No C 346/2 Official Journal of the European Communities 31. 12. 82 
2. However, the Committee points out that the 
proposed Regulation refers only to strong moral 
objections. The Committee would draw attention to the 
fact that the hunting of adult seals may create problems 
for the survival of the species and the preservation of a 
healthy ecological balance. Further research is needed 
into these aspects. 
3. While regretting that contact at Community level 
with the countries involved has not succeeded in bringing 
about an agreement to prohibit the killing of baby seals, 
the Committee recognizes that the only option open to the 
Commission was to propose a ban on imports for 
Done at Brussels, 24 November 1982. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Article 100 
thereof, 
Having regard to the request made by the Council of the 
European Communities on 27 April 1982 for an opinion 
on the proposal for a Council Directive amending Council 
Directive 70/220/EEC relating to measures to be taken 
against air pollution by gases from positive-ignition 
engines of motor vehicles, 
Having regard to the decision taken by the Committee 
Bureau on 27 April 1982 instructing the Section for the 
Protection of the Environment, Public Health and 
Consumer Affairs to draw up an opinion on the commercial purposes; the resulting restriction of the 
market should make hunting less profitable. 
4. The Committee notes furthermore that the 
proposed Regulation, based as it is on the common 
commercial policy, cannot have a decisive effect. It 
therefore asks the Commission to continue negotiations 
with Norway and Canada to seek a satisfactory solution 
to the problem. If the import ban to be imposed by this 
proposed Regulation is ineffective in restricting the killing 
of baby seals, the Commission should encourage similar 
action at international level to induce either a moratorium 
or a total ban. 
The Chairman 
of the Economic and Social Committee 
Francis CEYRAC 
Having regard to the Committee opinion on the draft 
action programme of the European Communities on the 
environment (1982 to 1986), adopted on 27 May 
1982, 
Having regard to the discussions at the 71 st meeting of the 
Section for Protection of the Environment, Public Health 
and Consumer Affairs, held on 11 November 1982, 
Having regard to the report made by the rapporteur, 
Mr von der Decken, 
Having regard to the discussions at its meeting on 
24 November 1982 (202nd plenary session of 24 and 
25 November 1982), Opinion on the proposal for a Council Directive amending Council Directive 70/220/EEC on 
the approximation of the laws of the Member States relating to measures to be taken against air 
pollution by gases from positive-ignition engines of motor vehicles 
The text referred to the Committee has not yet been published in the Official Journal of the 
European Communities. 
A. LEGAL BASIS FOR THE OPINION 
On 27 April 1982 the Council referred the abovementioned proposal to the Economic and 
Social Committee in accordance with Article 100 of the Treaty establishing the European 
Economic Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 202nd 
plenary session held in Brussels on 24 and 25 November 1982. 
matter, (i) OJ No C 205, 9. 8. 1982, p. 28. 
31. 12. 82 Official Journal of the European Communities No C 346/3 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously: 
I. General comments 
1. The Committee endorses the Commission's 
commitment to reduce air pollution caused by motor 
vehicles' engine gases. These emissions are a major cause 
of air pollution in urban areas, and can contribute to the 
formation of photochemical smog. 
Bearing in mind that such areas are densely populated, 
and that the level of motor traffic is still generally on the 
increase, so that pollution is spreading to new areas, the 
Committee agrees with the Commission that effective 
measures are urgently needed in this area, to safeguard 
public health and the environment. 
These measures are made easier both by technological 
progress in the Community motor industry, and by the 
very strict rules already in force in some non-member 
competitor countries. 
2. The Committee emphasizes that the abatement of 
air pollution caused by motor vehicles' engines not only 
requires specific measures on engine gases, but other 
measures too. 
In particular, it notes that this type of air pollution could 
be reduced by adequate town-planning provisions, and 
by provisions to regulate vehicular traffic, particularly an 
improvement in periodic checks on vehicles, which 
should be made compulsory. The Committee also asks 
the Commission to study the possible effects of tax 
incentives on the production and use of less polluting 
engine/fuel combinations. 
3. The Committee notes the Commission's belief that, 
in addition to the moves to introduce overall rules in this 
area, a specific measure is urgently needed (a) to achieve, 
in relation to the limits laid down in Directive 
78/665/EEC, a 23% reduction in carbon monoxide 
(CO) emissions and a 20 % to 30 % reduction according 
to weight category, in the combined unburnt 
hydrocarbon (HC) and nitrogen oxide (NO x) emissions, 
from vehicles with petrol engines and (b) to extend the 
same limit values to diesel-engined cars and light 
commercial vehicles (categories Mj and Nj). 
