19. 11. 84 Official Journal of the European Communities No C 307/21 
— fight unfair shipping competition from certain third 
countries, 
— continue stepping up the efforts to achieve greater use 
of ERDF non-quota measures in the areas hit by the 
shipbuilding crisis, 
— include specific measures such as early retirement in 
the revision of the Social Fund, 
— encourage European level research and development 
of the shipbuilding sector. 
4. Consideration should also be given in a future 
opinion to the way in which an international Community 
maritime policy can support Community shipbuilding by 
means of international shipping agreements with 
non-Community countries. The Community must show a 
united front in these agreements, and use all its 
negotiating strength. 
Thus, if cargoes are to continue being transported in 
conditions of free competition, demand for maritime 
Done at Brussels, 26 September 1984. 
Francois CEYRAC 
Opinion on the proposal for a Council Regulation on the designations used in the marketing of 
milk and milk products 
(84/C 307/08) 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 111 of 26 April 1984, page 7. 
A. LEGAL BASIS FOR THE OPINION 
On 13 April 1984 the Council decided to consult the Economic and Social Committee, under 
Articles 43 and 198 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
Procedure 
The Section for Agriculture, which was responsible for preparing the Committee's work on the 
subject, adopted its opinion on 6 September 1984, in the light of the report by Mr 
Strauss. transport services must be strengthened, and this in turn 
will stimulate demand for new ships. 
The Community must thus start making a serious effort 
to reach a common EEC position as soon as possible, in 
order to define a 'strategic dimension' for Community 
shipbuilding as such; 'strategic' with reference (a) to the 
maritime traffic fleet of this major economic area, and (b) 
to all the possible 'integration synergies' (induced effects, 
research, etc.) through which use can be made of an 
industrial dimension which has long been lost at national 
level. 
Determination of a 'minimum healthy level' is an essential 
prerequisite for effective international action with a view 
to orderly marketing, and a vital incentive for 
governments and industries to proceed with 
rationalization. 
5. While reiterating its support for the draft Directive, 
the Committee feels it vital that precise guidelines are 
drawn up and adopted as soon as possible, in order to be 
able to develop measures which, suitably coordinated, 
can form the basis of an overall policy for the sector. 
The Chairman 
of the Economic and Social Committee 
No C 307/22 Official Journal of the European Communities 19. 11. 84 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
At its 219th plenary session (meeting of 26 September 1984) the Economic and Social 
Committee adopted the following opinion by 56 votes to 11 with six abstentions. 
The Committee supports the Commission proposals. It 
believes, however, that these proposals should be only a 
first step towards the introduction of rules governing the 
manufacture, properties, quality, advertising and 
packaging of milk and milk products and of their 
imitations and substitutes. 
The Committee shares the view of the Commission that 
'manufacturers have often been in a position to present 
imitation products in such a way as to confuse the 
consumer. Community rules must, therefore, be adopted 
to give a more precise definition of the composition, 
ingredients and quality of products for which the 
traditional designations of milk and its derivatives are 
reserved'. It is their opinion that it is necessary to adopt 
designations which will enable the consumer to clearly 
distinguish between genuine dairy products and 
substitutes. However, the Committee is also of the view 
that the definition of dairy products should not be made 
so restrictive as to constrain the dairy industry from 
adapting to changes in technology and market 
requirements whilst not placing similar restrictions on the 
manufacture of substitute and imitation products. 
The Committee believes that the proposed Regulation 
would afford a considerable degree of protection to 
consumers. 
The Committee notes that the proposed Regulation was 
to enter into force on 1 May 1984. It is now unlikely to 
become operative before 1 January 1985. It is urged that 
the Regulation should be introduced as rapidly as 
possible. 
The Committee is concerned that the minimum 
percentage fat content figures mentioned in the 
definitions for certain dairy products could lead to a 
lowering of standards where at present more stringent 
national standards pertain. It is therefore suggested that 
this matter should be examined further with a view to 
seeing how such a deterioration in standards could be 
avoided. 
The adoption of the proposed Regulation could be a first 
step towards the harmonization of compositional 
standards of milk and dairy products offered for sale in 
the various Member States of the Community. While 
greater harmonization may be desirable it will be essential 
to ensure that the regional varieties of various dairy 
products currently on offer to consumers can be 
maintained. The Committee agrees that substitutes and imitation 
products should not carry the same names as the genuine 
dairy products. 
