23.1. 75 Official Journal of the European Communities No C 16/19 
2.4.2. The proposed reduction in the number of 
tariff quotas for sensitive products will make it 
impossible to work an observation system for the 
large majority of products except on an ex post facto 
basis. 
2.4.3. It follows that the observation system and, 
in particular, the ceiling mechanism for products 
under special observation must be effective. It 
appears that the Commission is technically equipped 
to carry out such observation in cooperation with the 
Member States' customs authorities (surveillance of 
entry into the customs territory of the Community at 
intervals of ten days or even on a daily basis). But 
there must also be a political determination to ensure 
that the observation system is effective in practice. 
2.4.4. The diversity and complexity of the 
instruments used (tariff quotas, ceilings for products 
under special observation, theoretical ceilings, 
cut-offs, etc.) calls for comment. 
— Application of the machinery advocated by the 
Commission presupposes supervision by a 
political body at European level. The supervision 
in question must be compatible with the speed of 
action which is required in this field. 
— Consideration should be given to introducing 
procedures for consultation between the various 
interests at Community level, so as to allow a 
regular, systematic evaluation of the impact of the 
generalized preferences system. In this connection, 
the Committee attaches importance to the 
supplementary measures contemplated by the 
Commission with respect to information, 
documentation, trade promotion and market 
research. — Particular attention must be paid to the 
endeavours made to share the advantages more 
fairly among the beneficiary countries, for 
example by using cut-offs. The Committee 
applauds such endeavours to reduce disparities in 
the application of preferences, since so far these 
have mainly benefitted the richest of the 
beneficiary countries. 
2.4.5. As far as rules of origin are concerned, the 
Committee has noted that the Commission wants to 
introduce a system of cumulative origin in favour of 
regional groups of countries. The Committee 
endorses the Commission's aims, but points out that 
the application of such a system would require 
monitoring facilities, inter alia, in order to prevent 
deflection of trade. In this connection, the Committee 
would refer to the Committee's Opinion on questions 
connected with the negotiations between the 
Community and the African, Caribbean and Pacific 
States (*). 
Done at Brussels, 28 November 1974. 
The Chairman 
of the Economic and Social Committee 
Henri CANONGE 
H OJ No C 116, 30. 9. 1974. 
Opinion on the proposal for a second Council Directive amending the Directive of 
23 November 1970 concerning additives in feedingstuffs 
The text referred to the Committee was published in Official Journal of the European 
Communities No C 104 of 13 September 1974, pages 93 and 94. 
A. LEGAL BASIS FOR THE OPINION 
On 31 July 1974, the Council referred the abovementioned proposal to the Economic 
and Social Committee under Articles 43 and 198 of the Treaty establishing the European 
Economic Community. 
No C 16/20 Official Journal of the European Communities 23.1. 75 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee drew up its Opinion at its 125th plenary session, 
held in Brussels on 28 November 1974. 
The Opinion is published below: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the referral on 31 July 1974 by the 
Council of the European Communities of the 
proposal for a second Council Directive amending 
the Directive of 23 November 1970 concerning 
additives in feedingstuffs; 
Having regard to Articles 43 and 198 of the Treaty 
establishing the European Economic Community; 
Having regard to the decision taken by its Bureau on 
9 October 1974, instructing the Section for 
Agriculture to prepare the Committee's work on the 
matter; 
Having regard to its previous Opinions on 
feedingstuffs; 
Having regard to the oral report made by the 
Rapporteur, Mr Wick; 
Having regard to the Opinion adopted by the Section 
for Agriculture at its meeting on 7 November 1974; 
Having regard to the discussions at its 125th plenary 
session of 28 November 1974, 
HAS ADOPTED THE FOLLOWING OPINION 
by a unanimous vote: 
The Economic and Social Committee approves the 
proposal submitted by the Commission to the 
Council, subject to the following comments: 
1. General comments 
1.1. The Committee welcomes the proposal, which 
is a further expression of the Commission's concern 
to ensure that Community regulations and 
procedures governing feedingstuffs keep pace with 
scientific and technical progress. 
1.2. The Committee also believes that the proposal 
will help to improve and facilitate intra-Community trade, which has not yet been liberalized to the 
desired extent. 
1.3. On this matter of progress towards trade 
liberalization, the Committee considers it regrettable 
that the Council of Ministers has not yet taken a 
Decision on the proposal for a Directive on straight 
and compound feedingstuffs, which was submitted 
to it by the Commission in November 1971 and was 
commented on at the time by the Committee. 
1.4. The Committee realizes that the proposal now 
before it represents a compromise between the 
situations and legislations in the various Member 
States. However, it would have preferred the 
Commission to have been more precise on certain 
points, such as the scope of the proposed directive 
(definition of the term 'animal'), so as to preclude 
overly flexible or even divergent interpretations by 
the Member States. 
1.5. In the light of the above, the Committee 
would make a number of comments on the various 
Articles of the proposal. 
1.6. Although the toxicology of the products listed 
in Annexes I and II has been studied, nothing at all is 
yet known about the toxicology of the breakdown 
products. 
Until the harmlessness of all the substances has been 
established, their use should be limited wherever 
possible, both as regards the number and the 
quantity of substances used, this being done in 
particular by adopting rearing methods which are 
more hygienic. 
1.7. The Committee recommends that after the 
present revision the complete codified version of the 
Directive, which has already been amended eight 
times, be published in the Official Journal of the 
European Communities. 
2. Comments on particular Articles 
2.1. Article 1, point 1 
The proposed Directive gives a more precise 
definition of the animals which it is intended to cover 
than did the Directive of 23 November 1970. 
23.1.75 Official Journal of the European Communities No C 16/21 
However, the word 'normally' is subjective and thus 
open to a number of interpretations. The Committee 
therefore suggests that a list of the types of animals 
covered be added to complete the definition. 
A special Directive covering pets and animals living 
in the wild state would also be useful, in the 
Committee's view. 
Roe and red deer, for example, are fed manufactured 
compound feedingstuffs on a substantial scale. 
Residues of dangerous substances in such animals 
would pose a much more serious danger to 
consumers than if, for example, dogs and cats did 
not fall within the scope of the proposed Directive. 
2.2. Article 1, point 2 
The wording here is open to different interpretations 
and divergences have been found between the French 
and German versions. 
To clarify matters, the German version should be 
amended as follows: '... diirfen nur mit einem 
einzigen anderen Antibiotikum ...' ('... qu'avec un 
seul autre antibiotique ...', '... with only one single 
other antibiotic...'). This would bring the wording 
into line with that of the Directive of 23 November 
1970. 
According to the German version, an antibiotic may 
also be mixed with a growth promoter, as is 
indicated by the word 'oder' (or). It is desirable that 
this possibility be provided for, and it should be 
expressed without ambiguity in the French version 
too. 
The final part of the sentence (in the French and 
German versions), from '... unless ...', is open to 
several interpretations. It can mean that this 
provision does not apply to listed mixtures or that 
the possibility of forming combinations is to be 
precluded in the case of these mixtures. 
In view of the foregoing, the Committee asks that the 
text in question be amended to read: 
'4. Antibiotics (Annex I (A) and Annex II (A)) 
and growth promoters (Annex I (J) and 
Annex II (E)) may be mixed with only one 
single other antibiotic or growth promoter. 
The mixtures provided for in those Annexes 
shall not be considered mixtures for the 
purposes of this provision.' 
2.3. Article 1, point 5 
It was explained that the new version is intended to 
allow extension of the limit to eight years or a choice 
of limits. The Committee agrees with this provision. 2.4. Article 1, point 7 
The clarification provided by the new wording is 
welcomed. 
2.5. Article 1, point 8 
The French version could be misinterpreted. The 
Committee proposes the following wording: 
'La substance peut etre reprise a l'annexe II, pour 
une periode determinee, si les conditions de 
l'alinea A sous b) et e) sont toujours remplies.' 
Furthermore, instead of 'for a determined period' it 
would be better to say 'for a maximum of two years'. 
This time limit would ensure that particularly 
doubtful substances did not continue to be permitted 
beyond a specific period after removal from Annex I. 
The case for such a limit is made all the stronger by 
the fact that Article 14 rules out restrictions on trade 
in animal products produced using such substances. 
2.6. Article 1, point 9 
The Committee welcomes this provision, which would 
make it possible for new substances included in 
Annex II to be thoroughly tested over a given period 
before being admitted to Annex I or being rejected. 
But the time allowed should not be longer than 
strictly necessary. 
On points 8, 9 and 17 generally, quite apart from its 
above comments on point 8, the Committee considers 
that the limits should be shortened as much as 
possible and should under no circumstances exceed 
three years. 
2.7. Article 1, points 13 and 14 
These paragraphs also lay down labelling 
requirements for substances in Annex II. This 
extension of the labelling obligations is considered 
necessary by the Committee. 
2.8. Article 1, point 16 
The Committee welcome this additional provision, 
which it considers valuable in view of the fact that 
the users of premixtures now include livestock 
rearers themselves. 
Done at Brussels, 28 November 1974. 
The Chairman 
of the Economic and Social Committee 
Henri CANONGE