15. 5. 75 Official  Journal  of the  European  Communities No C 108/65 
Opinion  on the proposal  for a Council  Regulation  amending  Regulation  (EEC)  No 816/70 
laying  down  additional  provisions  for the common  organization  of the market  in wine, 
Regulation  (EEC)  No 817/70  laying  down  special  provisions  relating  to quality  wines 
produced  in specified  regions,  Regulation  (EEC)  No 865/68  on the common  organi-
zation  of the market  in products  processed  from  fruit  and  vegetables  and  Regulation 
(EEC)  No 950/68  on the Common  Customs  Tariff 
The text  referred  to the Committee  was  published  in Official  Journal  of the European 
Communities,  No  C 31 of 8 February  1975,  pages  3 to 24. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 13 November  1974,  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 128th  plenary  session, 
held in Brussels  on 26 and  27 February  1975. 
The Opinion  is published  below: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the referral  on 13 November  1974 
by the Council  of the European  Communities; 
Having  regard  to the Treaty  establishing  the Euro-
pean  Economic  Community,  and  in particular 
Article  198  thereof; 
Having  regard  to the decision  taken  by its Bureau 
on 26 November  1974,  instructing  the Section  for 
Agriculture  to prepare  the  Committee's  work  on 
the matter; 
Having  regard  to its previous  work  on this  subject; 
Having  regard  to the  Opinion  adopted  by  the 
Section  for  Agriculture  at its meeting  on 6 Fe-
bruary  1975; 
Having  regard  to the oral  report  made  by the Rap-
porteur,  Mr  Guillaume; 
Having  regard  to the discussions  at its 128th  plenary 
session  of 26 and  27 February  1975,  sitting  of 
27 February  1975, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a unanimous  vote: 
The Economic  and  Social  Committee  approves  the 
Commission's  proposal,  subject  to the  following 
comments: 1. Preliminary  remarks 
1.1. The  Committee  takes  note  of the  proposals 
which  reveal  the need  to amend  Regulations  (EEC) 
No 816/70  and  (EEC)  No  817/70,  organizing  the 
market  in wine. 
1.2. Most  of the Committee's  comments  are based 
on the Commission's  report  to the Council  on fore-
seeable  planting  and replanting  trends  in the Commu-
nity and  on the ratio  between  production  and  utili-
zation  in the wine  sector,  which  indicates  a risk  of 
structural  surpluses  in the Community. 
1.3. Furthermore,  it is useful  to establish  a link 
with  Regulation  (EEC)  No 865/68  on the common 
organization  of the  market  in products  processed 
from  fruit  and  vegetables. 
1.4. The  experience  acquired  over  the  past  four 
years  shows  that  a number  of changes  need  to be 
made  in the market  organization  machinery. 
1.5. The  Committee  also  notes  that  the Decision 
concerning  the amendment  of the intervention  system 
was incorporated  in a Council  resolution  of 16 July 
No C 108/66 Official  Journal  of the European  Communities 15. 5. 75 
1974,  so that  it would  come  into  force  for the 
1975/76  wine-growing  year. 
1.6. The  Committee  welcomes  the  adoption  of 
any measure  calculated  to improve  the  market 
arrangements  for  products  covered  by  Regula-
tion (EEC)  No 816/70  and  make  for better  use  of 
the funds  of the Guarantee  Section  of the EAGGF. 
But this  objective  must  not disguise  the scale  of the 
financial  means  which  may  be mobilized  under  the 
Guidance  Section. 
1.7. Attempts  should  be made  to ensure  that  those 
concerned  are better  acquainted  with  these  means. 
Procedures,  and particularly  administrative  deadlines, 
should  be kept  to a minimum. 
1.8. Without  denying  the  need  for  measures 
guaranteeing  producers  a certain  level  of income 
in the  short  term,  the  Committee  considers  it 
preferable,  both  for the interests  involved  and  for 
society  as a whole,  that all available  resources  be used 
to improve  production  structures. 
2. General  comments 
2.1. At  the  general  level,  the  Commission's 
proposal  does  not  upset  the  overall  compromise 
reached  in 1970.  The  changes  proposed  are intended 
to obtain  a better  balance  between  resources  and 
demand  in the  light  of the  report  on foreseeable 
planting  trends,  to improve  the  efficiency  of the 
price  and  intervention  system  by bringing  in low-
price  preventive  distillation,  and  to introduce  long-
term  contracts  which  run  from  the beginning  of 
the wine-growing  year  so as to bring  forward 
intervention  to a point  in time  where  it seems  to be 
most  effective.  The  object  of these  measures  is to 
reduce  supply  at the start  of the wine-growing  year 
either  by eliminating  once  and  for all wines  of the 
most  mediocre  quality  or by forming  stocks  of good-
quality  wines  which  can be held  until  the end of the 
wine-growing  year. 2.3. As  regards  wine-growing  potential,  the pro-
visions  concerning  planting  policy  are intended  to 
limit  national  or European  aids  in a strictly  qualita-
tive sense.  Freedom  of planting  could  be abolished 
sooner  or later. 
2.4. In  addition,  a number  of provisions  have 
been  adopted  to promote  an improvement  of quality, 
either  in the vineyard  by placing  a strict  limit  on the 
use of low-grade  vine  varieties  or with  respect  to 
the product  itself  by redefining  minimum  natural 
alcohol  strength  and  enrichment  practices. 
2.5. As  far as trading  policy  is concerned,  the 
proposal  eases  import  restrictions  insofar  as they 
have  become  pointless  owing  to international  deve-
lopments.  But  in other  cases  it is planned  to tighten 
up provisions  in favour  of special  products  which 
are insufficiently  protected. 
2.6. Finally,  mutual  adherence  to registered 
designations  of origin  by the EEC  and  non-member 
countries  will  be assured  within  the framework  of 
the Community  rather  than  by bilateral  agreements. 
2.7. The  financial  note  attached  to the proposal 
shows  that  the  aim  is to reduce  the  intervention 
expenditure  of the EAGGF  while  at the same  time 
improving  its effectiveness.  The  Commission  pro-
poses  two-fold  action  in the  intervention  and 
structural  spheres  which  in its view  will  encourage 
a balance  between  supply  and  demand  and  thus 
make  the Community's  policy  less  costly. 
2.8. In  principle,  the  Committee  approves  the 
Commission's  proposals  as a whole  inasmuch  as 
their  basic  goal  is to improve  the efficiency  of the 
intervention  machinery,  strike  a better  balance 
between  supply  and  demand,  provide  better  pro-
tection  with  respect  to certain  products,  improve 
consumer  safeguards  and  maintain  producers' 
incomes. 
2.2. The  delivery  of vinous  alcohol  for distillation, 
which  in previous  Regulations  was  prescribed  purely 
for reasons  of quality,  now  acquires  a quantitative 
significance  because  of the rise in the percentages  laid 
down  and  can  be regarded  as compulsory  distil-
lation.  It is the Commission's  view  that  this measure 
should  curb  systematic  attempts  to achieve  high 
yields. 2.9. The  changes  made  to the intervention  system 
must  not be dictated  solely  by the concern  to reduce 
EAGGF  expenditure.  And  the political  compromise 
underlying  the decisions  on the various  agricultural 
Regulations  must  not be fundamentally  called  into 
question.  But  the  fact  remains  that  intervention 
mechanisms  should  be strengthened,  while  at the 
15. 5. 75 Official  Journal  of the European  Communities No C 108/67 
same  time  steps  should  be taken  to preclude  any 
encouragement  of structural  surpluses. 
2.10.  The  Committee  therefore  attaches  special 
importance  to the  level  of withdrawal  prices. 
These  must  ensure  a minimum  income  for producers 
during  a serious  crisis  by paying  a fair  price  for 
preventive  distillation,  but  not  encourage  them  to 
produce  specifically  for that  purpose. 
2.11.  The  Committee  approves  the Commission's 
proposals  concerning  planting  but  feels  that  they 
must  take  account  of interregional  economic,  social 
and qualitative  differences. 
