No C 211/4 Official Journal of the European Communities 8. 8. 83 
Opinion on the proposal for a Council Regulation introducing a specimen declaration 
from to be used in intra-Community trade 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 71 of 16 March 1983, page 1. 
A. LEGAL BASIS FOR THE OPINION 
On 14. January 1983 the Council referred the abovementioned proposal to the Econo­
mic and Social Committee in accordance with Article 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 
208th plenary session held in Brussels on 1 and 2 June 1983. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the Euro­
pean Economic Community, and in particular 
Article 198 thereof, 
Having regard to the request made by the Council 
of the European Communities on 14 January 1983 
for an opinion on the proposal for a Council Regu­
lation introducing a specimen declaration form to 
be used in intra-Community trade, 
Having regard to the decision taken by its Bureau 
on 25 January 1983 instructing the Section for 
Industry, Commerce, Crafts and Services to draw up 
an opinion on the matter, 
Having regard to the opinion adopted by that Sec­
tion at its meeting on 4 May 1983, 
Having regard to the oral report of the rapporteur, 
Mr Broicher, 
Having regard to the discussions at its 208th plenary 
session held on 1 and 2 June 1983, (meeting of 1 
June 1983), 1. Introduction 
As part of its campaign to strengthen the Com­
munity's internal market, the Commission has inter 
alia proposed a Regulation simplifying the customs 
formalities involved in trade within the Com­
munity ('). At its session on 24 February 1983 the 
Committee adopted an opinion in which it made a 
critical assessment of that draft Regulation but 
endorsed its aims (2). 
The draft Regulation under review has been drawn 
up pursuant to the abovementioned Regulation on 
the simplification of customs formalities. It is 
designed to introduce a single declaration form/for 
Community goods traded between Member States. 
1.2. Given the interlinkage between the basic 
Regulation and the layout of the standard form, 
including the data required, the draft Regulation 
should be considered in its overall context. It will 
therefore be necessary to revert to some of the prob­
lems dealt with in the Committee's opinion on the 
basic Regulation. 
2. General comments 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously: The Committee endorses its support for a standard 
form. A standard form, used in all the Member 
(') OJ No C 71, 16. 3. 1983, p. 1. 
(-') OJNoC90, 5.4. 1983, p. 16. 
8.8.83 Official Journal of the European Communities No C 211/5 
States, will further integration. It will make trade 
between Member States more transparent, and will 
further harmonization and standardization of the 
data required in intra-Community trade. 
It will thus improve the prospects of developing 
compatible data-processing systems in the Member 
States and will help to obviate 'information fron­
tiers' which, once established, will be impossible to 
eliminate. 
3. Specific comments on the standard form 
3.1. The Committee considers it essential that the 
form should not be additional to but replace several 
of the existing ones. Furthermore, it must be easy to 
use. This is all the more necessary because the 
switch to a standard form is a costly business. 
3.1.1. The introduction of a standard form for 
intra-Community trade will lead to a splitting of the 
standard forms for intra-Community and Com­
munity trade with non-member countries. The forms 
used to date for intra-Community trade cannot, 
however, be dispensed with in all cases. As the stan­
dard form will only apply to Community goods, the 
old declaration forms will have to be retained for 
trade with non-Community countries. As the stan­
dard form is also to be confined to trade between 
Member States, the present T-forms will have to be 
used for transit traffic. 
3.1.2. For these reasons, the Committee considers 
that the intra-Community standard form should also 
be used for non-Community goods and goods in 
transit through Member States. The forms for extra-
Community trade should subsequently be aligned 
on those for intra-Community trade. This process 
would be helped if there were a further reduction of 
Done at Brussels, 1 June 1983. information required to be declared on the form for 
intra-Community trade. 
3.2. If the standard form is really to improve and 
not complicate declaration procedures, the strict 
rule that the standard form is to be passed on all 
along the line from the consignor to the consignee 
should not apply where the consignor has in the 
past been required to make only a simplified written 
declaration, or none at all. In such cases it should 
therefore be provided that the formalities, e.g. at the 
consignee stage, will be discharged by completing a 
new standard form. The Commission has recognized 
the need for this in principle, but the Committee 
considers that it has failed to make it clear that in 
such cases the form does not have a 'transmission 
function'. Steps should also be taken to ensure that 
use of the single declaration form for groupage 
traffic does not make such operations more complex 
than at present. 
3.3. The standard form must meet specific tech­
nical requirements. Practical investigations have 
shown that if a high-speed printer is used, the bot­
tom carbon copies of a septuplicate form are illegi­
ble. They are only legible, at the best, if filled in 
with a low-speed printer, a typewriter or by hand. 
Similarly the design of the document must facilitate 
its production in exporters' document preparation 
systems based on UN recommendations. 
3.4. Another practical problem will occur when 
statistical declarations are transmitted on tape to 
national statistics offices. In such cases, because of 
the layout, use of the standard form will mean dif­
ferent records for intra-Community and extra-Com­
munity trade; this will lead to substantial additional 
costs. The Committee considers that this problem 
could be resolved if the draft Regulation were to 
specify that users do not have to provide more data 
than is indicated on the standard form, but that the 
national authorities may rule that not all these data 
have to be given. 
The Chairman 
of the Economic and Social Committee 
Francois CEYRAC