In any case, the Committee feels that the overall approach 
adopted by the Commission in 1981 must be urgently applied. In the context of this approach, the problem of 
lead-free petrol can be tackled, as has already been done 
in certain non-Member States, in order to permit the 
introduction of techniques capable of reducing emissions 
of noxious gases which have been applied to certain 
non-Member States. 
4. The Committee supports its recent opinion on the 
third action programme on the environment which states 
in point 4.9 that 'substantial work has still to be done in 
the field of motor vehicle pollution technology, and the 
Committee is of the opinion that vehicle manufacturers in 
the Community should intensify their efforts to produce 
less polluting engines, and to stay abreast of technological 
developments in this field' (J). 
In this context, the Committee trusts that research will be 
intensified in all Member States for the use of alternatives 
to conventional fuels, with the aim not only of reducing 
the Community's dependence on imported fuels, but also 
of reducing air pollution. This research should be more 
closely coordinated at Community level, and could be 
incorporated in the Cost 304 programme (Cost: 
European Cooperation in the field of Scientific and 
Technical Research). 
5. The Community vehicle maufacturing industry 
acknowledges that the proposed measures will mean an 
increase of production costs for petrol engines by an 
average of less than 3 % and an increase in fuel 
consumption of not more than 5 %. 
II. Specific comments 
1. The Committee is pleased that the sampling and 
analysis methods already employed in the USA, Japan 
and Sweden have been adopted in the Community. 
2. The Committee supports the proposal to extend 
Council Directive 70/220/EEC to cover diesel-engined 
light vehicles, but requests the Commission to formulate a 
Directive for gas emissions from diesel vehicles of over 
3 500 kg weight, and heavy duty diesel-powered 
construction equipment. 
3. Experts in the Member States believe that the 
deadlines proposed by the Commission for the 
enforcement of this Directive can be observed without 
creating insurmountable difficulties for national 
authorities or vehicle manufacturers. The Committee 
(') OJ No C 205, 9. 8. 1982, p. 28. 
No C 346/4 Official Journal of the European Communities 31. 12. 82 
approves these dates, although it would prefer an earlier 
deadline. 
4. The Committee takes note that the technical 
provisions of the Annexes conform to the standards of the 
Done at Brussels, 24 November 1982. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Articles 235 and 
198 thereof, 
Having regard to the request made by the Council of the 
European Communities on 6 July 1982 for an opinion on 
the proposal for a five-year research and development 
programme in the field of applied metrology and 
reference materials (non-nuclear indirect action) (1983 to 
1987) (>), 
Having regard to the decision taken by its chairman on 
19 August 1982 instructing the Section for Energy and 
Nuclear Questions to draw up an opinion on the 
matter, 
Having regard to the Community programme for this 
area for 1979 to 1982 (2), and the relevant ESC 
opinion (3), 
Having regard to the 1981 assessment report concerning 
the applied metrology and reference materials 
programme (4), 
(») OJ No C 187, 22. 7. 1982, p. 8. 
(2) OJNoL 258, 13. 10. 1979. 
(3) OJNo C 128, 21. 5. 1979. 
(4) EUR 7811. UN Economic Commission for Europe (the 04 series of 
amendments to regulation 15). The Committee feels that 
they can be approved as the best possible solution, given 
the present state of technical knowledge. 
The Chairman 
of the Economic and Social Committee 
Francis CEYRAC 
Having regard to the opinion adopted by the 
above-named Section at its 75th meeting held on 
5 November 1982, 
Having regard to the oral report made by the rapporteur, 
Mr von der Decken, 
Having regard to the discussions on 24 November 1982 
during the 202nd plenary session held on 24 and 
25 November 1982, 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously: 
1. The Economic and Social Committee has on several 
occasions endorsed R&D programmes in this area. It 
would like once again to stress the importance of 
reference materials and methods as well as applied 
metrology in many areas of economic and social activity. 
Progressive harmonization is of vital importance for 
industry, commerce, public health, environmental 
protection, agriculture, and so on. Divergence in 
measuring methods and results can create considerable 
obstacles to trade, for example, and can jeopardize the 
correct implementation of Community guidelines. Opinion on the proposal for a five-year research and development programme in the field of 
applied metrology and reference materials (non-nuclear indirect action) (1983 to 1987) 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 187 of 22 July 1982, page 8. 
A. LEGAL BASIS FOR THE OPINION 
On 6 July 1982 the Council referred the abovementioned proposal to the Economic and Social 
Committee in accordance with Articles 235 and 198 of the Treaty establishing the European 
Economic Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
202nd plenary session held in Brussels on 24 and 25 November 1982.