15.12.  75 Official  Journal  of the European  Communities No C 286/37 
The distinction  between  sensitive  products,  semi-
sensitive  products  and  non-sensitive  products  is in 
keeping  with  changing  economic  circumstances.  The 
division  of  the  various  products  into  these 
categories  is closely  bound  up with  the development 
of the  economic  situation.  A non-sensitive  product 
may,  in the space  of a few  months  or a few  weeks, 
unexpectedly  become  a sensitive  product.  The 
removal  of ceilings  for non-sensitive  products  should 
at all  events  be  dependent  upon  the  prior 
establishment  of an effective  warning  and  safeguard 
system. 
4.12.  For  the same  reason,  it cannot  be said  here 
and now  that  tariff  quotas  are  no longer  necessary. 
In view  of the difficulties  encountered  in developing 
Done  at Brussels,  24 September  1975. an effective  rapid  monitoring  system,  the  fixing  of 
tariff  quotas  has,  up till now,  proved  itself  to be the 
only practical  method  of ensuring  that  quotas  are 
not exceeded.  It may,  therefore,  under  certain 
circumstances,  continue  to be necessary  to employ 
this method. 
4.13.  In  conclusion,  the Committee  considers  that 
the future  development  of the  Generalized  Tariff 
Preferences  Scheme  should  be regarded  above  all as a 
complementary  instrument  of  Community 
cooperation  in the development  of a number  of third 
countries  which  recognize  that  economic 
interdependence  is a decisive  factor  in joint  economic 
and social  progress. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Directive  fixing  the maximum  level  of erucic 
acid in fats  and  oil and  margarine  for food 
The text  referred  to the  Committee  was  published  in Official  Journal  of  the 
European  Communities  No  C 150  of 5 July  1975,  page  5. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 3 July  1975,  the Council  referred  the abovementioned  proposal  to the  Economic 
and Social  Committee  under  Article  198  of the  Treaty  establishing  the  European 
Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 133rd  plenary  session, 
held in Brussels  on 24 and  25 September  1975. 
The Opinion  is published  below: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to  the  Treaty  establishing  the 
European  Economic  Community,  and  in particular 
Article  198  thereof; 
Having  regard  to the request  made  by the Council  of 
the European  Communities  on 4 July  1975  for  an 
Opinion  on the  proposal  for  a Council  Directive 
fixing  the maximum  level  of erucic  acid  in fats  and 
oil and  margarine  for food; Having  regard  to the decision  taken  by its Bureau  on 
15 July  1975,  instructing  the Section  for  Protection 
of the  Environment,  Public  Health  and  Consumer 
Affairs  to draw  up an Opinion  and  a report  on the 
above  matter; 
Having  regard  to the  Opinion  issued  by the Section 
for Protection  of the  Environment,  Public  Health 
and Consumer  Affairs  on 9 September  1975,  and  the 
Report  submitted  by Mr De Grave; 
No C 286/38 Official  Journal  of the  European  Communities 15. 12. 75 
Having  regard  to the  discussions  at its 133rd  plenary 
session  held  on 24 and  25 September  1975; 
Whereas  in its Opinion  of 16 December  1974,  the 
Scientific  Committee  for  Food  emphasized  that  when 
colza  oils  were  used  for  human  consumption, 
preference  should  be given  to those  oils  with  low 
levels  of long-chain  fatty  acids  (C 22 or higher); 
Whereas  the  Scientific  Committee  believes  that  the 
effects  reported  for  colza  may  not  be unique  to these 
oils and  that  further  research  on  long-chain  fatty 
acids  and  on oils  and  fats  used  in food  is necessary, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a majority  vote  with  five  votes  against: 
The Economic  and  Social  Committee  approves  the 
proposal  for  a Directive  but  has  the  following 
comments  to make: 
1. General  comments 
1.1. The  Committee  considers  that  in the  present 
state  of scientific  knowledge  surveyed,  among  others, 
by the  Scientific  Committee  for  Food,  the  adoption 
of precautionary  measures  to prevent  any  risk  to 
consumers'  health  is justified. 
1.2. In  view  of the  uncertainty  as to the  real 
causes  of  the  undesirable  effects  (primary 
myocarditis,  slowing  down  of  growth,  etc.),  an 
aspect  touched  upon  in points  2 and  4 of the 
explanatory  note,  the  Committee  urges  that  current 
research  on colza  oil be continued  and  extended  to 
other  edible  oils,  particularly  those  with  high  levels 
of saturated  fatty  acids  and  long-chain  fatty  acids. 
