30. 11. 87 Official Journal of the European Communities No C 319/27 
Opinion on the proposal for a Council Directive amending Directive 85/3/EEC on the 
weights, dimensions and certain technical characteristics of certain road vehicles(]) 
(87/C 319/09) 
On 11 June 1987 the Council decided to consult the Economic and Social Committee under 
Article 198 of the Treaty establishing the European Economic Community on the above-
mentioned proposal. 
The Section for Transport and Communications which was responsible for preparing the 
Committee's work on the subject, adopted its opinion on 9 September 1987 in the light of 
the report by Mr Bleser. 
At its 248th plenary session (meeting of 23 September 1987), the Economic and Social 
Committee unanimously adopted the following Opinion: 
1. Introduction 
1.1. Directive 85/3/EEC of 19 December 1984 (2), on 
the weights, dimensions and certain other technical 
characteristics of certain road vehicles, sets the 
maximum permitted width for any type of vehicle at 
2,5 m. The Commission is now proposing a 10 cm 
increase in respect of refrigerated vehicles. 
1.2. The proposal is prompted by the fact that the 
insulated walls of refrigerated vehicles are over 45 mm 
thicker than those of other vehicles. Their inside width 
is thus reduced (given a maximum external width of 
2,5 m), with the result that they cannot accommodate 
two standard international pallets side by side and their 
surface area cannot therefore be used profitably. 
1.3. While we are favourably disposed to the Com­
mission proposal and the underlying arguments, some 
comments and reservations are called for. 
2. General comments 
2.1. In the first place, the fact that the Commission 
is proposing that the current Directive be waived should 
not be glossed over. This would not in itself be worrying 
had the Directive been uniformly implemented in all 
the Member States; however, the various waivers intro­
duced since the parent Directive came into force, 
coupled with this Commission proposal to institu­
tionalize waivers for refrigerated vehicles, foster the 
belief that the Directive will, in the final analysis, 
become a dead letter. We therefore would have liked 
the Commission to provide reliable data on how Direc­
tive 85/3/ECC has been implemented to date, as well 
as — or particularly — which countries use standards 
other than those laid down in this Directive. 2.2. The proposal goes beyond one specific category 
of vehicle and touches on a far broader range of prob­
lems. We therefore have decided to address the more 
general problem of technical characteristics and their 
implications. This position has been bolstered by cur­
rent discussions within the Techical Committee No 104 
of the International Organization for Standardization 
(ISO).We also wonder to what extent Directive 85/3/ 
EEC may not be partially outdated and may not be 
in need of revision. The fact, for example, that the 
Commission has only just 'discovered' the problem of 
refrigerated vehicles merely confirms this view. This 
raises the question: does the specific problem of width 
not in fact affect vehicles in general? 
2.3. Piecemeal solutions for isolated technical prob­
lems are not enough. An overall review must be under­
taken of the whole issue of weights, dimensions and 
other technical characteristics of vehicles, and their 
implications. Directive 85/3/EEC ignores important 
aspects such as cab dimensions. Serious consideration 
will also have to be given to the specific features and 
needs of other modes of transport (e.g. railway gauges), 
especially combined transport. The considerable 
changes in this sector over the past years will also have 
to be taken into account. 
2.4. One Member State recently requested the re-
adjustement of the data for a number of technical 
characteristics. This is a further argument for an overall 
reassessment. 
2.5. We unreservedly support the proposals to lay 
down standard values at Community level for the 
weights, dimensions and certain other technical charac­
teristics of vehicles. The Committee called for this 
in its opinion of January 1980 (3). Standardization is 
becoming more essential than ever, in view of the 
proposed completion of the internal market by 1992. 
(!) OJ No C 148, 6. 6. 1987, p. 10. 
(2) OJ No L 2, 3. 1. 1985, p. 14. (3) Opinion of 31 January 1980 (OJ No C 113, 7. 5. 1980, p. 14). 
No C 319/28 Official Journal of the European Communities 30. 11. 87 
The Commission is therefore asked to draw up an 
accurate schedule of measures designed to secure stan­
dardized values in all Member States by 1992. Further­
more, since Directive 85/3/EEC has not been uniformly 
implemented, we feel that the ultimate aim should be 
a Regulation. 
2.6. It is surprising that both sides of industry have 
not been invited to express their views on the proposal 
in advance. The Commission is endeavouring to find 
a technical solution to this specific problem without 
looking into either (a) other technical aspects (e.g. the 
weight, length, height of the vehicle, cab dimensions 
etc.) or (b) the implications of implementing the pro­
posed measures. It should be recalled in this context 
that the abovementioned Committee Opinion called 
for the establishment of a study group involving the 
professional and social interest groups concerned, with 
the task of investigating the implications of the 
implementation of the Directive. 
3. Specific comments 
3.1. Economic and technical aspects 
3.1.1. The economic implications of the proposed 
measures are a matter for concern: (1) the coexistence 
of two types of refrigerated vehicles, at least in the 
transitional period, will adversely affect competition 
and (2) haulage firms and vehicle manufacturers will 
have higher costs due to the additional investments 
required by the new provisions — possibly sooner than 
anticipated. 
3.1.2. In addition, there are some objections to the 
scope of the Commission proposal. The term 'refriger­
ated vehicle' is vague (5th indent of Article 2 of the 
Done at Brussels, 23 September 1987. Directive) and should be replaced by 'vehicle with insu­
lating walls designed for palletized transport'. 
3.1.3. The proposed terms and dimensions should 
be fixed in close cooperation with the ISO. 
3.2. Hygiene, safety and social aspects 
3.2.1. While supporting the Commission's view that 
in the interests of hygiene, perishable foodstuffs should 
be transported in thick-walled vehicles, we would point 
out that the proposal to extend the maximum author­
ized width of refrigerated vehicles by 10 cm could not 
in itself provide a concrete, definitive solution to the 
problem of transporting perishable foodstuffs in line 
with safety requirements (e.g. the cold chain). 
3.2.2. Furthermore, has the Commission taken suf­
ficient into account the consequences of increasing 
vehicle width for some types of road infrastructure and 
for road safety? 
3.2.3. Safety is of the utmost importance both in 
relation to other road-users and to the driver of the 
vehicle himself. Similarly, any measures involving tech­
nical alteration should not only guarantee the driver's 
safety but also safeguard his working conditions and 
general well-being. 
3.3. Environment 
Abatement of noise and pollution are high-priority 
environmental objectives. The possible effects of 
increasing the maximum authorized width of vehicles 
on the environment and its components should be 
thoroughly investigated. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT