No C 346/8 Official Journal of the European Communities 31. 12. 82 
Ministers that it will submit the new proposal which has been announced to the Council and the 
Economic and Social Committee by the end of June 1983. The new method of calculation must take 
due account of the interests of all those concerned and be based on objective criteria.' 
Reasons 
See above. 
Voting 
For: 43, Against: 71, Abstentions: 14. 
Opinion on the proposal for a Council Regulation amending Regulation (EEC) No 355/77 on 
common measures to improve the conditions under which agricultural products are processed 
and marketed 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 147 of 11 June 1982, page 7. 
A. LEGAL BASIS FOR THE OPINION 
On 7 June 1982 the Council referred the abovementioned proposal to the Economic and Social 
Committee in accordance with Article 43 of the Treaty establishing the European Economic 
Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
202nd plenary session held in Brussels on 24 and 25 November 1982. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Article 43 
thereof, 
Having regard to the request made by the Council of the 
European Communities on 7 June 1982 for an opinion on 
the proposal for a Council Regulation amending 
Regulation (EEC) No 355/77 on common measures to 
improve the conditions under which agricultural 
products are processed and marketed, 
Having regard to the decision taken by its Bureau on 
29 June 1982 instructing the Section for Agriculture to 
prepare the work on the matter, 
Having regard to the opinion adopted by the Section for 
Agriculture at its 238th meeting held on 4 November 
1982, 
Having regard to the oral report made by the rapporteur, 
Mr Wick, 
Having regard to the discussions on 24 November 1982 
during the 202nd plenary session held on 24 and 
25 November 1982, HAS ADOPTED THE FOLLOWING OPINION 
with no dissenting votes, but with five abstentions: 
I. General comments 
1. Ever since its introduction in 1964, the 
Community's market-structure policy has been an 
important adjunct to the policy on agricultural structures. 
The Community's market-structure policy has proved to 
be an effective instrument of the common agricultural 
policy and has played an important role in improving the 
treatment, processing and marketing of agricultural 
products; it has also served consumers' interests by 
improving food quality. 
2. The Community's market-structure policy has also 
done much to further supply-side adjustment to changed 
consumer demand, thereby reducing expenditure on 
market support for agricultural products. The continuing 
need for structural adjustment means that these common 
measures must be continued beyond 1982, among other 
things to complement the Community's policy on 
31. 12. 82 Official Journal of the European Communities No C 346/9 
agricultural structures. If the Community is to go any way 
towards achieving these aims, more funds will have to be 
made available for such common measures. This implies 
- as the ESC pointed out in an opinion delivered in 
January 1976 (*) - that a 'new and permanent legal 
foundation' will have to be provided for the 
market-structure policy introduced in 1964 and carried 
further in 1977 by Regulation (EEC) No 355/77. 
3. Extension of Regulation No 355/77 is consistent 
with the guidelines drawn up by the Commission under its 
Mandate of 30 May 1980. These guidelines recognize the 
need to secure a balanced development of the Community 
by long-term measures and acknowledge the need for an 
active structural policy. 
4. The Committee believes that Regulation (EEC) No 
355/77 should not be deprived of its status as an overall 
Community measure by the introduction of Community 
provisions tailored to the needs of specific Member 
States. Everything should also be done to ensure that the 
Regulation is implemented uniformly in all Member 
States of the Community since the improvement of 
market structures is a matter of importance in all Member 
States and will remain so as far as can be foreseen. 
Uniform implementation, and the aim of structural 
improvement, do not conflict with the need to take 
account of the more particular requirements of certain 
regions of the Community. 
5. The Committee would like the Commission to 
produce a summary report of its experience in applying 
Regulation (EEC) No 355/77 by the end of the five-year 
period of operation. The lessons learned in applying 
Regulation (EEC) No 355/77 allow a number of 
suggestions to be made and these should be taken into 
consideration when the new Regulation is being 
prepared. 
6. The Committee notes that, judging from the 
experience of the relevant sectors of the economy, the 
Regulation has proved to be an appropriate instrument 
for fulfilling the objectives laid down. It can therefore be 
extended without major changes. 