2.12.  In  particular,  a more  restrictive  policy 
could  be justified  where  withdrawal  arrangements 
were  used  repeatedly  in certain  zones  or by certain 
producers. 
2.13.  The  Committee  finds  it difficult  to take  a 
stand  on whether  there  is a real  danger  of structural 
surpluses,  because: 
(a) the wine-producing  acreage  only  rose  slightly 
during  the last wine-growing  year,  and  has been 
declining  since  1968/69; 
(b) yields  have  not increased  everywhere,  and  it is 
difficult  to determine  the respective  parts  played 
in the increase  by cyclical  and  structural  factors; 
(c) demand  in the Community  of nine  is potentially 
much  higher  than  in the  Community  of six; 
the new  Member  States  are not wine-producing 
countries  and  consumption  in these  countries  is 
still kept  in check  by high  taxes; 
(d) imports  from  non-member  countries  are consi-
derable  when  Community  production  can  easily 
supply  the internal  market; 
(e) the harmonization  of taxes  at a level  close  to 
that found  in the  major  producing  countries 
would  encourage  a steep  rise  in internal  EEC 
demand;  of course,  this  is not  true  for  those 
Member  States  where  there  are  no taxes  on 
wine; 
(f) exports  to non-member  countries  could  rise 
sharply  if adequate  steps  were  taken; 
(g) up to now  the  extra  market  which  could  be 
opened  up by new  grape-based  products  has 
not been  sufficiently  exploited  or encouraged; (h) finally,  the Committee  wonders  whether  the 
chaptalization  procedures,  their  scale  and  the 
methods  of controlling  them  should  not  be 
reviewed,  now  that  there  is a shortage  on the 
sugar  market  and  a surplus  on the wine  market, 
both  of which  are likely  to last  for some  time. 
It wonders  whether  a reduction  in chaptalization 
could  be made  possible,  in particular  by moni-
toring  the movement  of sugar  or by the addition 
of an indicator,  the solution  adopted  being  that 
which  is the  most  effective  and  which  past 
experience  has  shown  to be the least  trouble-
some. 
3. Specific  comments 
3.1. Article  1 
3.1.1.  The  Committee  approves  the  changes 
proposed  and  in particular  the  inclusion  in Regu-
lation  (EEC)  No 816/70  of all the grape  musts  and 
juices  covered  by  regulation  (EEC)  No  865/68 
on products  processed  from  fruit  and vegetables. 
3.1.2.  It  approves  the deletion  of the phrase  'and 
diluted  vinous  wine',  as this  definition  has  been 
deleted  by  Article  13 (2) of Regulation  (EEC) 
No 2680/72. 
3.1.3.  CCT  subheading  23.05  B 'Argol'  has been 
omitted  from  1 (d), except  in the German  version, 
and should  be inserted. 
3.2. Article  2 
3.2.1.  The  Committee  approves  the principle  of 
withdrawing  wine  for distillation  at the beginning 
of the wine-growing  year  as this  will  aid the rapid 
elimination  of wines  of the most  mediocre  quality 
and reduce  the  distillation  of good-quality  wines 
during  the wine-growing  year. 
3.2.2.  However,  the withdrawal  prices  proposed 
may be too  low  to encourage  producers  to send 
their  wines  for  distillation.  On  the  other  hand, 
they should  not  be too  high  as this  could  help 
create  structural  surpluses.  The  Committee  suggests 
a price  level  close  to that  of the  prices  activating 
the intervention  system. 
3.2.3.  Where  wine  not  corresponding  to the 
standards  laid  down  is available  at the  beginning 
of the  wine-growing  year,  distillation  should  be 
mandatory  and  subject  to fraud  controls. 
No C 108/68 Official  Journal  of the European  Communities 15. 5. 75 
3.2.4.  The  Committee  has  been  particularly 
exercised  by the  problem  posed,  in connection 
with  the withdrawal  procedure,  by the production 
of potable  spirits.  Steps  should  be taken  to avoid 
abnormal  competition  with  high-quality  potable 
spirits  of registered  origin. 
