No C 37/28 Official  Journal  of the  European  Communities 1.4. 74 
social  equilibrium  and  thus  ensure  decisive  progress 
towards  economic  and  monetary  union.  However, 
while  aids  can  be a means  of developing  regions 
they cannot  by  themselves  eliminate  under-
development.  Thus  it is the Community's  duty  and 
responsibility  to carry  out  by itself  and  for  itself 
large-scale  equipment  and  infrastructure  schemes,  as 
well as  pilot-projects  within  the  context  of 
Community  regional  development  whose  crucial 
importance  has  been  underlined  by the  Economic 
and Social  Committee  on many  occasions. 
The Chairman 
of the Economic  and  Social  Committee 
Alfons  LAPPAS 
CONSULTATION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
on a proposal  for  a Council  Directive  on a ninth  amendment  to the  Directive  on the 
approximation  of the laws  of the Member  States  concerning  the preservatives  authorized 
for use  in foodstuffs  intended  for human  consumption 
A. REQUEST  FOR  AN  OPINION 
At its 247th  meeting  held  on 18 June  1973,  the Council  decided  in accordance  with  the 
provisions  of Article  100  of the Treaty  establishing  the European  Economic  Community 
to consult  Economic  and  Social  Committee  on the  above  proposal  for  a Directive. 
The request  for an Opinion  was  sent  by the President  of the Council  to the Chairman 
of the Economic  and  Social  Committee  on 21 June  1973. 
B. TEXT  WHICH  WAS  THE  SUBJECT  OF  THE  CONSULTATION 
The text  which  was  the subject  of the consultation  has not been  published  in the Official 
journal  of the European  Communities. 
C. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
At its 115th  Plenary  Session  held  in Strasbourg  on 29 November  1973,  the Committee 
adopted  unanimously  by the members  present  or represented,  its Opinion  on the  text 
referred  to under  B. 
The text  of the Opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE,  Opinion  on the  proposal  for  a Council  Directive  on 
a ninth  amendment  to  the  Directive  on  the 
approximation  of the  laws  of the  Member  States 
Having  regard  to the  request  by the  Council  of the  concerning  the  preservatives  authorized  for  use  in 
European  Communities  on  21  June  1973  for  an foodstuffs  intended  for human  consumption; The Committee  points  out  that  this  policy  of aid 
through  the  EAGGF  and  the  Regional  Development 
Fund  is essentially  complementary  in character.  It 
should  induce  Member  States  to  strengthen 
simultaneously  their  own  regional  development 
policies  coordinated  at Community  level. 
But aids,  however  important  they  may  be,  are  not 
sufficient  on their  own. 
The Community's  regional  development  policy  must 
be a fundamental  element  in restoring  economic  and 
Done  at Strasbourg,  29 November  1973. 
1.4. 74 Official  Journal  of the  European  Communities No C 37/29 
Having  regard  to the  basic  Council  Directive  No 
64/54/EEC  of 5 November  1963; 
Having  regard  to  Article  100  of  the  Treaty 
establishing  the European  Economic  Community; 
Having  regard  to the  Decision  by  its  Bureau  on 
25 June  1973  instructing  the Section  for the Protection 
of the  Environment,  Public  Health  and  Consumer 
Affairs  to prepare  a report  and  an Opinion  on  the 
subject; 
Having  regard  to  the  Opinion  delivered  by  the 
Section  for  Protection  of the  Environment,  Public 
Health  and  Consumer  Affairs  at its  meeting  of 
9 October  1973; 
Having  regard  to  the  report  presented  by  the 
Rapporteur,  Miss  Roberts; 
Having  regard  to its discussions  at its 115th  Plenary 
Session  on 29 November  1973, 
HAS  ADOPTED  THE  FOLLOWING  OPINION: 
The Committee  approves  the  proposed  Directive 
subject  to the  following  comments: 
The need  for  a Directive 
In putting  forward  this  ninth  amendment  to the 
preservatives  Directive  No  64/54/EEC  of 5 November 
1973  the  Commission  are  acceding  to the  requests  of 
certain  Member  States  who  find  it necessary  to use 
formic  acid,  hexamethylenetetramine  and  boric  acid  in 
certain  foodstuffs  (listed  in Section  I of the  Annex). 
Other  Member  States  do  not  consider  there  is a 
need  for  such  additives.  The  Committee  regrets  that 
in the  interests  of harmonization  Member  States 
•should  have  to accept  the  use  of additives  which 
they  consider  unnecessary,  either  because  they  do 
not make  the  product,  or because  they  use  another 
preservative,  or because  they  consider  them  toxic, 
but supports  the  Commission's  proposals  on  the 
grounds  that  free  trade  will  be facilitated  and,  as far 
as our  present  knowledge  permits,  we  are  virtually 
certain  that  the  health  of the  consumer  will  not 
suffer.  It would  have  been  useful  for  the  Committee 
to have  been  informed  of the  extent  of the  trade  in 
foodstuffs  treated  with  additives  included  in  the 
proposed  Directive. 
On examining  the  problem  of  controlling  the 
application  of the  provisions  of the  Directive,  the 
Committee  insists  that  the  Commission  should 
consider  carefully  the  enforcement  of  these provisions  via  national  legislation  and  take  all 
measures  that  prove  necessary. 
