1L^.88 Official]ournal of the European Communities ^oC9^9 
Opinion on the proposal foraCouncil Directive on the approximation ofthelaws,regulations 
and administrative provisions of the member States relating to construction products 
^88BC^B^ 
On^8]anuary 198^theCouncildecidedto consult the Economic and SocialCommittee 
under Article It^ofthelreaty establishing theEuropeanEconomicCommunityonthe 
abovementioned proposal 
The Section for Industry,Commerce, Crafts and Services, which was responsible forpreparing 
the Committee'swork on the subject, adopted its Opinion on3Eebruary!988,in the light 
of the oral report by ^irdel^ormann. 
At its ^3rd plenary session ^meeting of^eoEebruary 1988^ the Economicand Social Committee 
adopted unanimously with three abstentions the following Opinion. 
L Ceneral considerations 
LL The Committee endorses the proposal for a 
Council Directiveon theappro^imationof thelaws, 
regulations and administrative provisions of the ^Blem^ 
ber States relating to construction products, subject to 
the following comments. 
IB^, It considers that the proposed Directive has two 
main objectives. 
The first is stated clearly.lt is to ensure free movement, 
marketing and use in the internal market of construe 
tion products for which the fitness for purpose has been 
demonstrated. The effect shouldbe that trade in and 
useof suchproducts shall notberestramedby laws, 
regulations andadmmistrativeprovisionsof Aiember 
States, 
1.3, The second objective is implied only. It is to 
discharge the responsibility of the Council under Article 
It^OAof the Single European Act to adopt measures 
for the approximation of the provisions laid down 
by laws, regulations or administrative provisions in 
member States,Articlelt^A^^ expressly states that 
these provisions apply to health, safety, environmental 
protection and consumer protection. 
1,^, The Committee considers that this Directive 
does not express simply and with complete clarity the 
second of these twin objectives and its implications, 
hence it is opentovanous interpretations which may 
at least result in considerable debate and at most in the 
necessity for resort to the European Court of justice 
L^he Committee calls for the appropnateArticles and 
explanations of the Directive to be redraftedtomake 
clear that it is mandatory m its regulatory effect on 
construction work^ and henceon the marketing and 
use of construction products. IBo, ^^^^or^o^^r^o^o^r^^o^o^D^r^r^^ 
Phe Committee has based its analysis of this Directive 
on the following considerations, ^^u^^ 
1,^,1, The construction sector involving works and 
the products from which they are built is largeand 
complex. It includes manufacturing and craft industries, 
a number of professions anda wide spectrum of conD 
sumers. This complexity demands that it be approached 
fromabasis of knowledge and experience, 
1,^, The sector is said to haveaturnover of over 
3^ billion ECU per annum of which materials account 
for one third. The sector stands with agriculture in 
numbers employed, 
1,0,3, The removal of regulatory restraints to trade 
in constructionproductsisakeystepmthe progress 
towards the inclusion of the construction sector in the 
internal marked by 199^, 
1,^,^, The Committee believes that an initial 
approachfocusmgaDirectiveonclearlydefmedand 
achievable objectives will be the best way forward 
towards achieving the internal market byl99^,Along 
drawnout attempt to agreeacomple^ Directive meet 
mg every eventuality could be self-defeating. 
l,eo,^. Indeed it may not be possible toforesee and 
hence to provide for all the difficulties which will arise 
in implementmgthis Directive, The Committeecon 
sidersit important thereforeto makeprovisionfor a 
mechanism whereby the results of application in prac 
tice are fed back to inform and direct a process of 
subsequent modification, 
IBo,^, fhe Directive must lead to simple, understand 
able and practicable arrangements and not to an 
increase m bureaucratic effort. Its implementation 
should not be moredifficult to monitor andenforce 
than existing regulations. 
No C 95/30 Official Journal of the European Communities 11.4.88 
1.6. Interpretation of the proposed Directive 
The Committee understands the proposed Directive to 
state: 
1.6.1. The building laws, regulations and adminis­
trative provisions of Member States will be so drawn as 
to encompass the essential requirements in the Directive 
(Annex I). 