1.3. The  Committee  considers  that  consumer 
protection  can  be achieved  simultaneously  through 
(a) regulations  intended  for  the  population  as  a 
whole,  and  (b)  appropriate  labelling  to enable  the 
individual  consumer  to decide  what  to eat  and  what 
not to eat. 
1.4. The  Committee  is  not  unaware  of  the 
qualitative  and  quantitative  difficulties  involved  in 
specifying  composition  and  use  on product  labels. 
These  difficulties  include: — variability  of composition, 
— significant  alterations  undergone  by  the  raw 
material  incorporated  in the finished  product. 
The Committee  nevertheless  trusts  that  a satisfactory 
solution  will  be found  to this  problem  of labelling 
within  the  more  general  framework  of the  draft 
Directive  on margarine  (under  study  for  many  years) 
and the  draft  Directive  on edible  oils  and  fats  (in 
preparation).  These  proposals  are  intended  to solve  a 
complex  of problems  of which  erucic  acid  forms  but 
one aspect. 
1.5. The  Committee  hopes  that  the  Commission 
will ensure  that  seeds  of the  new  varieties  are 
available  in  good  time  to  all  Member  States 
producing  colza. 
2. Specific  comments 
2.1. First  recital 
2.1.1.  The  Committee  points  out  that  the  notion 
of 'large  quantities'  of colza  does  not  appear  in the 
report  of the  Scientific  Committee.  Likewise,  the 
statement  that  'the  applicability  of these  undesirable 
effects  to  man  has  not  been  completely 
demonstrated'  misrepresents  the  conclusion  of the 
Scientific  Committee,  which  was  that  'the 
investigations  and  studies  conducted  up to now  on 
man,  which  have  been  few,  have  not  provided 
evidence  of adverse  effects'. 
The recital  should  be changed  accordingly,  with  the 
word  'completely'  being  deleted. 
2.2. Article  1 
2.2.1.  The  Committee  notes  that  paragraph  (b)  of 
Article  1 is unclear.  The  aim  should  be to ensure 
that when  preparations,  or compound  foods  made 
with  fats  and  oils,  are  marketed  for  human 
consumption,  they  do  not  contain  higher  levels  of 
erucic  acid  than  are  laid  down  in Article  2. The 
marketing  of colza  oil at any  earlier  stage  should  not 
be prohibited.  The  Committee  therefore  proposes 
that the  Commission  should  redraft  Article  1 (b) to 
make  this  point  clear. 
15.12.  75 Official  Journal  of the  European  Communities No C 286/39 
2.2.2.  The  Committee  also  draws  attention  to the 
fact that  as it stands  the Directive  does  not apply  to 
preparations  or foods  made  with  fats  and  oils.  It 
would  like  to see  identical  protection,  whether  the 
food  is prepared  at home,  in institutions,  by caterers 
and restaurateurs,  or by the food  industry.  The  title 
and text  of the Directive  should  therefore  be brought 
up to date. 
Done  at Brussels,  24 September  1975. 2.2.3.  A  new  paragraph  could  be added,  extending 
the concept  of 'products  referred  to in Article  V so 
as to make  Article  2 applicable  to preparations  and 
to prohibit  the  marketing  of manufactured  or 
imported  products  with  an erucic  acid  content  higher 
than that  specified  in Article  2. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the  proposal  for  a Council  Regulation  amending  Regulation  (EEC)  No 
657/75  on the standard  quality  for colza  and  rape  seed 
The text  referred  to the  Committee  was  published  in Official  Journal  of  the 
European  Communities  No  C 150  of 5 July  1975,  page  6. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 3 July  1975,  the Council  referred  the abovementioned  proposal  to the Economic 
and Social  Committee  under  Article  198  of the  Treaty  establishing  the  European 
Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 133rd  plenary  session, 
held in Brussels  on 24 and  25 September  1975. 
The Opinion  is published  below: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  request  for an Opinion  made 
by the Council  on 3 July  1975; 
Having  regard  to  the  Treaty  establishing  the 
European  Economic  Community,  and  in particular 
Article  198  thereof; 
Having  regard  to the decision  taken  by its Bureau  on 
15 July  1975,  instructing  the Section  for Agriculture 
to draw  up an Opinion  on the matter; Having  regard  to the  oral  report  made  by  the 
Rapporteur,  Mr Schnieders; 
Having  regard  to the Opinion  issued  by the Section 
for Agriculture  at its meeting  on 15 September  1975; 
Having  regard  to the discussions  at its 133rd  plenary 
session,  held  on 24 and  25 September  1975;