COMMENTS  ON  PARTICULAR  ADDITIVES 
1. Formic  acid  and  its salts 
The Commission  in their  explanatory  memorandum 
suggest  that  the  quantities  provided  for  in  the 
proposed  Directive  represent  only  a very  low 
proportion  of the  Acceptable  Daily  Intake  (ADI)  of 
formic  acid  (5 mg/kg  by weight  — Joint  FAO/WHO 
Committee  of  Experts  on  Food  Additives).  The 
Committee  agrees  that  the  permitted  levels  would 
not in general  lead  to the  ADI  being  exceeded,  but 
would  point  out  that  there  is a theoretical  possibility 
that a person  weighing  60 kg and  consuming  daily 
350 g of processed  fish  and  vegetables  in vinegar 
would  exceed  the  ADI.  The  comment  of  the 
Commission  is therefore  unnecessarily  optimistic. 
The Committee  welcomes  the  fact  that  the  permitted 
use of formic  acid  in fruit  juices  should  lead  to 
reduction  in the  use  of sulphur  dioxide. 
2. Hexamethylenetetramine 
The Committee  notes  that,  according  to  the 
Commission,  recent  studies  indicate  a significantly 
lower  ADI  for  this  additive  than  that  recommended 
by the  Joint  FAO/WHO  Committee  (0T5  mg/kg  by 
weight  as opposed  to 5 mg/kg  by weight),  and  that 
the Commission  has  based  its  calculations  on  the 
lower  figure.  In the  absence  of conclusive  evidence 
and in view  of the  restricted  use  of this  additive  the 
Committee  accepts  its proposed  use.  The  Committee 
welcomes  the  fact  that  the  Commission  will 
encourage  further  studies  to be  made  as soon  as 
possible  that  would  confirm  or reject  this  recent 
evidence. 
3. Boric  acid  and  its salts 
The Committee  accepts  the  proposed  limited  use  of 
boric  acid  and  welcomes  the  fact  that  the 
Commission  has  discussed  with  the  producers  of 
caviar  the  need  for  safe  substitutes  for  this  additive. 
Derogation  for  national  use  until  1976 
The Committee  welcomes  the  setting  up  of  a 
deadline  in the  amended  version  of Article  5 for  the 
No C 37/30 Official  Journal  of the  European  Communities 1.4.74 
use of formic  acid  and  its  salts  in fruit  juices 
intended  for the production  of syrups,  hexamethylene-
tetramine  in semi-preserved  fishery  products  and 
boric  acid  in  egg  products  according  to  the 
provisions  of national  laws.  However,  in view  of the 
repeated  extensions  of the  time  limit  proposed  by 
the Directive  of 1963  no further  extension  beyond 
the deadline  of 30 June  1976  should  be contemplated. 
The Directive  No  64/54/EEC  of 5 November  1963 
provided  for  the  continuance  of  national  laws 
relating  to the  additives  in question  for  a period  of 
three  years  following  notification  of the  Directive. 
The further  derogation  proposed  in  the  current 
Directive  means  that  national  laws  will  have  been 
allowed  to continue  for  a total  of thirteen  years.  In 
these  circumstances  the  Committee  is unlikely  to 
Done  at Strasbourg,  29 November  1973. find itself  in a position  to  approve  any  further 
derogation  at a future  date. 
Report  on  the Scientific  Committee  on  Foodstuffs 
The Committee  found  itself  hampered  in its work 
because  of the  reports  of the  Scientific  Committee 
on Foodstuffs  were  unavailable,  whereas  the  reports 
of the  Joint  FAO  WHO  Committee  of Experts  on 
Food  Additives  and^many  national  committees  are 
freely  available  for  study.  The  Commission  in its 
explanatory  memorandum  refers  to opinions  of the 
Scientific  Committee  but  without  disclosing  either 
the arguments  of the  Committee  or the  evidence  on 
which  it based  its opinions.  The  Committee  strongly 
recommends  that  the  reports  of this  Committee 
should  be published. 
The Chairman 
of the Economic  and  Social  Committee 
Alfons  LAPPAS 
CONSULTATION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
on a draft  Council  Resolution  on a Social  Action  Programme 
A. REQUEST  FOR  AN  OPINION 
On 30  October  1973,  the  Counail  decided  to exercise  its option  of consulting  the 
Economic  and  Social  Committee  on the  above  proposal  for  a draft  Resolution. 
The request  for  an Opinion  was  sent  by the  President  of the  Council  to the  Chairman 
of the  Economic  and  Social  Committee  on 30 October  1973. 
B. TEXT  WHICH  WAS  THE  SUBJECT  OF  THE  CONSULTATION 
The text  which  was  the  subject  of the  consultation  was  not  published  in the  Official 
Journal  of  the  European  Communities. 
C. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
At its 115th  Plenary  Session  held  in Strasbourg  on 29 November  1973,  the  Committee 
adopted  unanimously  with  9 abstentions  its Opinion  on the  text  referred  to under  B. 
The text  of the  Opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  request  of the  President  of the 
Council  of the  European  Communities  of 30 October 1973  for  an Opinion  on  the  Draft  Social  Action 
Programme; 
Having  regard  to  Article  198  of  the  Treaty 
establishing  the European  Economic  Community;