19. 9. 74 Official  Journal  of the  European  Communities No C 109/19 
— products  whose  density  cannot  be kept  suffi-
ciently  constant  during  packing  operations 
despite  considerable  technical  efforts, 
— products  the  packing  of which  demands  more 
than  one  operation, 
— products  with  a high  unit  weight,  i.e.  products 
composed  of pieces,  fragments  or grains  the 
maximum  unit  weight  of which  is greater  than 
or equal  to the maximum  permitted  error  corres-
ponding  to  the  nominal  weight  of  the prepackage  which  contains  them,  as set  out  in 
the table  in sub-section  3.2 (Category  'B'), 
— products  with  gaseous  inclusions,  the  flow 
characteristics  of which  cannot  be kept  constant 
despite  considerable  technical  efforts. 
Done  at Brussels,  29 May  1974. 
The Chairman 
of the 
Economic  and  Social  Committee 
Alfons  LAPPAS 
OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
on the  proposal  for  a Council  Directive  amending  for  the  fifth  time  the  Council 
Directive  of 27 June  1967  concerning  the  approximation  of the  laws,  regulations  and 
administrative  provisions  relating  to the  classification,  packaging  and  labelling  of 
dangerous  substances 
The text  referred  to the  Committee  has  been  published  in Official  Journal  of  the 
European  Communities  No  C 92 of 31 October  1973,  page  8. 
A. LEGAL  BASIS  FOR  THE  OPINION 
At its 254th  meeting,  held  on 20 September  1973,  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 24 September  1973. 
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  from  the Council  of the 
European  Communities  on 24 September  1973  for 
an opinion  on the  proposal  for  a Directive  (EEC)  of 
the Council  amending  for the  fifth  time  the  Council 
Directive  of 27 June  1967  concerning  the  approxim-
ation  of the  laws,  regulations  and  administrative 
provisions  relating  to the  classification,  packaging 
and labelling  of dangerous  substances  ; 
Having  regard  to Article  100  of the  Treaty  estab-
lishing  the European  Economic  Community  ; Having  regard  to the  decision  taken  by the  Bureau 
on 26 September  1973,  entrusting  the  Section  for 
Industry,  Commerce,  Crafts  and  Services  in the  first 
instance  with  the  preparation  of  work  on  the 
matter  ; 
Having  regard  to the  general  programme  to elimi-
nate technical  barriers  to  trade,  resulting  from 
disparities  between  the  laws,  regulations  and  admi-
nistrative  provisions  of the  Member  States,  dated 
28 May  1969  ; 
Having  regard  to the  Council  Directive  of 27 June 
1967  concerning  the  approximation  of the  laws, 
No C 109/20 Official  Journal  of the  European  Communities 19. 9. 74 
regulations  and  administrative  provisions  relating 
to the  classification,  packaging  and  labelling  of 
dangerous  substances  ; 
Having  regard  to the  Council  Directive  (*)  of 4 
June  1973  on solvents  ; 
Having  regard  to its Opinion  (2) on the  proposal  for 
the aforementioned  Directive  ; 
Having  regard  to the  Opinion  delivered  by the 
Section  for Industry,  Commerce,  Crafts  and  Services 
at its meeting  on 8 May  1974  ; 
Having  regard  to  the  report  presented  by  the 
Rapporteur,  Mr Kramer  ; 
Having  regard  to the  supplementary  Opinion  of 
the Section  for  Protection  of the  Environment, 
Public  Health  and  Consumer  Affairs,  delivered  on 
12 February  1974  ; 
Having  regard  to  the  discussions  at its  120th 
Plenary  Session  on 29 and  30 May  1974  (Session  of 
29 May  1974), 
HAS  ADOPTED  THE  FOLLOWING  OPINION  : 
The Economic  and  Social  Committee  approves  the 
proposal  but  makes  the  following  general  and 
specific  comments  : 
1. GENERAL  COMMENTS 
1.1. The  Committee  underlines  once  more  the 
importance  of  the  basic  Directive  of  27  June 
1967  and  of the  proposed  amendments  on  the 
free movement  of goods  in the  field  of dangerous 
substances,  which  are  based  on  the  'complete 
harmonization'  solution.  The  harmonization  aims  at 
ensuring  effective  health  protection  to works  and 
consumers  coming  into  contact  with  those  goods  in 
all Member  States. 
1.2. The  proposed  amendment  is  broadly 
supported,  especially  since  its purpose  is to align  the 
older  basic  Directive  on the  provisions  and  wording 
of the more  recent  Directive  on solvents  — an align-
ment  which  has  been  proposed  in the light  of practi-
cal experience  in the  operation  of the  basic  Direc-
tive,  after  thorough  discussion  and  last  but  not  least 
following  the  recommendations  of the  Economic 
and Social  Committee  in its Opinion  on the  solvents 
Directive.  Nevertheless  this  proposal  for  a fifth amendment  does  not  align  the  basic  Directive  as 
consistently  as is now  possible. 
1.3. For  this  reason  in the 'specific  comments'  the 
Committee  recommends  various  additions  and 
further  steps  towards  Complete  harmonization. 
2. SPECIFIC  COMMENTS 
2.1. The  1967  Directive  only  .prescrided  a 
maximum  and  a minimum  label  size.  The  new 
proposal  is that  there  should  be  a range  of 
sizes,  varying  with  package  capacity  in the  same 
manner  as is laid  down  in the  solvents  Directive. 
Insertion  of the  term  'if possible'  in the  stipulations 
as to the  size  of the  smallest  label  ensures  that  a 
label  appropriate  to the  size  of the  package  can  be 
used  for very  small  receptacles. 