Articles 
The Committee agrees with the principles of the Articles 
in the proposed Regulation but offers the following 
comments: 
Article 1.1 
The Regulation should in no way conflict with the 
continued upholding of standards for individual 
products, such as the various types of cheese. 
Article 2.1 
The Committee agrees that where a dairy product is 
incorporated as an ingredient in a foodstuff, such an 
ingredient must comply with the designations set out in 
the Annex. For example, butter cake must contain butter, 
as defined. 
Article 2.3 
As the proposed Regulation will not now come into force 
by 1 May 1984 the relevant lists should be provided 
within 12 months of the Regulation having been 
adopted. 
The difficulty of asking Member States to provide the 
Commission with a list of products which they consider as 
meeting, on their territory, the conditions set out in 
paragraph 2 is that the designation may not be 
automatically recognized by other Member States. It will 
therefore be necessary for the Commission to publish a 
list of products which they consider to fall within the 
scope of Article 2.3. It will also be necessary for all 
Member States to recognize that products on the lists will 
not fall within the scope of the Regulation. 
Designations 
Milk 
The definition of milk should be sub-divided into two 
clauses: 
19. If. 84 Official Journal of the European Communities No C 307/23 
(i) that as derived from milk of cows, to be given the 
specific designations laid down in Article 3 of 
Regulation (EEC) No 1411/71; 
(ii) that as derived from milk of buffaloes, ewes, goats or 
other mammals, to be designated as buffalo milk, 
ewe milk, goat milk or milk of the other mammal in 
question. 
Where a dairy product is derived from buffalo, ewe or 
goat milk or the milk of another mammal this should be 
included in the designation of that product. 
Milk powder 
The definition should be changed to read: 
'the powdered product obtained by removal of water 
from milk consistent with current processing techniques 
and market requirements. (Current drying techniques of 
milk do not allow the complete elimination of water). 
This would accord with Directive 76/118/ EEC in as far 
as it pertains to milk powder.' 
Whey powder, cream powder and buttermilk powder 
The definition of these items should be aligned with the 
amended definition of milk powder to take account of the 
fact that current drying techniques of whey, cream and 
buttermilk do not allow the complete elimination of 
water. This would accord with Directive 76/118/EEC in 
as far as it pertains to cream powder. The definitions 
should also relate to the 'powdered product' rather than 
the 'solid product'. 
Butter 
The definition of butter should take account of the 
existence of salted butter. The definition should, 
therefore, be extended to read as follows: 
'The product obtained exclusively from milk or cream in 
the form of a solid, malleable water-in-fat emulsion 
containing not less than $2% butterfat for unsalted 
butter and not less than 80% butterfat for butter with 
Done at Brussels, 26 September 1984. more than 0,1% but not more than 3% added salt. 
Where butter contains more than 3 % added salt then the 
minimum butterfat level may fall to 78 %, provided that 
the percentage by which the butterfat falls below 80 % 
does not exceed the percentage by which the salt exceeds 
3%: 
Cheese 
The proposed definition is too restrictive since it would 
not allow buttermilk or milk powder or other materials 
obtained from milk to be used in the manufacture of 
cheese; nor might it allow the use of new technology such 
as ultra-filtration. The FAO/WHO Codex Alimentarius 
definition should be adopted. This is as follows: 
'(a) by coagulating milk, skimmed milk, partly skimmed 
milk, cream, whey cream, or buttermilk or any 
combination of these materials, through the action 
of a milk coagulating enzyme and by partially 
draining the whey resulting from such coagulation, 
or 
(b) by processing techniques involving coagulation of 
milk and/or materials obtained from milk which 
give an end product which has the same essential, 
physical, chemical and organoleptic characteristics 
as the product defined under (a).' 
Processed cheese 
(To follow the definition of cheese and precede the 
definition of whey cheese in the Commission's 
proposal). 
'The product obtained from cheese by emulsification 
using heat and emulsifying salts.' 
Curdled milk, fermented milk (yoghurt, etc.) 
To allow for the inclusion of yoghurt in the description, 
the definition should read: 
'. . . enzymes, yeast or other bacterial cultures and 
rennet'. 
The Chairman 
of the Economic and Social Committee 
Francois CEYRAC