No C 109/22 Official  Journal  of the  European  Communities 19. 9. 74 
The Committee  therefore  proposes  that  after  the  phrase  "clearly  and  indelibly  the 
following..there  should  be inserted  : "The  type  size  to be'used  for  any  wording  must 
be at least  1 mm  x height".' 
Result  of the  vote 
Votes  for : 21 
Votes  against:  25 
Abstentions  : 8. 
OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
on the  proposal  for  a Council  Directive  on the  approximation  of the  laws  of the 
Member  States  relating  to the  installation  of lighting  and  light  signalling  devices  on 
motor  vehicles  and  trailers 
This  document,  which  had  been  referred  to the  Economic  and  Social  Committee,  has 
not been  published. 
A. LEGAL  BASIS  FOR  THE  OPINION 
At its meeting,  held  on 16 January  1974,  the  Council  referred  the  above-mentioned 
proposal  for  a Directive  to the  Economic  and  Social  Committee  in accordance  with 
Article  100  of the Treaty  establishing  the European  Economic  Community. 
The request  for  an Opinion  was  sent  by the  Council  to the  Economic  and  Social 
Committee  on 17 January  1974. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its Opinion  on the  above  matter  at its 
120th  Plenary  Session,  held  in Brussels  on 29 and  30 May  1974. 
The full  text  of the Opinion  is as follows  : 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  request,  dated  17  January 
1974,  from  the President  of the  Council  of the Euro-
pean  Communities  for  an Opinion  on the  proposal 
for a Council  Directive  on the  approximation  of the 
laws  of the  Member  States  relating  to the  installa-
tion of lighting  and  light  signalling  devices  on 
motor  vehicles  and  trailers  ; 
Having  regard  to Article  100  of the  Treaty  esta-
blishing  the European  Economic  Community  ; 
Having  regard  to the  Decision  taken  by its Bureau 
on 29  January  1974  instructing  the  Section  for 
Industry,  Commerce,  Crafts  and  Services  to prepare 
a report  and  an Opinion  on the matter; 
Having  regard  to the  Opinion  delivered  by  the  -
Section  for  Industry,  Commerce,  Crafts  and  Services 
at its meeting  of 8 May  1974  ; Having  regard  to  the  report  submitted  by  Mr 
Masprone,  the Rapporteur  ; 
Having  regard  to  the  discussions  at its  120th 
Plenary  Session,  held  on  29  and  30  May  1974 
(Sitting  of 29 May), 
HAS  ADOPTED  THE  FOLLOWING  OPINION  : 
The Economic  and  Social  Committee  approves  the 
proposal  for  a Directive  subject  to the  following 
comments  : 
1. Although  the  draft  Directive  as a general  rule 
lays down  precise  rules  on the  colour  of the  various 
lighting  devices,  the  Commission  proposes  two 
colours  — white  and  selective  yellow  — for  dipped-
19. 9. 74 Official  Journal  of the  European  Communities No C 109/23 
beam  and  main-beam  headlights,  choice  between 
the two  being  left  to the  user.  The  Committee 
approves  the  Commission's  solution  since  neither  of 
the two  colours  has  real,  overriding  advantages  over 
the other. 
2. The  provisions  concerning  the  alignment  of 
the dipped  beam  and  the  checking  procedures  do 
not seem  to  be  sufficiently  clear  to  obviate 
conflicting  interpretations. 
3. For  instance,  no mention  is made  of the  basis 
on which  the  inclination  of the  beam  is to be 
measured  and,  in particular,  the  necessary  instruc-
tions  regarding  the  demarcation  line  of the  'Euro-
pean  beam'  are  not  given.  What  is more,  the provi-
sions  themselves  seem  extremely  restrictive  and 
would  require  troublesome  and  sophisticated 
devices.  It is not  appropriate  to specify  an initial 
aim-setting  for  passing  (dipped  headlight)  beams 
because  control  of initial  aim  is essentially  an in-use 
problem,  since  aim  can  be varied  at will  by the 
user.  Different  types  of vehicle  require  different 
initial  aim-settings  to take  account  of factors  such 
as the  variation  in headlamp  mounting  heights,  the 
nature  of vehicle  tilt with  load  and  the  proportion 
of time  spent  on the  road  in various  conditions  of 
loading.  For  these  reasons  the Committee  calls  upon 
the Commission  to delete  the abovementioned  provi-
sions  from  the  Directive  pending  better  tests  and 
clarification  of controversial  points. 
As a rider  to this  and  in order  to rectify  certain 
shortcomings  of  the  document,  the  Committee 
pronounces  as follows  : 
4. The  proposed  Directive  stipulates  that  the 
initial  vertical  alignment  of the  dipped  beam  must 
be 1-5  %. The  Committee  considers  that  the  initial 
setting  is pointlessly  restrictive  and  troublesome, 
apart  from  the fact  that  it is difficult  to adhere  to in 
practice  since  no tolerance  is stated.  Tolerances  are 
vital  to take  account  of both  measuring  errors  and 
the inevitable  inaccuracies  of instrumentation. 
5. In  addition,  the  attitude  of a given  vehicle 
resulting  from  changes  in loading  conditions  is not 
standard  in relation  to the initial  alignment.  It tends 
in most  cases  to become  higher  or lower  according to the  design  of the  vehicle  (depending  on whether 
the vehicle  has  its engine  at the  front  and  boot  at 
the back  or vice  versa). 
6. As  a result,  the provisions  concerning  the align-
ment  of the  headlamps  should  be  reviewed,  to 
provide  that  the  initial  aim-setting  for  dipped  beam 
headlights  should  be determined  by the  manufac-
turer  and  to include  requirements  to control  the 
extent  to which  the  aim  of dipped  beams  varies 
with  load.  This  requirement  should  be expressed 
also in terms  of a maximum  permitted  range  of vari-
ation  in the  .vertical  orientation  of,  the lamps. 
Changes  are  proposed  in point  2 of Chapter  III of 
the report  of the  Section  for  Industry,  Commerce, 
Crafts  and  Services. 
7. The  Committee  observes  also  that  it is not 
clear  how  the  weight  of the  passengers  and  the 
baggage  is to be distributed.  This  should  be speci-
fied more  exactly.  Furthermore,  certain  loading 
conditions  run  counter  to any  reasonable  criterion 
of safety. 
8. In  this  connection  the  Committee  refers  to 
point  4 in Chapter  III of the  report,  in which  the 
Section  for Industry,  Commerce,  Crafts  and  Services 
makes  concrete  proposals. 
9. As  regards  the  position  of the  rear  fog  light, 
the Committee  does  not  consider  that  the passage  in 
the proposed  Directive  which  requires  that  in all 
cases  the distance  between  the rear  fog  light  and  the 
stop light  must  be greater  than  100  mm  is neces-
sary.  Driving  in fog  is done  with  special  care,  and 
drivers  base  their  manner  of driving  and  the  safety 
distance  between  their  own  vehicles  and  those  in 
front  of them  on their  fog  lights.  This  being  so, and 
bearing  in mind  the low  speeds  which  apply  in such 
cases,  it can  be concluded  that  the  importance  of 
being  able  to see  the  stop  lights  is less  than  it 
would  — rightly  — be under  normal  atmospheric 
conditions.  Consequently,  the  requirement  for  a 
minimum  distance  between  the  two  lights  is 
needlessly  restrictive. 
Done  at Brussels,  29 May  1974. 
The Chairman 
of the 
Economic  and  Social  Committee 
Alfons  LAPPAS