2.2. In  this  connection  the  Committee  proposes 
that,  in the  case  of dangerous  substances  and  pre-
parations  packed  in such  small  amounts  that  there  is 
no risk  involved  for those  handling  them  or for third 
parties,  the  special  clause  for  very  small  receptacles 
should  be better  adapted  to the  situation  which 
obtains  in practice.  The  symbol  applicable  to the rele-
vant  danger  and  the  designation  of the  type  of 
danger  should,  however,  still  be prescribed  in all 
cases. 
2.3. The  proposal  for  a Directive  stipulates  that, 
as before,  the  symbol  with  its  background  must 
occupy  one-tenth  of the  surface  of the  label.  In the 
case of small  receptacles,  the  following  should  be 
added  to the  relevant  sentence  to ensure  a clear, 
effective  warning  : '. .. but  must  not be smaller  than 
one square  centimetre'. 
2.4. The  Committee  suggests  that,  in line  with  its 
recommendation  in the  Opinion  (3) of 29 June  1972 
on the  solvents  Directive,  the proposed  amendments 
should  amplify  Article  6 (3) of the 1967  Directive  to 
stipulate  that  all  dangerous  substances  must  be 
accompanied  by advice  on safety  precautions.  The 
purpose  of this  advice  would  be to give  users  clear 
instructions  on the  safety  precautions  to be taken 
when  handling  and  storing  substances  and  if medical 
treatment  has  to be  given  after  an accident.  It 
should  also  contain  fire  instructions. 
2.5. Since  1 July  1973  the  UN  labelling  system, 
which  is used  all over  the world,  has  been  uniformly 
(*) OJ  No L 189,  11. 7. 1973,  p. 3 et seq. 
(2) OJ  No  11,  20.1.1966,  and  OJ No C 26, 28. 2.1969. (3) OJ  No  C 89, 23. 8. 1972,  Chapter  II, Article  5. 
19. 9. 74 Official  Journal  of the  European  Communities No C 109/21 
applicable  to  all  modes  of  transport  in  the 
EEC.  As a result,  in the  case  of outer  packages 
containing  one  or more  separate  inner  packages 
mentioned  in Article  3 (4)  (a) of the  amendment 
Directive,  the  outer  package  is labelled  in accor-
dance  with  rules  on  transport  and  the  inner 
packages  are  labelled  in accordance  with  Annex  II 
to the  1967  Directive.  Such  a dual  system  of 
differing  labels  is very  confusing  especially  for chil-
dren,  old people  and  employees  with  language  diffi-
culties  (migrant  workers  for  instance).  Total 
harmonization  leading  to better  protection  requires 
that the same  labelling  be used  for the same  type  of 
danger  at all stages  from  manufacture  to utilization. 
The Committee  therefore  considers  that,  over  and 
above  the  proposed  amendments  for  the  two 
specific  cases,  every  effort  should  be made  to intro-
duce  consistent  standardization  of labelling  with 
regard  to shape,  colour,  symbols  and  background  in 
the field  of transport  and  in the  field  covered  by 
this Directive. 
2.6. The  Committee  believes,  however,  that  there 
is a particularly  important  precondition  here, 
namely,  that  the  Commission  and  the  Member 
States  should,  in an appropriate  manner,  press  the 
relevant  UN  authorities  to improve  the  impact  of 
certain  important  UN  symbols.  In particular  a 
single  colour  should  be used  for the danger  warning 
(as in the  EEC  system)  instead  of several  colours 
(as in the UN  system). 
2.7. The  aim  of  securing  standardization  of 
labelling  is also  consistent  with  the recommendation explicitly  made  by  the  Economic  and  Social 
Committee  in its Opinion  of 7 December  1965  (*) 
on the basic  Directive. 
2.8. The  Committee  also  proposes  that  a provi-
sion corresponding  to Articles  8 and  9 of the 
solvents  Directive  be adopted  in order  to safeguard 
the free  movement  of goods  and  to regulate  special 
measures  in the event  of emergencies. 
2.9. The  Committee  points  out  that  since 
Member  States  are  not  compelled  to insist  on the 
marketing  of dangerous  substances  in their  territo-
ries being  subject  to the use of the national  language 
or languages  in the labelling  of these  substances,  the 
persons  handling  dangerous  substances  may  be 
unable  to understand  instructions  because  they  are 
written  in a foreign  language. 
The Committee  therefore  proposes  that  Article  3 (3) 
of the fifth  amendment  to the directive  be amended 
to read  as follows  : 
'The  Member  States  shall  make  the  placing  on 
the market  of dangerous  substances  in their 
territory  subject  to the  use  of the  national  or 
usual  language(s)  for the drafting  of the label.' 
Done  at Brussels,  29 May  1974. 
The Chairman 
of the 
Economic  and  Social  Committee 
Alfons  LAPPAS 
(*) OJ  No  147,  20.1.1966,  Chapter  I, Section  4. 
ANNEX 
to the Opinion  of the Economic  and Social  Committee 
The following  amendment,  submitted  in accordance  with  the  Economic  and  Social  Committee's 
Rules  of Procedure,  was  rejected  by the  Plenary  Session  : 
Insert  between  points  2.3.  and  2.4.  the following  text: 
'Article  2 of the  fifth  amendment  proposes  altering  Article  6 (2) of thd  1967  Directive  so 
that the first  sentence  would  read  : 
"Every  package  must  show  clearly  aind  indelibly  the  following  ..." 
The Committee  believes  that  this  general  wording  could  be interpreted  in so widely 
different  a way  throughout  the  nine  member  countries  that  it might  lead  to the  very 
disparity  in national  legislation  which  the Directives  are  seeking  to remove. 
The Committee  proposes  therefore  that  a minimum  size  for  the  precautionary  wording 
should  be laid  down. 
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-