30. 11. 81 Official Journal of the European Communities No C 310/7 
Opinion on the proposal for a Council Directive amending Directive 73/405/EEC on the 
approximation of the laws of the Member States relating to methods of testing the 
biodegradability of anionic surfactants 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 112 of 14 May 1981, page 4. 
A. LEGAL BASIS. FOR THE OPINION 
On 10 April 1981 the Council referred the abovementioned proposal to the Economic and 
Social Committee in accordance with Article 100 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 
190th plenary session held in Brussels on 23 and 24 September 1981. 
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 100 
thereof, 
Having regard to the request made by the Council of the 
European Communities on 10 April 1981 for an opinion 
on the proposal for a Council Directive amending 
Directive 73 / 405 /EEC on the approximation of the laws 
of the Member States relating to methods of testing the 
biodegradability of anionic surfactants, 
Having regard the decision taken by its Bureau on 
28 April 1981, instructing the Section for Industry, 
Commerce, Crafts and Services to prepare an opinion and 
a report on the matter, 
Having regard to the opinion adopted by the Section for 
Industry, Commerce, Crafts and Services at its meeting 
on 2 September 1981, 
Having regard to the oral report by Mr Ramaekers, the 
Rapporteur, 
Having regard to the discussions on 23 September 1981 at 
its 190th plenary session, held on 23 and 24 September 
1981, 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously: 
Subject to the following comments, the Committee 
approves the proposal for a Directive. 1. General comments 
1.1. The Committee acknowledges the need to update 
the testing methods used in the various Member States 
and to add the method in force in the United Kingdom to 
those currently recognized. 
1.2. The Committee believes, however, that the long 
term trend should be towards harmonization of the 
various methods so that the reference method 
(confirmatory test procedure) becomes the testing 
method in use throughout the Member States of the 
Community. The Committee is aware of the cost of this 
process of adjustment and feels, therefore, that the most 
realistic course at the moment is still to allow a choice of 
reference method. 
1.3. The Committee feels that the scope of the 
Directive should be more precisely defined by making 
it clear that it applies only to surfactants used in 
detergents. 
2. Specific comments 
Article 1 
2.1. To introduce a degree of uniformity in texts 
dealing with similar topics, the Committee requests that 
the wording of Article 1 should be brought into line with 
the wording of the first Article of the Proposal for a 
Directive on testing the biodegradability of non-ionic 
surfactants (J). 
(') OJNoC 104,28.4. 1980. 
No C 310/8 Official Journal of the European Communities 30. 11. 81 
2.2. Accordingly, the Committee suggests that 
Article 1 should read: 
'Directive 73/405/EEC is hereby amended as 
follows: 
1. The following is added to Article 1: "present in 
detergents".' 
2.3. Apart from the advantage of harmonizing texts, 
the Committee believes that the word 'present' describes the situation referred to better than 'used in', since 
substances used in the manufacturing process are not 
necessarily present in the finished product. 
2.4. As the authors of the text are referring specifically 
to anionic surfactants present or contained in detergents, 
the verb 'used' seems to reflect the proposed situation less 
accurately. 
Done at Brussels, 23 September 1981. 
The Chairman 
of the 
Economic and Social Committee 
Tomas ROSEINGRAVE