No C 113/14 Official  Journal  of the European  Communities 7. 5. 80 
Opinion  on the  proposal  for  a Council  Directive  on the  weights  and  certain  other 
characteristics  (not  including  dimensions)  of road  vehicles  used  for  the carriage  of 
goods 
The text  referred  to the Committee  has been  published  in Official  Journal  of the Euro-
pean  Communities  No  C 16 of 18 January  1979,  page  3. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 15 January  1979  the Council  referred  the abovementioned  proposal  to the Economic 
and Social  Committee  in accordance  with  Article  75 of the Treaty  establishing  the Euro-
pean  Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its opinion  on the above  matter  at its 
175th  plenary  session  held  in Brussels  on 30 and  31 January  1980. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the Treaty  establishing  the Euro-
pean  Economic  Community,  and  in particular 
Article  75 thereof, 
Having  regard  to the request  made  by the Council  of 
the European  Communities  on 15 January  1979  for 
an opinion, 
Having  regard  to the proposal  for a Council  Direc-
tive on the  weight  and  dimensions  of commercial 
road  vehicles  and  certain  additional  technical  re-
quirements  ('), 
Having  regard  to its opinion  of 27 January  1972  on 
this matter  (2), 
Having  regard  to the decision  taken  by its Bureau  on 
23 January  1979  instructing  the Section  for Transport 
and Communications  to draw  up an opinion  on the 
matter, 
Having  regard  to Article  22 of the Rules  of Proce-
dure, 
Having  regard  to the opinion  of the Section  adopted 
at its 130th  meeting  on 16 January  1980, 
Having  regard  to the report  submitted  by Mr Bonety, 
the rapporteur, 
Having  regard  to the discussions  at its 175th  plenary 
session  on 30 and  31 January  1980  (meeting  of 
31 January  1980), Whereas  it is essential,  within  the framework  of the 
common  transport  policy,  to establish  maximum 
standards  for the weights  and other  characteristics  of 
certain  commercial  road  vehicles  which  will  permit 
these  vehicles  to be used  throughout  the Communi-
ty; 
Whereas  harmonization  at Community  level  of the 
weights  and  dimensions  of commercial  vehicles  is of 
prime  importance  for the definition  and implementa-
tion of a common  transport  policy; 
Whereas  according  to the Commission,  the establish-
ment  of uniform  limits  for all the Member  States  will 
facilitate  the development  of a more  homogeneous 
market  for heavy  motor  vehicles; 
Whereas  it is necessary  that  motor  vehicles  which  are 
permitted  free  circulation  in the Community  should 
comply  with  all Community  Directives; 
Whereas  consideration  must  be given  to the foresee-
able repercussions  on the present  vehicle  fleet,  the 
need  for  undertakings  to replace  existing  vehicles 
rapidly,  the changes  in vehicle  manufacturing  plans 
and their  impact  on capital  expenditure,  employment 
and working  conditions; 
Whereas  it is essential  that  any  attempt  to harmonize 
vehicle  weights  take  energy  problems  into  account, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
(') OJ No C9,  11.9.  1971,  p. 25. 
(2) OJ No C 61, 10.6.  1972,  p. 5. by 70 votes  to 17 with  12 abstentions: 
7. 5. 80 Official  Journal  of the European  Communities No C 113/15' 
1. General  comments 
1.1. In  its opinion  of 28 March  1974  (i) on a com-
munication  from  the Commission  to the Council  on 
the development  of the common  transport  policy  the 
Economic  and Social  Committee  expressed  the view 
that solving  the problem  of the weights  and  dimen-
sions  of commercial  vehicles  would  have  a decisive 
influence  in facilitating  the further  development  of 
that policy. 
1.2. The  Committee  takes  the same  line  it has al-
ways  adopted  on this matter  and therefore  has no ob-
jection  in principle  to the Commission's  proposal. 
It even  considers  that this proposal  represents  a laud-
able attempt  by the Commission  to make  significant 
progress  towards  the  harmonization  of technical 
standards  for commercial  vehicles,  at a time  when 
circumstances  have  led to complete  the stagnation  in 
the Community  harmonization  of road  vehicle 
weights  and  dimensions. 
1.3. Accordingly,  while  confirming  that it approves 
the principle  of harmonization  at European  level  of 
the weights,  dimensions  and  other  characteristics  of 
road  vehicles  used  for the transport  of goods,  the 
Committee  suggests  setting  up an ad hoc committee 
— with  whose  proceedings  interested  professional 
and social  groups  would  be associated  — which 
would  have  the task  of evaluating  the practical  conse-
quences  of the application  of the Directive. 
1.3.1.  In a period  when  the European  economy  is 
relatively  stagnant  it would  in fact  be inexpedient  to 
subject  industry  to considerable  structural  changes 
with the result  of possible  disturbance  to the already 
badly  hit labour  market. 
1.3.2.  Furthermore,  the Community  should  wait  for 
the findings  of the technical  investigations  which  are 
under  way  in several  EEC  Member  States  and coor-
dinate  these  investigations  rather  than  rely  only  on 
the AASHO  trials.  The  latter  were  carried  out more 
than 20 years  ago on infrastructure  which  do not cor-
respond  to the various  types  of infrastructure  existing 
in the Member  States. 
1.3.3.  Finally,  the  Committee  considers  that  the 
Council  should  ascertain  the views  of the new  Mem-
ber States  on this  subject. 
(i) OJ No C 126,  17. 10. 1974,  p. 26. 2. Specific  comments 
The Committee  therefore  approves  this  draft  Direc-
tive, subject  to the following  reservations: 
2.1. Maximum  authorized  weight  of vehicles  and 
combinations  — maximum  weight  per driving 
axle 
It suggests  confining  application  of the Directive  to 
combinations  with  not more  than  five  axles  and  a 
GVW  of 40 tonnes,  with  authorized  axle  loadings  as 
proposed  in the Directive,  including  the maximum  of 
11 tonnes  on the driving  axle  of a two-axle  tractor 
unit. 
It considers  that  such  a limitation  is justified  in view 
of (i) the economic  situation  of the railways,  (ii) the 
lack of any  real  coordination  between  different 
forms  of transport,  (iii) the foreseeable  effects  on the 
environment  and on safety  and (iv) the repercussions 
on energy  consumption. 
Such  a limitation  is also  justified  by: 
— the possibility  of continuing  the studies  in pro-
gress  on the effects  on the infrastructure, 
— the need  for planning  in the industrial,  commer-
cial and  administrative  spheres  in connection 
with the repercussions  of the Commission's  pro-
posal, 
— the possibility  of continued  use  of the existing 
vehicle  fleet,  thereby  avoiding  a fall  in its 
value. 
2.2. Uncoupling  of vehicles  forming  part  of a com-
bined  vehicle  during  international  transport 
The Committee  notes  that  the exclusion  of two-axle 
vehicles  from  the scope  of the Directive  and the limi-
tation  of the maximum  weight  per driving  axle  to 10 
tonnes  for all rigid  vehicles  could  result  in reloading 
problems  when  crossing  frontiers. 
The Committee  therefore  proposes  allowing  vehicles 
forming  part  of a combined  vehicle  to uncouple, 
without  necessarily  having  to lighten  the  tractor, 
during  international  transport. 
2.3. Transport  of containers 
The Committee  would  ask the Commission  to study 
the possibility  of transporting  40-foot  containers  in 
certain  zones,  the limits  of which  could  be fixed 
during  the work  on this  Directive,  by way  of a dero-
No C 113/16 Official  Journal  of the European  Communities 7. 5. 80 
gation  from  the standards  adopted  in the Community 
regulations. 
2.4. Tandem  axles 
The Committee  proposes  raising  to 20 tonnes  the 
maximum  load  for tandem  axles  with  a spacing  of 
more  than  two  metres,  the two  axles  of the tandem 
being  regarded  as separate. 
Under  the regulations  of several  Community  coun-
tries the two axles  of a tandem  are already  regarded 
as separate  if they  are more  than  two  metres  apart. 
2.5. Transitional  provisions 
Transitional  provisions  must  be laid  down  enabling 
the Directive  to be applied  rapidly  to existing  vehi-
cles which  comply  with  Community  standards  on 
noise,  exhaust  emissions,  steering  and  braking. 
The solution  sought  by the Commission  to the prob-
lem of frontier  difficulties  will only  be achieved  if ex-
isting  vehicles,  or at least  a large  number  of them,  can 
benefit  immediately  from  the free  circulation  pro-
vided  for in the draft  Directive. 
Since  the  provisions  of Article  4 (plates)  and  of 
Article  8 (date  of entry  into  force)  suggest  that  only 
new vehicles  will be covered,  the Commission  should 
specify  the conditions  under  which  existing  vehicles 
will be able  to benefit  from  the new  arrangements 
and the time-scale  for this. 2.6.2.  Furthermore,  the Committee  would  draw  the 
Commission's  attention  to the effects  of this  Direc-
tive on road  safety  and  the working  conditions  of 
road  haulage  personnel. 
It recognizes  that  the road  network  will  have  to be 
improved  if accidents  are to be cut down. 
However,  since  it is not known  what  effect  imple-
mentation  of the Directive  will have  on traffic,  there 
is justification  for asking  a Community  body  — it 
could  be the 83 Committee  — to look  into  the road 
safety  aspects  of the growth  in traffic. 
2.6.3.  The  Committee  is aware  of the impact  that  an 
increase  in GVW  will have  on the working  conditions 
of personnel  and considers  it essential  that the conse-
quences  of the new  draft  Directive  on vehicle  weights 
be scrutinized  in the light  of Community  social  regu-
lations. 
At all events,  the Committee  thinks  that the Commis-
sion should  convert  into  a draft  Community  Direc-
tive the opinion  of 3 March  19%8  issued  unanimously 
by the Joint  Advisory  Committee  on social  questions 
in road  transport  on the cab and bunk  equipment  of 
vehicles  with  a GVW  of over  3 5 tonnes  used  in road 
haulage.  (Opinion  V/II/408/A/76-F,  transmitted  3 
March  1978  to the Commission  of the European 
Communities.) 
However,  this specific  aspect  does  not solve  the other 
social  problems  raised  during  the examination  of the 
draft  Directive,  i.e. driving  and working  hours,  voca-
tional  training,  etc. 
2.6. Environment,  safety,  working  conditions 
Without  calling  into  question  the technical  nature  of 
the Directive  on vehicle  weights,  the  Committee 
would  like  to make  some  proposals  regarding  its re-
percussions  on the  environment  and  the  working 
conditions  of road  haulage  personnel. 
2.6.1.  It is pleased  to note  that  in Annex  III the 
Commission  lists  the  Community  legislation  on 
noise,  air pollution  by exhaust  gases  from  vehicles, 
braking  and  steering  to which  new  vehicles  would 
have  to conform. 
The Committee  thinks  that  consideration  should  be 
given  as of now  to procedures  for ascertaining  the ex-
tent to which  the regulations  referred  to in the Direc-
tive will  in future  always  be adapted  to vehicles 
qualifying  for Community  approval  pursuant  to 
Article  4; this  is to take  into  account  the concerns 
voiced  regarding  protection  of the environment. 2.7. Planning  of structural  changes  — deadline  for 
implementation 
The Committee  also  considers  that  attention  should 
be drawn  to the scale  of the structural  changes  in the 
vehicle  manufacture  and  transport  industries  liable 
to result  from  implementation  of the draft  Directive; 
this applies  not only  to road  transport  but to other 
forms  of transport  also. 
These  structural  changes  must  be planned,  since  'the 
broad  decisions  as to the course  of transport  policy 
cannot  be based  purely  on the machinery  of the mar-
ket economy'  (ESC  opinion  of 28 March  1974).  Such 
planning  would  help  to prevent  disruption  in the em-
ployment  sphere. 
The Committee  also  thinks  that  the deadline  for im-
plementation  of the Directive  should  be such  as to 
enable  the Member  States  to take  account  of the 
7. 5. 80 Official  Journal  of the  European  Communities No C 113/17 
problems  likely  to arise  in the  adaptation  of infra-
structures  (roads  and  bridges). 
3. Final  comments 
Finally,  the Committee  reserves  the right  to re-exam-
ine the  problem  of the  weights  of road  vehicles  used 
Dore  at Brussels,  31 January  1980. for the  carriage  of goods  if the  Commission  makes 
any amendment  to its proposed  Directive  which 
would  lead  to conclusions  different  from  those  set 
out above.  This  also  applies  to the opinion  delivered 
by the Committee  on 27 January  1972  on the  propo-
sal for a Council  Directive  on the weights  and  dimen-
sions  (dimensions  aspects)  of  commercial  road 
vehicles  and  certain  additional  technical  require-
ments. 
The Chairman 
of the Economic  and Social  Committee 
Raffaele  VANNI 
ANNEX 
to the opinion  of the Economic  and  Social  Committee 
The following  amendments  were  rejected  during  the debate: 
Point  1.2: 
Add the following  points  at the end  of point  1.2 (1.2.1  to 1.2.5): 
'1.2.1.  But  a number  of preliminary  comments  are necessary  to demonstrate  the complexity 
of the problem,  which  must  be solved  in the light  of the economic  and productive  differences 
within  the various  Member  States.  This  may  make  it necessary  to phase  in the general  applica-
tion of certain  standards,  making  timely  and  objective  use of the experience  gained  in this 
field.' 
Reasons 
The Member  States  have  differing  views;  the proposal  for alignment  is a temporary  compromise 
between  widely  different  extremes. 
Voting 
For: 15, against:  58, abstentions:  8. 
'1.2.4.  A cautious,  realistic  approach  to this  whole  sector  is needed,  since  the Community's 
manufacturing  industry  is at present  already  in the process  of reorganization  and  is giving 
priority  to a reduction  in the fuel  consumption  of vehicles.' 
Reasons 
The proposal,  which  was  drafted  in 1977/78,  could  not take  into  account  recent  trends  which  are 
now of critical  importance:  the rising  inflation  rate,  the inflexibility  of certain  factors  with  a con-
siderable  impact  on the running  cost  of road  vehicles,  the availability  and  cost  of oil products 
which  has risen  uncontrollably  in the last 18 months,  with  the future  outlook  even  more  unpredict-
able. 
Voting 
For: 24, against:  35, abstentions:  16. 
Point  2: 
Amend  as follows: 
'The Committee  therefore  approves  the proposal,  subject  to the following  conditions  and 
reservations  ...' 
No C 113/18  Official  Journal  of the European  Communities  7.  5. 80 
Reasons 
This will emphasize  the significance  the Committee  attaches  to a number  of important  comments 
which  are basic  to its opinion. 
Voting 
For: 14, against:  58, abstentions:  4. 
Points  2.2 to 2.5: 
Add points  2.2 to 2.5: 
'2.2. The  Committee  proposes  to limit  the application  of the Directive  initially,  and for at 
least 10 years,  to international  transport  and to exclude  that which  originates  and terminates 
within  the same  Member  State.' 
Reasons 
The lengthy  discussions  by the study  group  and session  are an indication  of the confusion  caused  in 
every  country  for various  reasons  by the adoption  of the standards  in the Directive. 
Limiting  the Directive's  application  initially  to international  transport,  which  is regulated  on the 
basis  of quotas,  would  afford  useful  experience  and  reduce  any negative  effects,  which  cannot 
always  be accurately  predicted. 
Voting 
For: 11, against:  large  majority. 
'2.3. The  Economic  and Social  Committee  proposes  that,  before  the Directive  is given  gen-
eral application,  it should  be checked  for compatibility  with  the objective  of reducing  the con-
sumption  of oil per tonne  of transportable  weight  in all Community  countries.' 
Reasons 
This caution  seems  appropriate  in view  of the present  oil supply  position  and the different  effects 
which  the generalized  adoption  of the proposed  standards  would  have  in particular  countries.  This 
also ties in with  the last recital. 
Voting 
For: 11, against:  large  majority. 
'2.4. The  Economic  and  Social  Committee  is in favour  of promoting  combined  transport 
(road-rail,  road-ship,  etc.)  and safeguarding  users'  free  choice  of means  of transport.  It there-
fore feels  that legal  and technical  provision  should  be made  for the transportation  by road  of 
containers  that  comply  with  the ISO  668-1979  standard.' 
Reasons 
The development  of combined  transport  is linked  to the container.  ISO  668-1979  laid down  valid 
and accepted  international  standards  for the dimensions  and  weights  of the four  standardized 
classes  of containers. 
Combined  transport  generally  includes  road  haulage.  If the transport  by road  vehicle  of ISO  con-
tainers  is not legalized,  this type  of transport,  which  is viewed  with  growing  interest  by all the Mem-
ber States  with  the aim of utilizing  their  rail and shipping  more  intensively,  cannot  be effectively 
developed. 
Voting 
For: 27, against:  38, abstentions:  16.