26. 6. 89 Official Journal of the European Communities No C 159/21 
4.6. Moreover, in view of the complexity of the new 
system proposed, the reliability of statistical infor­
mation may suffer, especially in the outlying countries, 
from the lack of technical facilities and training for the 
staff responsible for collecting and processing statistics. 
Another technical problem will affect Luxembourg, 
which will need to strengthen its administrative services 
Done at Brussels, 26 April 1989. 
1. Introduction 
1.1. Directive 80/1263/EEC of 4 December 1980 (2) 
provides as follows: 
a) when the holder of a driving licence moves to 
another Member State his/her original licence 
remains valid for one year but must be exchanged 
for a licence issued by the other Member State 
before the end of that period; 
b) a Community model driving licence is to be intro­
duced with effect from 1 January 1986. 
1.2. There are difficulties in comparing driving 
licences issued by different Member States. There are 
disparities as regards: 
a) categories of vehicle; 
b) period of validity; 
c) driving test requirements. 
t1) OJNoC48, 27. 2. 1989, p. 1. 
(2) OJ No L 375, 31. 12. 1980, p. 1. which currently benefit from collaboration with the 
Belgian authorities under the Belgo-Luxembourg Econ­
omic Union (BLEU). It would be a good idea if, in 
addition to any introduction of a new system, the 
Commission provides at the same time adequate assist­
ance with technical, training and financial facilities. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
1.3. The Commission work programme for 1985 
states that the Commission is to submit a proposal for 
making driving licences valid throughout the Com­
munity, regardless of the Member State in which the 
holder is resident. 
There are also to be more favourable arrangements for 
the disabled and invalids. 
1.4. In order to fulfil these commitments the Com­
mission is proposing that Directive 80/1263/EEC be 
replaced by a new Directive. 
2. General comments 
2.1. The Committee believes that driving licences 
should be harmonized in the EC, for technical and also 
psychological reasons. 
2.1.1. It is of course desirable from the technical 
point of view that the same rules should apply in all 
Member States so that all driving licences have the same 
value. Opinion on the proposal for a Council Directive on the driving licence (*) 
(89/C 159/08) 
On 21 December 1988 the Council decided to consult the Economic and Social Committee, 
under Article 75 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Transport and Communications, which was responsible for preparing the 
Committee's work on the subject, adopted its Opinion on 12 April 1989. The rapporteur 
was Mr Tukker. 
At its 265th plenary session (meeting of 26 April) the Economic and Social Committee 
adopted the following Opinion by a large majority with 4 abstentions. 
No C 159/22 Official Journal of the European Communities 26. 6. 89 
2.1.2. Harmonization is also psychologically impor­
tant for the People's Europe. People would be brought 
into contact with a Directive which affects, and will be 
welcomed by, virtually every EEC citizen. As a result 
people would begin to appreciate that steps are being 
taken to further the integration of Europe. 
3. Specific comments 
3.1. Article 4(1) 
These rules are already in force in most Member States. 
The categories already appear on the EC driving licence. 
3.2. Article 4(3) 
This would involve some change for three Member 
States. 
3.3. Article 4(4) 
Introduction of the 400 cm3 threshold for motorcycles. 
Already exists in some Member States. 
If adopted, a sufficient transitional period should be 
allowed. 
3.4. Article 4(5) 
The Committee supports the introduction of specific 
licences for these categories, particularly the proposals 
for categories C and D. 
3.4.1. Category C 
Vehicles heavier than 3 500 kg are in effect lorries with 
quite different characteristics from private cars. They 
are larger and harder to manoeuvre, e.g. when 
reversing. 
3.4.2. Category D 
Vehicles with less than 8 passenger seats (not counting 
the driver's seat) include estate cars and vehicles for the 
carriage of workmen which are nonetheless the size of 
normal cars. 
Vehicles with 8 or more passenger seats (not counting 
the driver's seat) can be described as minibuses. The 
situation regarding responsibility is different; roadhold-
ing characteristics are different and manoeuvring is 
more difficult. More stringent training and a corre­
sponding licence are thus needed. 
3.4.3. Categories C and E 
See under C. 
3.4.4. Categories D and E 
See under D. 3.4.5. The Committee feels that more stringent driv­
ing skill requirements are needed for the categories of 
vehicle listed in Article 4(5) but that the group 1 medical 
requirements are sufficient. 
3.4.6. Article 4(5) is a controversial point, as the 
United Kingdom and Ireland have different standards 
from other Member States. Furthermore, minibuses 
play an important role in both these countries. Opinions 
are in any case divided even in those two countries and 
among their representatives. 
3.5. Article 8 
See point 3.4.5 regarding the requirements for the cate­
gories of vehicle listed in Article 4.5, and the group I 
medical requirements. 
3.6. Article 9 
When a single uniform driving licence is introduced in 
the EC, it should have the same period of validity in 
all Member States. 
3.7. Article 10(2) 
A resident of a Member State who moves to another 
Member State may apply for a driving licence in his/ 
her new country of residence. In this case he/she must, 
however, surrender the licence issued by his/her original 
country of residence. He/she is, however, not obliged 
to apply for a new licence, as the original licence is and 
remains valid in other Member States regardless of 
where the holder is resident. 
3.8. Article 10(3) 
It would be unthinkable for a Member State issuing a 
licence to a citizen of a non-Community country co 
withdraw the original licence issued by the non-Com­
munity country. In most countries driving licences, like 
passports, remain the property of the State and cannot 
thus be withdrawn by another State. 
3.9. Annexes 
It is difficult to assess the annexes. 
3.9.1. Point 6 of the comments in Annex 1 (p. 19) 
states that: 
Member States shall have the right to: 
— dispense with the photograph requirement, 
— replace the permanent place of residence by the 
postal address. 
The Committee does not support these provisions and 
considers that the photograph and the exact address 
are, on the contrary, necessary in order to prevent 
fraud. 
26. 6. 89 Official Journal of the European Communities No C 159/23 
3.9.2. Annex 2 is very long and it may be asked 
whether all the requirements listed are really necessary. 3.9.3. The sub-categories C + E and D + E should be 
added to group I in point 1.1 of Annex 3. 
Done at Brussels, 26 April 1989. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
Opinion on the proposal for a Council Directive on speed limits for certain categories of 
motor vehicles in the Community (l) 
(89/C 159/09) 
On 26 Janu.iry 1989 the < <mncil decided, in accordance with Article 75 of the Treaty 
establishing the European E<^>nomic Community, to consult the Economic and Social Com­
mittee on the abovementioned proposal. 
The Section for Transport and Communications, which was responsible for preparing the 
Committee's work on the subject, adopted its Opinion on 12 April 1989. The rapporteur 
was Mr Cavazzuti. 
At its 265th plenary session (meeting of 26 April 1989), the Economic and Social Committee 
adopted the following Opinion by a substantial majority, with one dissenting vote. 
1. The Committee endorses the Commission's aim 
of standardizing road traffic regulations in the Com­
munity. 
2. The Committee notes that the proposed Directive 
covers only certain aspects (introduction of differen­
tiated speed limits according to the characteristics of 
vehicles and roads) and agrees with this pragmatic 
approach. It basically endorses the Commission pro­
posal, but would make the following comments. 
3. It would ask the Commission to complete the rest 
of its work in this area as soon as possible by drafting 
general rules for road traffic and for cars. The Commit­
tee hopes that the points (both general and specific) 
made in its Opinion of 21 October 1987 (2) on speed 
limits will be given due consideration. 
(') OJ No C 33, 9. 2. 1989, p. 9. 
(2) OJ No C 347, 22. 12. 1987. 4. Although the Commission proposal concerned 
does not mention the 1987 Opinion as such, the Com­
mittee notes that the two are broadly similar. 
5. The explanatory memorandum is somewhat cur­
sory as it covers traffic of all kinds (goods vehicles, 
public transport and private vehicles). The fact that it 
is so sweeping means that, in addition to sounding 
slightly unconvincing, there are frequent inaccuracies, 
e.g. as regards the link between accidents and different 
types of road, and the factors determining the impact 
in an accident (points 5 and 6). 
6. To be effective, safety policy requires coordinated 
action, the objective being to reduce the likelihood of 
accidents. Sensible road traffic rules will help to achieve 
this. 
7. The Committee therefore hopes that the recitals 
will be reworded so as to give priority to this objective