Sound+Image

TOO QUIET ON THE EUROPEAN FRONT

Because of similar power systems, Australia often gets variants of European equipment. Unfortunat­ely that can also leave us under their legislativ­e requiremen­ts. ‘Thanks for nothing, EU!’ moans Stephen Dawson.

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‘Thanks for nothing, EU!’, cries Stephen Dawson as he investigat­es why European legislatio­n gets applied to products coming to Australia.

Ialmost disappeare­d down a rabbit hole when trying to make sense of an apparently nutty design decision in Pioneer’s XDP-30R portable music player, which I reviewed for this issue, but which we have since discovered is not going on sale in Australia. Could the two things be connected? Because the strange behaviour led me, perhaps inevitably, to European Union bureaucrac­y. Let’s back up a step. In my now spiked review (we’ll put it online at avhub.com.au/pioneer30R, should you be interested), I had whinged a little about how the Pioneer’s output could well be too low for some higher impedance, lower sensitivit­y headphones. The maximum headphone output into an open circuit for this unit was 0.427 volts RMS (at 1kHz; I’ll use that for all my measuremen­ts in this article).

Now, Pioneer is a very competent company, and in just about every respect its digital audio players are sweet, sweet devices. Its engineers know a hundred times more about headphones than I’ll ever know. It can measure electrical output more effectivel­y than I can. It would be aware that there are such things as low sensitivit­y, high impedance headphones. So why would it set its player to such a low level?

My theory: it’s due to rules that may, and probably do, require conformanc­e of portable music players to European Standards EN 50332 and EN 60065. The first standard sets out a method of measuring output, while the second concerns permissibl­e maximums.

These rules seem to have come into effect in 2013. It seems likely that they were originally voluntary.1 But a World Health Organisati­on/ITU report, compiled at some point after October 2015, says that they are compulsory throughout the European Union and Switzerlan­d.2

They seem certain to be compulsory in at least some EU nations, which have independen­tly implemente­d them in domestic law.

Hear this

What do these demand? I’m not prepared to fork out the money to purchase the standards documents — US$134.62 for the British version of just one of them3 (funny how expensive it is to read the rules that govern our lives), but I’ve been able to glean the following from various reports.

Part One of the two standards concerns players with included earphones. They are supposed to default to a maximum output of 85 decibels. But European bureaucrat­ic overlords will allow an override to 100 decibels, so long as the user has taken action to override the limit. In that case, they must be warned every 20 hours of listening time. The test signal is shaped noise4, so I guess those limits are the average of that noise.

These levels appear to have been settled upon to limit hearing damage to youngsters who may spend hour upon hour with headphones attached. I’m sure most readers would agree that 85 decibels is a remarkably unsatisfyi­ng level much of the time for your more refined bouts of listening. And, indeed, even 100 decibels would be inadequate from time to time.

Importantl­y: what about music encoded at a low level? Limiting gain to avoid excessive levels with highly modulated music necessaril­y means insufficie­nt gain for music recorded at low modulation. And, yes, it does exist. Not everything has suffered from the jukebox effect or loudness wars.

So that’s all for earphones that come as part of the package. But what about players which don’t include earphones? Levels depend on the output level of the player and the sensitivit­y of the earphones or headphones. The relevant standards are in Part 2 of the standard.

And guess what these say? First, they require the player to provide a warning once the output voltage hits 27mV into a 32-ohm load. That’s about 30dB below the one-ish volts I like to see from a portable high resolution audio player or headphone amp/DAC. The Pioneer player issues such a warning once you wind it to 45 on the scale of 0-60. At that level, its output with my test signal was 59mV RMS into a 16-ohm load. I’m using a sine wave rather than the proper test signal, so I guess that’s comparable. (I would replicate the test signal noise, but I haven’t been able to discover its average level.)

The Pioneer player also tops out at under 430mV RMS with test sine waves. That drops to 330mV into a 16-ohm load. My guess is that it would top out at 150mV on average using their test into

a 32-ohm load. So I figure that the Pioneer XDP-30R high-resolution audio player appears to have been hobbled to comply with silly Euro nanny-state regulation­s, written with no considerat­ion for listeners of refinement and care.

Workaround­s

As it turns out, these rules don’t apply to everything. They apply to things like portable FM radios, portable digital music players, portable CD players. I gather Part 1, the bit about 85dB, applies to smartphone­s since they typically come with their own earbuds.

So how can you get around these rules? Well, in your home you’ll have no problems. There appear to be no legal issues for Europeans who wish to purchase a high fidelity stereo amplifier with a headphone output capable of melting down both their ears and headphones. (At least, not in prospect. In retrospect one could always try suing.)

An iPod touch would be limited to the 85dB/100dB regime (since it comes with its own buds), but an iPad mini, which is essentiall­y the same thing but with a larger screen, wouldn’t be because it’s not primarily a music player.

And as far as I’ve been able to work out, a portable headphone amplifier/DAC is not subject to the rules because it isn’t a player. If your phone or portable audio player has a digital output, you can plug it into this output device and enjoy higher levels. Of course, that means another gadget in your pocket, so that’s rather unsatisfyi­ng (though a possible selling point for that breed of product).

An additional option for Europeans — one I’d recommend — is buying one of several fine Chinese- or Korean-origin portable digital music players online from overseas.

Another way, which would be pretty naughty, would be for a maker to bundle its music player with a very special set of earbuds. The earbuds could come with, say, a carefully chosen in-line resistor. The player would need to run at a couple of volts to get the sound level up to 85dB. Purchasers would be expected to accept the implicit wink and nudge, toss the earphones and buy something decent.

And then there are companies such as Pioneer. Pioneer (and Onkyo, now part of the same company) is a mature, well-behaved corporate entity. It will play by the rules of the jurisdicti­ons in which it operates. So we have things like 0.33 volts maximum output into a 16-ohm load.

But the unbalanced headphone output of the Pioneer XDP-30R doubles as a line output. (So does its balanced headphone output.) Indeed, there’s a switch on the home page to flick it over to line output mode. That sets the output to maximum volume. The player warns you about that. As the manual says, “When ‘Line Out Mode’ is on, output through the headphone jack is at maximum volume, so do not use the headphones.”

The output in that mode is spot-on 2.0 volts into an open circuit. Ah, but there’s more. If you dig into the settings, there’s one for ‘Line Out Mode’. So you can switch it on or off there as well. But under this setting you can also choose ‘Fixed’ (the default) or ‘Variable’. And, you guessed it, ‘Variable’ means that the line output is under the control of the player’s volume knob.

I was tempted to switch it to line output variable and listen through headphones. Okay, but what if some other circuit is employed in line output mode? Perhaps a low-impedance load from headphones would damage it. I examined the manual with some care, and nowhere did it warn against using headphones in line out variable mode.

How could I be certain all would be fine? As it happens, I’d measured the line resistance of the output. It was 4.7 ohms, which not so co-incidental­ly matches the 4.7-ohm resistor shown in the Applicatio­n Diagram on the output of the ESS Sabre 9601K amplifier.5 Which is the amplifier used by the Pioneer XDP-30R.

And in line mode, the line resistance was the same. It looked like the same output stage to me.

So I plugged in headphones. Into a 16-ohm load, the output was now 874mV instead of 330mV. That’s 8.4 decibels more.

More importantl­y, the output into 300-ohm headphones was now 1.99 volts instead of 0.42 volts. That is, 13.4 milliwatts instead of 0.6 milliwatts. And it sounded fine.

That meant satisfying listening levels on all manner of music. That meant that my rip of the Silverstei­n/Ozawa/Boston Symphony of Vivaldi’s ‘Four Seasons’ on Telarc could be played at a pleasing level. Remember the famous 1978 Telarc recording of the 1812 Overture? On CD the cannon are even higher in level above the orchestra than they were on LP. With my much loved Sennheiser HD 535 headphones, the first three quarters of the performanc­e is quite insipid, due to a very low level that simply cannot be raised any further.

And it also meant that when I felt in the mood to truly blast myself with some Rage Against the Machine, the European bureaucrat­s weren’t standing in the way, waving their collective finger at me. Talk about rage against the machine.

Implicatio­ns

Yet we’re in Australia, not Europe! Why the limitation­s? It is, sadly, not unusual. I am also a guy who has spent many, many hours cumulative­ly over the past couple of decades plucking plastic plugs from the speaker binding posts on home theatre receivers, and then putting them back again when the reviews are complete. They are there only because of European regulation­s.

Sometimes we in Australia get products not part of the European lots, and they frequently lack such pointless ‘safety’ measures (apparently they’re concerned that people will plug their two prong power leads into speaker terminals). But we, like Europe, are part of the community of nations with 220/240V mains power running at 50Hz. So we shall, inevitably, for commercial reasons, end up getting products conforming to European rules. And while I didn’t read all the way through the aforementi­oned WHO/ITU report, I did gain the impression that they’d like to promulgate internatio­nal standards.

My preference would be for the US standard. To quote from the WHO/ITU report: “[I]n 2010, the U.S. Court of Appeals for the Ninth District affirmed a 2008 decision by a California district court to dismiss a long-running lawsuit that claimed Apple iPods endangered users’ hearing. The original 2006 lawsuit ... claimed that iPods were defective because they could play music at unsafe volumes above 115 decibels (dB). The district court disagreed, saying that any dangers of hearing loss from playing music too loud were “obvious” and “unavoidabl­e”.

I’m not so sure about the ‘unavoidabl­e’ part, but by golly the dangers are obvious. But the fact that such dangers are obvious doesn’t mean that similar rules won’t eventually be applied in Australia too.

Meanwhile, I’d encourage readers to consider carefully reviews — particular­ly measuremen­ts of output — when contemplat­ing the purchase of a portable music player. They can frequently deliver superb results in the home, even with older and lower efficiency headphones. If, that is, they are not hobbled by rules. Stephen Dawson NOTE: I am not a lawyer, nor well-versed in European law. If you are thinking of doing anything legally iffy, obtain competent legal advice.

XDP-30R review: avhub.com.au/Pioneer30R REFERENCES: 1: e.g. avhub.com.au/eumusic1 2: p3 of PDF linked at avhub.com.au/eumusic2 3: avhub.com.au/eumusic3 4: avhub.com.au/eumusic4 5: avhub.com.au/eumusic5

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 ??  ?? ▶ NOT BEST BUDS: Packaged in-ear buds are a key target of EU legislatio­n to prevent high listening levels.
▶ NOT BEST BUDS: Packaged in-ear buds are a key target of EU legislatio­n to prevent high listening levels.
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