional value of a company
car for the purposes of income tax. At the local level, it will be possible to restrict or
grant certain facilities to vehicles with a minimum label rating: access to an
environmental zone, reserved parking places, dedicated lanes, or exemptions to the
standard loading and unloading periods, for example.
A notable development in recent years has been the desire for quieter zones in the urban
area. To ensure that such zones can be enforced, all vehicles – not only new ones –
should have a noise label. The model described in this paper can be readily applied to
vehicles which are already on the roads, perhaps as part of the annual inspection.
Moreover, the standard inspection should be expanded to include the re-assessment of
noise emissions. It is possible that new tyres or a new exhaust have been fitted since the
noise label was issued, whereupon the rating may no longer be accurate.
The application of the labelling system to existing vehicles, together with the necessary
regulation and enforcement measures, will be a useful supplement to the statutory limits
which apply to new vehicles and new tyres. Those limits have been established in the
interests of safety and environmental responsibility. A vehicle is subject to normal ‘wear
and tear’ during use. An annual inspection, perhaps leading to the adjustment of the
label rating but certainly accompanied by the enforcement of the minimum standards,
will do much to reduce environmental noise.
The noise label presented in this paper integrates both interior noise and the exterior,
environmental noise produced by the tyres and the powertrain (engine and exhaust
system). It is, however, based on the assumption that consumers will attach importance
to interior noise. A label that is concerned solely with environmental aspects will take no
account of interior noise whatsoever. The Global New Car Assessment Programme
(GNCAP) and the Global Fuel Economy Initiative (GFEI) recently announced the intention
of developing a system to assess and quantify the environmental performance of cars:
GreenNCAP9. It seems appropriate for the GreenNCAP assessment to include both
components of exterior noise: powertrain noise and tyre noise. The approach presented
in this paper may prove a useful model.
Last but not least, consideration must be given to whether vehicle noise labels should be
introduced first or whether it would make more sense to move towards an integrated
environmental label straightaway. After all, a noise label for vehicles will be an adjunct to
the existing energy label and the label for tyres. Integration does not necessarily mean
an improvement. An integrated label may be so general that it provides little or no useful
information at all. Or it might be difficult and cumbersome to find out the information
behind such a general integrated label. The development of an effective noise label for
vehicles could be overshadowed and subsumed by the introduction of an integrated label.
For this reason, it seems advisable to gain some experience with a vehicle noise label as
such, and only later pursue integration if necessary and appropriate. That said, it may be
preferable to present the environmental information of the three labels (energy, noise,
and tyres) as a combined ‘Environmental Information Package’.
References
6. De Roo, F., Dittrich, M., et al.; VENOLIVA – Vehicle Noise Limit Values –
Comparison of two noise emission test methods – Final report; TNO report
MON-RPT-2010-02103, 30 March 2011
7. De Graaff, E.; Evolution of tyre noise emission over time and potential to update
the tyre noise limits; paper in preparation for UNECE/GRB, Sept. 2014
(http://www.unece.org/trans/main/wp29/wp29wgs/wp29grb/grbinf60.html)
9. http://www.globalfueleconomy.org/Documents/GreenNCAP_expression_of_interes
t_v6.pdf
Acknowledgements
Drafts of this paper were reviewed by several experts whose comments have prompted
various improvements. This does not necessarily imply that these experts endorse the
content, which remains the sole responsibility of the author. I acknowledge and thank the
following for their input:
P.J.G. (Pieter) van Beek M.Sc., Systems Engineer, TNO – Technical Sciences – Fluid
Dynamics / Acoustics and Sonar, P.O. Box 96864, 2509 JG The Hague, The Netherlands
D.F. (Erik) de Graaff M.Sc., Senior Consultant, M+P Consulting Engineers, P.O. Box 2094,
5260 CB Vught, The Netherlands
C. (Kees) van der Reijden, Senior Advisor, Rijkswaterstaat, P.O. Box 8242, 3503 RE
Utrecht, The Netherlands
E. (Erik) Roelofsen, Director, Dutch Noise Abatement Society, P.O. Box 381, 2600 AJ
Delft, The Netherlands
Article 7
Vehicle manufacturers and distributors shall endeavour to ensure that the sound level of
each vehicle in decibels (dB(a)), measured in accordance with this Regulation, is
displayed in a prominent position at the point of sale and in technical promotional
material.
In the light of the experience gained in the application of this Regulation, the Commission
shall, by 2019, carry out a comprehensive impact assessment on labelling conditions
applicable to air and noise pollution levels and on consumer information. The Commission
shall report on the findings of that assessment to the European Parliament and the
Council and, if appropriate, submit a legislative proposal.
Appendix II.
Distribution of test results for vehicles in categories M2-N3, as measured using the new
‘B’ method of the Regulation on the sound level of motor vehicles1 during the monitoring
period 2007-2010 (source: EU database6)
Appendix III.
Distribution of noise label values for category C2 and C3 tyres sold in the Netherlands in
20137