3.2.5.  The  Committee  suggests  that  different 
premiums  be laid  down  depending  on whether  the 
product  obtained  from  distillation  is alcohol  or a 
potable  spirit,  with  the latter  receiving  a lower  level 
of aid. 
3.2.6.  As  there  is a shortage  of sugar  at world  and 
European  level,  the Committee  also  suggests  that 
ways  be studied  of encouraging  the production  of 
concentrated  musts  and  of grape  sugar,  which 
would  enable  the  use  of distillation  as the  sole 
withdrawal  measure  to be limited. 
3.2.7.  Article  2 (a) 
The Committee  asks  that  a new  Article  2 (a) be 
inserted,  amending  Article  2 (2) of Regulation 
(EEC)  No 816/70  by introducing  cost  prices  as a 
factor  in determining  the guide  price. 
3.3. Article  3 
3.3.1.  The  Committee  wants  the activating  price 
for each  type  of wine  to have  a lower  limit  of 90 % 
of its corresponding  guide  price,  in addition  to 
the proposed  upper  limit  of 95 %. 
Article  3 would  then  read  : 
'It may  not,  however,  be less than  90 % or more 
than 95 % of the  corresponding  guide  price.' 
3.4. Article  4 
3.4.1.  The  Commission  proposes  that  the  inter-
vention  system  should  not  be activated  by the 
average  price  on each  market  but by a Community 
weighted  average  price.  The  Committee  considers 
that this  change  will  limit  intervention  considerably, 
and large  quantities  of wine  on regional  markets 
going  through  .a depression  may  not  receive  any 
support. 
3.4.2.  The  Committee  wants  the present  system 
of average  prices  to be retained;  if this  is not done, 
it advocates  introduction  of a regionally  differen-
tiated  intervention  system  which  will  allow  effective 
action  to be taken  on the most  disturbed  markets 
in the light  of the  prices  on those  markets. 
3.5. Article  5 
3.5.1.  The  Committee  approves  the setting  up of 
a system  of permanent  aid for the disposal  of musts. 3.5.2.  It  also  approves  the introduction  of special 
long-term  contracts,  which  may  be concluded  as 
from  1 September,  to help  support  the market  right 
from  the beginning  of the wine-growing  year. 
3.5.3.  As  regards  the mechanisms  for activating 
the different  types  of contract,  the Committee  has 
some  reservations  about  the introduction  of Commu-
nity weighted  average  prices. 
3.5.4.  The  activating  conditions  may  occur  too 
infrequently  for short-term  contracts  to be concluded. 
It should  be possible  to enter  into  regional  storage 
contracts  on the basis  of the prices  in a given  region. 
(See remarks  on Article  4 above.) 
3.5.5.  The  conditions  for  entering  into  special 
long-term  contracts  will  very  rarely  all be fulfilled 
at the same  time  and  so a particularly  advantageous 
intervention  at the beginning  of the  wine-growing 
year will  be precluded.  The  Committee  suggests 
that the requirements  be eased. 
3.5.6.  The  Committee  considers  that  aid  for 
musts  and  concentrated  musts  should  be provided 
on a permanent  basis  and  wants  the use  of these 
products  as wine-enriching  agents  to be encouraged 
by measures  to make  them  competitive  with  sugar, 
except  when  the  making  of quality  wines  psr  is 
involved. 
3.6. Article  6 
3.6.1.  No  comment. 
3.7. Article  7 
3.7.1.  The  conditions  stipulated  for the commen-
cement  of distilling  operations  are even  more  strin-
gent than  those  laid  down  for  the  conclusion  of 
special  long-term  contracts,  in that  the Community 
weighted  average  price  must  be less  than  80 % and 
not 90 % of the respective  activating  price. 
3.7.2.  In  these  circumstances  distillation  should  be 
automatic,  and  not contingent  on a decision  by the 
management  committee. 
