30. 11. 87 Official Journal of the European Communities No C 319/25 
Opinion on the proposal for a Council Directive on the approximation of the laws of the 
Member States relating to certain components and characteristics of wheeled agricultural or 
forestry tractors 
' (87/C 319/08) 
On 1 June 1987 the Council decided to ask the Economic and Social Committee to deliver 
an Opinion, in accordance with Article 100 of the EEC Treaty, on the abovementioned 
proposal. 
The Section for Industry, Commerce, Crafts and Services, which was responsible for preparing 
the Committee's work on the matter, adopted its Opinion on 2 September 1987. The 
rapporteur was Mr Pearson. 
At its 248th plenary session on 23 and 24 September 1987 (meeting of 23 September) the 
Committee adopted the following Opinion unanimously: 
1. General comments 2. Specific comments 
1.1. The Committee welcomes the Commission's 
proposals and is particulary pleased that this Directive 
will complete the total orbit concerning the safety on 
the roads and the safety at work of agricultural and 
forestry tractors. The Committee is aware that there 
already exist 22 Directives and six amendments which 
will also apply in this area of providing manufacturers 
scope to obtain full EEC typeapproval for this type of 
tractor: it is aware that tractors for industrial use are 
covered in another series of regulations. 
1.2. The Committee draws attention to the omission 
of any proposal for caterpillar tractors. It realizes that 
although in a number of Member States such vehicles 
are not permitted on the highway and are a very small 
percentage of tractors produced, they do operate in 
forestry and agricultural areas and suggests that the 
Commission should look at this aspect. 
1.3. The Committee notes that a new procedure has 
been used to draw up the draft Directive. It recognizes 
the need for speed an efficiency in the decision making 
process but, nevertheless, finds it necessary to ensure 
that the relevant organizations (industry, employers, 
farmers, small businessmen, consumers and workers' 
representatives) are consulted on all matters affecting 
safety and health. The Committee also takes note of 
the fact that the new procedures deriving from the 
Single Act do not affect the consultation of the Econ­
omic and Social Committee pursuant to Article 100 A 
(paragraph 1) of the Treaty in its amended form. 
1.4. The Committee, nevertheless, endorses the pro­
posals subject to the following technical reservations. 2.1. Article 4, 'The Committee' 
The Committee believes that 'the Committee' as defined 
in Article 12 of the basic Directive 74/150/CEE and to 
be continued in the current Directive, cannot fulfil its 
function as proposed. It should have representation 
from the social partners and from the Community 
manufacturing federations. The greatest use of expert 
advice should be availed of and account properly taken 
of the Committee's deliberations. 
2.2. Article 5.1 
Whilst the Committee is aware of the need for these 
provisions to come into force as soon as possible, the 
deadline for compliance, 31 December 1988, is seen as 
too soon. It suggests that eighteen months from the 
date of implementation of the Directive should apply. 
2.3. Annex I 
2.3.1. 2.1.2. 
The Committee agrees with a maximum width of 
2.5 metres: it suggests however that individual Member 
States might permit extra width, up to 3.0 metres, when 
special tyres or double tyres are required for special 
conditions, such as to relieve pressure on ground. 
2.3.2. 2.2.1.1. 
The Committee suggests that clauses 1.4 and all of 
section 2.2 should be withdrawn. These clauses concern 
the requirements of trailers and the Committee thinks 
that a Directive specifically dealing with trailer regu­
lations is necessary. 
No C 319/26 Official Journal of the European Communities 30. 11. 87 
2.3.3. 2.2.1.2. and 2.2.1.3. 
Should this suggestion at 2.3.2 be accepted then the 
Braking Directive (76/432/CEE), still needs to be altered 
to ensure that a tractor is always able to take over 
the mass weight of the trailer on a slope. When the 
manufacturer states that the tractor is able to tow a 
trailer over 6 tons weight, some means of power must 
be available from the tractor to brake the trailer. 
2.3.4. 2.3.2.1. (ii) 
The Committee believes that International Standards 
Organization (ISO) standards would be more univ­
ersally acceptable than the European Technical Organ­
ization for Tyres and Rims (ETRTO) tables. 
2.4. Annex 11 - 3 (3.1, 3.2, 3.3) 
The Committee again draws attention to the fact that 
the proposed Directive relates to tractors. Paragraph 3 
refers to trailers and as such is inadequate in relation 
to basic trailer requirements (i.e. harmonized warning 
systems, hydraulic or other braking systems). The Com­
mittee reiterates its suggestion at 2.3.2 above, that the 
regulations for trailers be the subject of a separate 
document. Consequently this paragraph should be 
deleted from the draft Directive. 
2.5. Annex 111 A 
This section of the Annex 1.14. does not make it clear 
that a manufacturer may use any of the types of 
approved safety glass for the windscreen, provided the 
EEC typeapproval mark is affixed. 
2.6. The Committee realizes that the security of the 
driver, commensurate with the operation for which the 
tractor is being used, is a major consideration in the 
series of Directives concerning the Regulations harmon­
izing tractor manufacturing requirements. A resume of 
all the items involving the safety measures included in 
the various Directives should be prepared and attached 
to each Directive. 
2.7. Annex IV 
2.7.1. If the suggestion, made at 2.3.2 and 2.4 above, 
that all reference to trailers be withdrawn is accepted, 
then all reference to trailers in this Annex must equally 
be deleted. 
Done at Brussels, 23 September 1987. 2.7.2. 3.2.1.2. 
As current practice in some Member States is to use a 
40 coupling whilst ISO 6489/2 requires a 50 coupling, 
the Committee suggests that 'including a 40 coupling' 
be added to the end of this clause. 
2.7.3. 3.2.1.3. 
As at 3.2.1.2 above, some Member States satisfactorily 
normally use 40 rings whilst ISO 5692 only requires 
50 rings. The Committee suggests that the wording be 
changed to read: '... between vehicles — towing rings 
both type 50 and 40 — ...'. 
2.7.4. 3.2.2. 
The Committee is concerned that the maximum towing 
height parameters may not be safe and suggests that ISO 
500 standard be used instead. It is the manufacturers 
responsibility under product liability to cater for the 
safety elements and thus, if the ISO 500 standard is not 
acceptable, then this clause should be deleted. 
2.7.5. Appendix 1.1 (Testing method) 
The last line of the paragraph must be changed to read 
'attachment to the tractor'. 
2.7.6. Appendix 1.3 (Test procedure), 
5th paragraph 
This paragraph stipulates a fatigue strength of 2 million 
load cycles whilst experience shows that this figure is 
too high: it would be sufficient to stipulate a fatigue 
strength of 0,5 million. New wording would therefore 
read: 'The frequency of the sinusoidal stresses shall not 
exceed 35 Hz for a number of cycles equal to 0,5 x 
106.' 
2.8. Annex V 
2.8.1. 2.1.8. 
This should be amended as follows: 'Maximum permit­
ted total weight when standard tyres are fitted.' 
2.8.2. 2.1.9. 
As at 2.7.1 above, clause 2.1.9 of Annex V would need 
to be deleted. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT