Again though, I would encourage
@JippaLippa to base their decision on usage. I fully support people returning the Mac Studio if they're displeased, but I know threads like this can encourage paranoia.
However, I also want to comment on your "move my head" comment because I know that a lot of people scoff at that in the respect that "if it's so subtle the tilt of your head impacts it then you're just looking for faults" or other similar comments. Like, no that is how sound works. It reverbs and bounces. My Mac Studio was on the corner of my desk near (not up against) a wall. When I first started hearing the sound I thought it was just my ears. It took me a while to realize where it was coming from. It's just at the point of me noticing.
I can't bear noise and am returning my Mac Studio (M1 Max). I am coming from a Mac Mini and was startled by how noisy the Studio is even when doing nothing. I spend a lot of time in a silent office and very quickly the noise is very irritating, especially the higher pitched whistle-like noise that many have also reported.
As it relates to the "whistle" it very well could have been they received better units. Also, the frequency we're talking could very easily not be perceivable to people depending on age and biology. However I agree with you about the fans. Not to say the fans are bad per se, but the fact that so many reviewers said it was silent is very disappointing. Only Jason Snell on Six Colors commented on it. I'm not saying they should have made a big deal about it, but Jason Snell art least commented that it generated a low, but ever-present white noise.
Not a single person on this forum has a "dead silent" Studio because it's not designed to be silent. However, some people just notice it more than others.
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Unrelated, but to rant on this again - I've seen discussions (not necessarily only here) about the Mac mini comparisons saying things along the lines of "If you were fine on a mini and care so much about fan noise then you didn't need the Studio." First, just because someone can "get by" on the mini doesn't mean their workflow wouldn't be benefited by the Studio. Second, I don't think most users are upset that fans exist - if they were they'd get the MacBook Air. They're upset because the fans are noticeable while the machine is practically doing nothing. Not everyone works in a shared office, or with headphones, or with loud ambient sound. Third, many people buy computers way more powerful than they need because it makes them happy. A valid observation about a product doesn't mean the answer is "you didn't need it anyway."