3.7.3.  Furthermore,  the prices  proposed  for: 
— normal  distillation,  and 
— distillation  for  the  benefit  of producers  who 
have  entered  into  long-term  contracts, 
15. 5. 75 Official  Journal  of the European  Communities No C 108/69 
are not high  enough.  The  Committee  suggests  that 
in the latter  case  a premium  to cover  risks  be added 
to the  distillation  price  so as to encourage  the 
conclusion  of long-term  contracts,  which  play  an 
important  part  in supporting  the market  and  ensur-
ing regular  supply. 
3.8. Article  8 
3.8.1.  The  Committee  regrets  that,  in the absence 
of a regulation  on alcohol  of agricultural  origin,  it 
is not in a position  to comment  on the conditions 
for balance  on the market  in alcohol. 
3.8.2.  Moreover,  while  the  Committee  agrees 
that the production  of sub-quality  wine  should  not 
be encouraged,  it believes  that  a distillation  price 
limited  to 70 % of the guide  price  is not sufficiently 
attractive. 
3.9. Article  9 
3.9.1.  The  Committee  approves  the extension  of 
the reference  price  procedure  to cover  grape  musts, 
grape  juices  and  bottled  wines. 
3.9.2.  However,  when  calculating  the  level  of 
reference  prices  for wines  account  should  be taken 
of the  products'  total  alcoholic  strength  (actual 
alcoholic  strength  plus  potential  alcoholic  strength). 
3.10.  Articles  10,  11, 12, 13 and  14 
3.10.1.  The  Committee  approves  the  proposed 
changes,  that  is to say  the transfer  to Regulation 
(EEC)  No 816/70  of the passages  concerning  grape 
juices  with  an added  sugar  content  of 30 % which 
are contained  in Regulation  (EEC)  No  865/68. 
3.11.  Article  IS 
3.11.1.  Broadly  speaking,  this Article  is acceptable 
but the  Committee  considers  that  it should  be 
possible  to grant  aids  for the renewal  of vineyards 
in regions  which  have  socio-economic  problems 
(mountains,  hills),  where  such  regions  are recognized 
as being  particularly  suited  to the  production  of 
quality  wines  and  are covered  by regional  develop-
ment  and  land  consolidation  plans. 
3.12.  Article  16 
3.12.1.  The  Committee  notes  with  regret  that  no 
steps  have  been  taken  to speed  up the grubbing  of 
unclassified  vine  varieties,  which  means  that  low-
grade  wine  will  continue  to be produced  until 
1983.  It would  have  been  preferable  to lay down 
a timetable  for the phasing-out  of such  varieties. 3.12.2.  At  the very  least,  Member  States  could  be 
recommended,  under  Article  15, to encourage  re-
planting  where  such  action  is intended  to speed  up 
the grubbing  of unclassified  vine  varieties. 
3.12.3.  This  aid could  be degressive,  being  reduced 
in line  with  the period  of the ban. 
3.13.  Article  17 
3.13.1.  The  Committee  appreciates  the  need  to 
provide  a legal  basis  for the new  planting  system 
and approves  the Commission's  proposals,  since  it 
believes  that  there  is at least  a danger  of cyclical 
surpluses  of limited  duration  necessitating  stricter 
control  of planting.  Moreover,  it considers  that  the 
table  wines  market  and  the market  in quality  wines 
psr are not completely  separate  and  that  surpluses 
on the  latter  would  have  immediate  repercussions 
on the  former. 
3.14.  Article  18 
3.14.1.  The  Committee  approves  the wording  of 
this Article  but regrets  that  up to now  there  have 
been  no such  rules  applying  to the preparation  of 
other  products,  notably  vermouths,  a type  of wine 
whose  quality  is particularly  dependent  on  the 
original  vine  variety  used. 
3.15.  Articles  19 and  20 
3.15.1.  The  Committee  approves  the  proposal 
under  which  the  addition  of sucrose  in aqueous 
solution  is limited  to the new  zone  A I. 
3.15.2.  However,  it questions  the need  to intro-
duce  such  a measure  at Community  level,  since  the 
matter  seems  to be dealt  with  satisfactorily  under 
national  law. 
3.16.  Article  21 
3.16.1.  The  Committee  endorses  the proposal  to 
lay down  conditions  governing  the sweetening  of 
imported  wines  by musts  originating  in the Commu-
nity. 