II. Proposal to amend Regulation (EEC) No 
355/77 (2) 
7. The Committee asks that its consultation should be 
explicitly recorded in the proposal for a Regulation. 
8. The Committee regrets that the Commission was 
unable to submit in time a proposal for a long-term 
(») OJ No C 45, 27. 2. 1976, p. 11. 
(2) OJ No C 147, 11.6. 1982, p. 7. Regulation to succeed Regulation (EEC) No 355/77. 
The proposal to extend Regulation (EEC) No 355/77 
initially by just one year will cause considerable 
uncertainty among the relevant business circles, which 
require a longer-term perspective for their investment 
plans and structural adjustments. 
9. In view of the imminent expiry of Regulation (EEC) 
No 355/77, and in the interests of ensuring as smooth as 
possible a continuation of the provisions, the Committee 
approves the extension of the Regulation by one year, to 
31 December 1983. 
10. The Committee nevertheless considers that it is 
urgently necessary to increase the amount of money set 
aside for the implementation of the Regulation in 1983. A 
rise to 143 million ECU in 1983 would be needed merely 
to offset inflation since 1976, when the sum required for 
the Community of Nine was originally estimated 
(80 million EUA per year). This rise would not take into 
account the fact that investment expenditure on the 
treatment, processing and/or marketing of agricultural 
products has increased because of technical progress, 
energy-saving schemes and the requirements of 
environmental and consumer protection. 
III. Comments on the changes needed to be made to 
Regulation (EEC) No 355/77 with a longer-term 
solution in mind 
With the submission of a proposal for a Regulation to 
follow up Regulation (EEC) No 355/77 just round the 
corner, the Committee requests that the following 
comments be taken into consideration. The comments 
are based on existing Regulation (EEC) No 355/77. 
The Committee assumes that it will also be asked to 
deliver an opinion on the proposal for a long-term 
Regulation. At all events it reserves the right to deal with 
this matter in the manner deemed most appropriate. 
(a) Specific programmes 
11. A new requirement was introduced when the 
Community began to apply Regulation (EEC) No 
355/77 on 1 January 1978, namely that projects are only 
eligible for aid if they are part of 'specific programmes'. 
The Committee believes that this system of overall 
planning has generally proved workable in practice. 
Member States should continue to be encouraged to work 
out programmes, even if some States have, to a certain 
extent, had difficulties in drawing them up and in 
presenting them in time. 
12. The Committee believes that, in the light of the 
experience gained, the existing provisions on 
No C 346 /10 Official Journal of the 
programmes (Article 3) should not be changed. They 
already guarantee the necessary information about 
programmes and programme objectives, and they already 
offer the requisite flexibility. 
(b) Projects 
13. There should be no blanket extension of the scope 
described in Article 7. This is mainly because funds are 
limited and there are generally speaking a large number of 
applications. The Committee is afraid that, if the scope 
were extended, it might not be possible to achieve the 
aims laid down. 
14. At the same time the Committee is well aware that 
in certain cases it would be in the interests of the 
Regulation's objectives to encourage projects relating to 
types of products not covered by Annex II. 
15. The Committee notes that the Council has not so 
far made use of Article 7 (2). It wonders whether the 
procedure set out in Article 22 should not allow for 
derogations, subject to strict application of Article 7 (2) 
and Article 9. 
16. The Committee would point out in connection 
with Article 8 that the term 'production objectives' has 
acquired another**neaning as a result of the Mandate of 
30 May 1980. The Committee would therefore propose 
that the term be changed,, for example to 'production 
orientation'. 
17. The Committee notes that each year there are 
generally very long delays in announcing aid criteria, even 
though aid criteria are of vital importance in the selection 
of the projects to receive financial aid under the 
Regulation. In the view of the Committee, aid criteria 
should be announced earlier and should be valid for 
longer periods of time. Investors will then be in a position 
to adjust their longer-term investment plans to these 
criteria. 
18. Article 12 was intended as a temporary measure 
when Regulation (EEC) No 355/77 first came into force, 
and can be dropped. 
19. The Committee believes that programmes which 
have already been submitted and approved should be 
allowed to run their full course, even if this means 
implementing them beyond 1983. 
(c) Procedure for the examination of projects 
20. The Committee calls upon the Commission to 
continue its efforts to speed up the administrative uropean Communities 31. 12. 82 
procedure for approving and funding projects. By saving 
time, this would make the measures even more effective. 
Delays not infrequently pose additional problems for the 
implementation of projects, especially in Member States 
where there are high inflation and interest rates. Such 
delays should be avoided. The Member States, for their 
part, should be asked to prepare and pass on their 
applications to the Commission promptly. 
(d) Financial and general provisions 
21. The Committee believes that a five-year period for 
the validity of the Regulation and the allocation of funds 
is too short and does not match the necessary long-term 
perspective of market-structure policy and business 
investment planning. The Committee therefore 
emphasizes once again the need for a 'legal basis' of 
unlimited duration as well as for financial provisions that 
are adjusted in line with economic needs every five 
years. 
22. The amount of money required to cover 
programmes which have already been authorized is, in 
some countries, more than twice the amount available for 
the implementation of Regulation (EEC) No 355/77. 
This discrepancy brings about a situation whereby 
worthy projects frequently have to be rejected on account 
of a lack of funds. The Committee is afraid that this 
Community investment promotion policy will not have 
the success expected if budgetary limits rather than the 
importance of the project itself are the crucial 
criterion. 
The Committee believes that adequate funds must be 
made available for the policy on agricultural structures if 
it is to be used more widely (as an adjunct to price policy), 
in order to secure the effective rationalization and 
structural improvements required to meet the needs of the 
market and the requirements of both producers and 
consumers. 
23. When determining the size of the appropriation 
for measures under the Regulation, account must be 
taken not only of continuing structural changes in the 
treatment, processing and marketing of agricultural 
products, but also of the steep rise in investment costs 
resulting from new legal requirements in respect of the 
environment, health protection and energy-saving 
measures. 
24. These ever-increasing financial requirements are 
further aggravated by the continuing general inflation, 
which is particularly marked in some Member States. The 
400 million units of account originally allotted to 
Regulation (EEC) No 355/77 should be increased to 714 
31. 12. 82 Official Journal of the European Communities No C 346/11 
million ECU to allow for changes in the value of money 
between 1976 and 1982. The Committee therefore 
considers it necessary to adjust the appropriation to take 
account of the realities described above and to make 
provision in the new Regulation for a mechanism which 
would operate for the whole of the period of validity of 
the Regulation and would reflect real needs in the 
Community. 25. Subsequent measures (Regulations (EEC) No 
1361/78, (EEC) No 1820/80, (EEC) No 3509/80 and 
Directive 72/161 /EEC have not really eased the burden 
on the overall appropriation allocated to Regulation 
(EEC) No 355/77 since they were primarily introduced 
to reduce structural disparities between Community 
regions and to cater for the accession of Greece. All these 
measures require a corresponding increase in funds. 
Done at Brussels, 24 November 1982. 
The Chairman 
of the Economic and Social Committee 
Francois CEYRAC 
APPENDIX 
to the opinion of the Economic and Social Committee 
Defeated amendment 
The following amendment, tabled in accordance with the Rules of Procedure, was rejected during plenary 
session discussions: 
Page 4 
The following new point 11 should be added: 
'11. The Committee points out that the timing and methods of Community financing are causing 
difficulties, especially in the high-inflation Member States where interest rates are high. Action should 
be taken to eliminate these difficulties as from 1 January 1983, to avoid the danger of it being 
impossible in practice to implement the extension in the Member States in question. 
The Committee thinks that it is feasible right now either (1) to amend points 4 and 5 of Annex A to 
Commission Regulation (EEC) No 219/78 (on applications for EAGGF Guidance Section assistance 
for projects for improving the conditions under which agricultural products are processed and 
marketed), so as to make clearer that the cost to be specified when submitting the application relates to 
the date of execution of the work (or at least that the cost can be revised depending on the length of time , 
between the application and the execution of the work; or (2) to amend the price review system to allow 
for national inflation rates.' 
Reasons 
Self-evident. 
Voting 
For: 39, Against: 43, Abstentions: seven.