No C 138/52 Official Journal of the European Communities 9. 6. 81 
Opinion on the proposal for a Council Directive on the harmonized application of the 
International Convention for safe containers (CSC) in the European Economic 
Community 
The text referred to the Committee has been published in Official Journal of the 
European Communities No C 228 of 8 September 1980, page 13. 
A. LEGAL BASIS FOR THE OPINION 
On 31 July 1980 the Council referred the abovementioned proposal to the Economic 
and Social Committee in accordance with Articles 75 and 84(2) 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 
185th plenary session held in Brussels on 25 and 26 February 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 
Articles 75 and 84 (2) thereof, 
Having regard to the request made by the Council on 
31 July 1980 for an opinion on the proposal for a 
Council Directive on the harmonized application of 
the International Convention for safe containers 
(CSC) in the European Economic Community (*), 
Having regard to the decision taken by its chairman 
on 21 August 1980, under Article 22 of the Rules of 
Procedure, instructing the Section for Transport and 
Communications to draw up an opinion and a report 
on the matter, 
Having regard to the opinion issued by the Section 
for Transport and Communications at its 134th 
meeting, held on 12 November 1980, 
Having regard to the report submitted by the 
rapporteur, Mr Law, 
Having regard to the discussions at its 185th plenary 
session, held on 25 and 26 February 1981 (meeting of 
26 February 1981), 
Whereas the International Convention for safe 
containers (CSC), which was drafted by the United 
Nations' Inter-Governmental Maritime Consultative Organization (IMCO), entered into force on 6 
September 1977 and is open for ratification or 
accession by the Member States, among other 
countries; whereas Council recommendation 
79/487/EEC of 15 May 1979 on the ratification of 
the International Convention for safe containers 
(CSC) (2), on which the Committee delivered a 
favourable opinion on 4 April 1979 (3), urged the 
Member States to ratify this Convention or accede 
thereto before 1 July 1980, 
Whereas only the Federal Republic of Germany, 
France, the United Kingdom, Denmark and Italy 
have so far acceded to the Convention; whereas 
important sea-trading nations such as Belgium and 
the Netherlands have still too do so, 
HAS ADOPTED THE FOLLOWING OPINION 
with no votes against and one abstention: 
The Committee recognizes that the aim of the 
proposed Directive is to ensure Community-level 
harmonization in the drawing-up, application and 
interpretation of IMCO recommendations. 
It does not, however, think that there is a need for a 
Community Directive at the present time. It bases 
this view on the following factors: 
(i) OJ No C 228, 8. 9. 1980, p. 43. (2) OJ No L 125, 22. 5. 1979, p. 18. 
(3) OJ No C 171, 9. 7. 1979, p. 27. 
9. 6. 81 Official Journal of the European Communities No C 138/53 
1. Past experience has shown that a satisfactory 
degree of safety is assured in container transport by 
liner service. 
2.. The text of the International Convention for safe 
containers (CSC) and the recommendation 
concerning the harmonized interpretation and 
application of the CSC adopted by IMCO (Appendix 
to IMCO Document A XI/Res 436 of 22 January 
1980) guarantee a certain standard of safety in 
container transport and do not impede 
competition. 
3. The Committee is unable to see how the 
Commission proposal can in practice lead to any 
improvement or make things easier. Rather, it is 
afraid that the extensive individual measures 
provided for will result in a lot of paperwork without 
enhancing the standard of safety. 
Since the proposal also deviates in part from the 
IMCO interpretations, it is to be feared that 
harmonization at international level will be 
jeopardized. 
Done at Brussels, 26 February 1981. 4. In this connection the proposal also shows a lack 
of awareness of several glaring problems which 
IMCO has already recognized and is making serious 
efforts to solve. This applies in particular to the 
approval of 'existing containers' by the deadline of 
6 September 1982. Since it is a question not merely of 
securing official approval for the containers but of 
having each unit provided with an appropriate CSC 
plate, it is already clear that owners of large container 
fleets will hardly be able to meet these requirements, 
even if the country in which they are domiciled 
acceded to the Convention at a relatively early 
date. 
5. For the above reasons the Committee fears that 
adoption of the Community Directive would entail 
considerable cost disadvantages in international 
competition for container-owners in the Member 
States. 
The Committee therefore recommends that the 
proposed Directive should come into force only 
when all the problems concerning uniform 
implementation of the Convention for safe 
containers (CSC) throughout the world have been 
solved at IMCO level and the CSC has met with 
sufficient worldwide approval. 
The Chairman 
of the 
Economic and Social Committee 
Tomas ROSEINGRAVE