3.17.  Article  22 
3.17.1.  Article  22 fundamentally  changes  the role 
played  by deliveries  of vinous  alcohol  for distillation. 
Under  Regulation  (EEC)  No 816/70,  such  deliveries 
had a purely  qualitative  purpose  but Article  22 of 
the proposed  amending  regulation  assigns  them  a 
role which  has  an indirect  quantitative  influence 
and is equivalent  to compulsory  distillation. 
No C 108/70 Official  Journal  of the European  Communities 15. 5. 75 
3.17.2.  The  Committee  accepts  this  new  approach 
provided  that  deliveries  of products  for distillation 
are fixed  at a higher  standard  rate  on the basis  of 
forward  estimates,  and  reduced  rates  are  set for 
producers  of quality  wines  psr  and  certain  table 
wines  of recognized  quality. 
3.17.3.  The  Committee  expresses  reservation  about 
the possibility  of discharging  the obligation  to distil 
by deliveries  to the vinegar-producing  industry,  as 
it believes  that  wine  vinegar  must  be made  from 
products  which  comply  with  the  standards  laid 
down  and  not  from  by-products. 
3.18.  Article  23 
3.18.1.  A  majority  of the  Committee  endorses 
the new  text,  which  restricts  the opportunities  for 
the coupage  of a wine  suitable  for yielding  a table 
wine  with  a table  wine,  or with  another  wine 
suitable  for yielding  a table  wine. 
3.18.2.  However,  the Committee  has  misgivings 
as regards  making  it compulsory  for the coupage  of 
a wine  suitable  for yielding  a table  wine  and possess-
ing an alcoholic  strength  of more  than  15°  with  a 
table  wine  possessing  alow  alcoholic  strength  to be 
carried  out in the production  zone  of the former,  and 
asks the Commission  to study  this  question  care-
fully. 
3.19.  Article  24 
3.19.1.  The  Committee  approves  the new  wording 
proposed  for  Article  27 of Regulation  (EEC)  No 
816/70  as it is clearer. 
3.19.2.  ' However,  the qualitative  aspect  must  not 
be excluded  with  respect  to wine  vinegars  and 
special  provisions  should  be adopted  for this product. 
3.20.  Article  25 (1) 
3.20.1.  The  Committee  approves  the rules  impo-
sing a minimum  alcoholic  strength  for  imported 
wines  of 8-5°,  i.e. a strength  which  is at least  equal 
to that  of EEC  table  wines.  However,  in the inte-
rests  of greater  market  equilibrium  it would  be 
advisable  to raise  the  minimum  total  alcoholic 
strength  of table  wines  and  imported  wines  to 9°, 
with their  actual  alcoholic  strength  being  not  less 
than 8*5°. 
3.20.2.  It  is hoped  that  the list of imported  wines 
to which  waivers  are  to apply  will  be limited  to 
wines  bearing  traditional  geographical  indications. 3.20.3.  Paragraph  3 
The indicator  should  be specified  (sucrose). 
3.21.  Article  26 
3.21.1.  The  Committee  endorses  the principle  of 
reciprocal  agreements  to respect  geographical  indi-
cations,  but  wants  the legal  basis  of the Commis-
sion's  negotiating  powers  to be specified. 
3.22.  Article  27 
3.22.1.  The  Committee  would  point  out  to the 
Commission  and  the  Council  that  even  when 
distilling  operations  decided  on at Community  level 
are being  carried  out,  large  quantities  of wine  from 
one Member  State  are  sold  in another  Member 
State  at a price  below  that  paid  for  Community 
distillation,  because  of the saturation  of the market 
in alcohol.  It asks  the Commission  and  the Council 
to institute,  with  the  utmost  urgency,  the  most 
suitable  measures  for ending  this  situation,  which 
is incompatible  with  a proper  functioning  of the 
common  wine  market. 
3.23.  Article  28 
3.23.1.  The  wording  of this  Article  presupposes 
that there  will  be imports  even  when  the  EEC 
market  is sufficiently  supplied  by its own  produc-
tion.  The  proposal  to distil  Community  wine  in 
order  to re-establish  a balanced  market  is absurd 
because  it would  encourage  the entry  of wine  from 
non-member  countries  to the EEC  internal  market. 
But should  it prove  impossible  to limit  imports  to 
a level  which  was  just sufficient  to fulfil  the Commu-
nity's  needs,  consideration  could  be given  to dis-
tilling  surplus  imported  products  under  Community 
supervision.  Special  additional  funds  should  be set 
aside  for such  distilling. 
3.23.2.  Finally,  if in spite  of the abovementioned 
measures  being  taken,  the distillation  of Community 
wine  could  not  be avoided,  individual  producers 
should  be given  permission  to engage  in such  dis-
tillation  although  producers'  associations  would  be 
granted  certain  advantages. 
3.24.  Article  31 
3.24.1.  The  Committee  approves  the  new  defi-
nitions  proposed. 
15. 5. 75 Official  Journal  of the  European  Communities No C 108/71 
3.25.  Article  31 (4a) 
3.25.1.  At  the  end  of Article  31 (4),  add  an 
Article  31 (4a),  reading: 
'4a. Wine  not  suitable  for  yielding  table  wine: 
products  corresponding  to the  definition 
given  in item  9 except  with  regard  to the 
minimum  and  maximum  alcoholic  strengths 
required.' 
3.26.  Article  31 (5),  last  subparagraph 
3.26.1.  The  Committee  points  out that  in practice 
it is impossible  to produce  wines  containing  no 
residual  sugar.  The  following  wording  is therefore 
proposed: 
'However,  in the  case  of wines  from  certain 
wine-growing  areas  to be determined  which  have 
been  produced  without  any  enrichment  and 
contain  not  more  than  5 g/1 of residual  sugar  ...' 
3.27.  Articles  32 and  34 
3.27.1.  With  reference  to Article  32  (1),  the 
Committee  wonders  whether  the subdivision  of zone 
A into  zones  A I and  A II really  serves  any  useful 
purpose,  as the  enrichment  of wines  in this  zone 
is regulated  satisfactorily  by national  legislation. 
With  reference  to Article  32 (2) and  (3),  the Commit-
tee points  out  that  the  vineyards  of Burgundy, 
which  are not  mentioned  specifically  but which  are 
counted  among  the  vineyards  of the  Centre,  are 
included  in zone  C I. But  there  could  be an anomaly 
here  as it seems  that  northern  Burgundy  is to be 
classified  in zone  B. 
3.27.2.  This  becomes  all the more  relevant  when 
we look  at Article  34,  which  raises  the  minimum 
alcoholic  strength  required  for  zone  B wines  from 
7° to 8*5°,  that  is to say  to a figure  which  is half  a 
degree  higher  than  that  laid  down  for  wines  from 
zone  C I (8°)  in Article  6 (2) of Regulation  (EEC) 
No 817/70. 
3.28.  Article  35 (1) 
3.28.1.  It  is inadvisable  to provide  for  a possi-
bility  of authorizing  exceptional  enrichment  inde-
pendent  of any  similar  authorization  with  respect 
to table  wines. 
3.28.2.  Paragraph  2 
The Committee  proposes  that  this  be reworded  to 
read: 
'No wine  with  a total  alcoholic  strength  of less 
than  9'5°  may  be considered  a quality  wine  psr. 
However,  Member  States  may  decide  that  in 
wine-growing  zones  other  than  C II and  C III the total  alcoholic  strength  for  a quality  wine 
psr is to be not less  than  8*5°,  provided  that  such 
wine  has undergone  none  of the processes  specified 
in Article  19 (1) of Regulation  (EEC)  No  816/70.' 
3.29.  Article  36 
3.29.1.  The  Committee  wants  sweetening  by 
means  of sucrose  or a product  containing  sucrose  to 
be expressly  prohibited,  unless  such  a practice 
corresponds  to one  which  is authorized  in a Member 
State  for an equivalent  category  of wine.  Inter  alia 
this is justified  because  the  questions  arising  in 
connection  with  sweetening  are  already  regulated 
in Community  law  by Regulations  (EEC)  No 816/70, 
(EEC)  No  3282/73  and  (EEC)  No  2133/74. 
3.29.2.  Furthermore,  the instruments  and  methods 
for checking  observance  of this  prohibition  should 
be laid  down  at Community  level. 
3.30.  Article  38 
3.30.1.  The  Committee  agrees  with  the  Commis-
sion in so far  as there  is no  method  approved 
at international  level. 
3.31.  Article  39 
3.31.1.  The  Committee  approves  the ban  on using 
the name  of a specified  region  to describe  a table 
wine  in pursuance  of Article  2 of Regulation  (EEC) 
No 817/70. 
3.31.2.  It  trusts  that  the  use  during  the  transi-
tional  period  of the  names  of specified  regions  to 
describe  table  wines  will  only  be authorized  under 
stringent  conditions  which  preclude  any  confusion 
between  the  two  wine  categories. 
3.32.  Financial  note 
3.32.1.  The  desire  to limit  expenditure  arising 
from  the modification  of intervention  arrangements 
and aids  must  not  lead  to producers'  incomes  being 
made  less  secure.  In  particular,  the  Committee 
doubts  the  effectiveness  of arrangements  to with-
draw  products  for distillation  under  which  the price 
paid  for  withdrawal  is too  low  to be attractive. 
The level  of this  price  must  be reviewed  carefully, 
in order  to ensure  that  distillation  at the beginning 
of the  wine-growing  year  is effective  and  to avoid 
encouraging  the formation  of structural  surpluses. 
Done  at Brussels,  27 February  1975. 
The Chairman 
of the  Economic  and  Social  Committee 
Henri  CANONGE 
No C 108/72 Official  Journal  of the  European  Communities 15. 5. 75 
ANNEX 
to the Opinion  of the Economic  and  Social  Committee 
The following  passage  in the Opinion  of the  Section  for Agriculture  was  withdrawn  following 
an amendment  adopted  unanimously  in the  course  of the  proceedings: 
Paragraph  2.13  (h)  (last  sentence): 
'It considers  that  a reduction  in unauthorized  chaptalization  should  be made  possible, 
in particular  by controlling  the  movement  of sugar  or by the  addition  of an indicator,  but 
without  causing  difficulties  for  Community  regions  where  this  practice  is warranted  and 
authorized  by law.' 
Opinion  on the proposal  for a Council  Directive  on the approximation  of the laws  of the 
Member  States  relating  to materials  and  articles  intended  to come  into  contact  with 
foodstuffs 
The text  referred  to the  Committee  was  published  in Official  Journal  of the European 
Communities,  No  C 121  of 11 October  1974,  pages  27 to 30. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 20 August  1974,  the Council  referred  the abovementioned  proposal  to the Economic 
and Social  Committee  under  Article  100  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 128th  plenary  session, 
held in Brussels  on 26 and  27 February  1975. 
The Opinion  is published  below: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  referral  on 21 August  1974 
by the  Council  of the  European  Communities  of 
the proposal  for a Council  Directive  on the approxi-
mation  of the  laws  of the  Member  States  relating 
to materials  and  articles  intended  to come  into 
contact  with  foodstuffs; 
Having  regard  to the  Treaty  establishing  the Euro-
pean  Economic  Community,  and  in particular 
Article  100  thereof; 
Having  regard  to the  decision  taken  by its Bureau 
on 8 October  1974,  instructing  the  Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  to draw  up an Opinion  and  a 
report  on the  matter; Having  regard  to the  Opinion  adopted  by  the 
Section  for  Protection  of the  Environment,  Public 
Health  and  Consumer  Affairs  on 11 February  1975 
and having  regard  to Mrs  Evans'  report; 
Having  regard  to the discussions  at its 128th  plenary 
session  of 26 and  27 February  1975,  sitting  of 27 
February, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a unanimous  vote: 
The Committee  approves  the  proposal  for a Direc-
tive,  subject  to the  following  comments: