24. 5. 88 Official Journal of the European Communities No C 134/7 
Opinion on the draft Council Directive amending Directive 78/546/EEC on statistical returns 
in respect of carriage of goods by road, as part of regional statistics (*) 
(88/C 134/04) 
On 10 December 1987 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned draft Council Directive. 
The Section for Transport and Communications, which was responsible for preparing the 
Committee's work on the subject, adopted its Opinion on 9 March 1988. The rapporteur 
was Mr Bos. 
At its 254th plenary session (meeting of 23 March) the Economic and Social Committee 
adopted the following Opinion unanimously. 
1. General comments 
1.1. The Explanatory Statement preceding the draft 
Directive amending Directive 78/546/EEC points out 
that the present annual statistics no longer suffice to 
keep track of current trends in the carriage of goods 
by road, and that it is difficult to compare annually-
compiled figures with statistics for other means of 
transport which are received more often. There are 
gaps in the existing statistics; they provide no details on 
the carriage of goods between third countries, (future) 
cabotage traffic or transport to a number of third 
countries. The draft Directive provides for quarterly 
returns of certain data as well as collection of the 
'missing' statistics mentioned above. 
1.2. The Committee is glad that this 10-year old 
Directive is being amended in order to make more 
detailed statistics on the carriage of goods by road 
available, and therefore endorses the proposal. 
1.3. One should not, however, lose sight of the fact 
that all carriage data are to be collected by means of 
surveys of vehicle owners, one reason for this being 
that the Member States are required to dispense with 
all formalities for international transport at internal 
Community frontiers. Given that a considerable volume 
of detailed information on a representative number of 
vehicles will be needed every quarter, quite a large 
sample of vehicle owners will have to be surveyed, and 
a considerable number of owners will be asked for 
returns more than once a year. Providing the required 
data will be administratively difficult for a lot of vehicle 
owners. Many vehicle owners will not be motivated to 
seek out the necessary data, and this will cast doubt on 
the accuracy of their replies to the questions asked in 
surveys and the reliability of the published results. 
1.4. This situation in such a large and complex sector 
as road haulage can also be monitored quarterly by 
means of limited economic surveys aiming to do no 
(j) OJNoC4, 8. 1. 1988, p. 4. more than keep track of the general trend of economic 
activity and several indicators in the sector. (Simple 
surveys of this kind form part of the international 
transport market monitoring system which has been in 
operation for several years and which gives a fairly 
reliable picture of (inter alia) general trends in transport 
activity very soon after the end of the reference period; 
for details see publications in the Europa Transport 
series.) 
1.5. The final part of the title of the Directive '... as 
part of regional statistics' serves little purpose. The 
Section suggests that no geographical references be 
made in the title. 
2. Specific comments 
2.1. Article 1, point 2 
2.1.1. Monitoring the movements of the tractor 
vehicle, rather than the trailer unit, could have a serious 
drawback in the case of combined road/rail and roll-on/ 
roll-off transport. The tractor vehicle does not always 
accompany the trailer unit for the whole of the inter­
national itinerary. Transport to and from ports and 
railway stations within a Member State will be included 
in the statistics as domestic transport and the inter­
national carriage will not be recorded. 
2.1.2. Establishing a sample for survey purposes may 
also be a problem with tractor vehicles; the sample will 
presumably have to be very large, since stratification 
on the basis of payload will not be possible. 
2.2. Article 4, point 7 
In tables C3, C4 and C5 details on cabotage have to be 
entered in box A, so that these data, too, would have 
to be collected as from 1988. This form of transport 
has, however, not yet been authorized. (The Council 
has yet to take a decision on a Commission proposal 
No C 134/8 Official Journal of the European Communities 24. 5. 88 
on cabotage in transport for hire or reward.) The 
Committee is pleased to note that the Commission is 
contemplating amending the proposal to require the 
collection of data on cabotage only when this form of 
transport is authorized. 
2.3. Article 4, point 10 
The Member States are to take the steps necessary to 
obtain 'sufficient' results. This requirement is very 
vague and furthermore each Member State may use 
its own method to calculate the number of tonne-
kilometres. To what extent, then, will the figures pub­
lished by the various Member States be comparable? 
The Committee suggests that the possibility of intro­
ducing a uniform survey and calculation system be 
studied. 
Done at Brussels, 23 March 1988. 
1. The Committee welcomes the Commission pro­
posal and is in general agreement. The Committee 
makes the following observations. 
2. General comments 
2.1. The present proposal must clearly distinguish in 
its demands between meat, either minced or in pieces 
of less than 100 g, which 
a) either enters direct for sale to the buyer, 
b) or passes for further processing. 
(!) OJNoC 18,23. 1. 1988, p. 8. 2.4. Article 4, point 11 
The Commission is to publish 'appropriate' statistical 
results. This wording, too, is very vague. It should be 
borne in mind that some data may be confidential, for 
example figures relating to a market segment where 
during a given quarter only one or a few road hauliers 
were active. 
2.5. Article 4, point 13 
In the course of implementing the proposed changes 
considerable costs will be incurred in connection with 
the registration of cabotage. Cabotage will be freely 
permitted, however, only in 1992 at the earliest, i.e. after 
the expiry of the period during which the Community is 
to make a financial contribution in respect of the new 
work involved. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
2.2. The Committee took note of the Commission's 
declaration that the proposal only applies to meat for 
direct consumption, and that meat intended for further 
processing is being dealt with elsewhere. 
2.3. The Committee welcomes that this proposal will 
eventually be applied to national trade and thereby 
remove the opportunity for fraudulent trade. 
2.4. The Committee recommends that the feasibility 
be examined of placing a limit on the interval between Opinion on the proposal for a Council Directive on health problems affecting the production, 
placing on the market of the Community and importation from third countries of minced 
meat and meat in pieces of less than one hundred grams (*) 
(88/C 134/05) 
On 15 January 1988 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Agriculture and Fisheries, which was responsible for preparing the Com­
mittee's work on the subject, adopted its Opinion on 3 March 1988 in the light of the oral 
report by Mr Storie-Pugh. 
At its 254th plenary session held on 23 and 24 March 1988 (meeting of 23 March 1988), the 
Economic and Social Committee unanimously adopted the following Opinion.