1.6.2. Member States may apply additional regu­
lations but they may not be used to restrict trade in 
products which comply with the requirements of the 
Directive. 
1.6.3. No construction product may be marketed or 
used in the Community unless it is compatible with the 
essential requirements for the structure in which it is 
intended to be used. 
1.6.4. No construction product which conforms to 
the requirement of the Directive may be prohibited 
from marketing and use throughout the internal market 
by the application of Member State laws, regulations 
and administrative provisions. This assumes that the 
product has been specified fur a purpose for which it 
is fit and that it is to be correctly installed. 
1.6.5. No structure may be erected within the Com­
munity unless it conforms to the essential requirements 
given in the Directive. 
Compliance with the essential requirements by the 
structure follows from the exclusive use of products 
which are fit for their purpose and correctly installed. 
1.6.6. Whilst the free movement of products that 
meet the requirements of the Directive may not be 
hindered by any laws, regulations and administrative 
provision of Member States, the Directive imposes no 
constraint on the freedom of consumers to choose avail­
able products for specification and installation in con­
struction works. 
1.6.7. It should be clearly stated that products 
intended for these construction works are affected. If 
they are not, there would be two standards — one 
concerning products for new works and one concerning 
products for existing buildings. This would not be 
conducive to productivity in the sector. 
1.7. The new approach 
This Directive is based on the Council resolution of 7 
May 1985 'concerning a new approach to technical 
harmonization and standardization' and is one of a 
number of such 'new approach Directives'. 1.8. The first principle of the new approach involves 
Community agreement to those essential requirements 
(Art. 100 A of the Single European Act) (or other 
requirements in the general interest) with which prod­
ucts put on the market must conform, and which should 
therefore enjoy free movement throughout the Com­
munity. 
1.9. Since construction products have a single pur­
pose only, to be used in construction works, the new 
approach, as applied in this Directive, relates them to 
such works. 
1.10. The effect of the Directive will thus be to ensure 
that the building laws, regulations and provisions of all 
Member States encompass and take account of the 
essential requirements. 
1.11. Furthermore, the Directive will ensure that no 
product may be marketed or used in the Community 
unless it is compatible with the essential requirements 
for the structure in which it is used. 
1.12. The second fundamental principle of the new 
approach is that the task of drawing up the technical 
specifications needed for the production and placing on 
the market of products conforming to the essential 
requirements established for construction works '... is 
entrusted to organizations competent in the standard­
isation area'. 
1.13. The Committee supports the Commission in 
defining the role of the European Committee for Stan­
dardization (CEN) as the body responsible for Euro­
pean standards in the area of construction works. 
1.14. The Committee considers that the operational 
division of responsibility between the Commission and 
CEN is important and should be clearly defined and 
that the principles of the new approach should be 
followed in defining this relationship. A simple 
approach is needed to start the long programme 
involved in implementing the Directive. 
1.15. The third fundamental principle of the new 
approach is that those technical specifications for prod­
ucts which conform to the requirements of the Directive 
are not made mandatory but maintain their status of 
voluntary standards. The Committee supports the 
maintenance of the principle of voluntary standards 
arrived at by consensus and formally adopted in the 
European standards institutions by weighted majority 
voting. 
1.16. Thus CEN should use agreed procedures based 
on consensus to write terminology, classification, test 
11. 4. 88 Official Journal of the European Communities No C 95/31 
methods and acceptance levels, design codes, specifi­
cations for products and workmanship requirements. 
1.17. The Commission may mandate CEN to do this 
work but CEN should have the final say in the format 
and timing of the work it agrees to do. 
1.18. The Commission will need to agree with CEN 
the priority for the tasks to be undertaken. The Com­
mittee envisages that the Commission will give priority 
to mandates which will enable the essential require­
ments in the Directive to be codified by reference to 
design codes and technical product specifications. This 
will enable CEN to proceed with work on the harmon­
ization of technical specifications to replace the national 
standards of Member States. 
1.19. The Commission should discharge its responsi­
bility to the Council under the Single European Act 
by stating the mandatory essential requirements and 
supporting these with a series of interpretative docu­
ments which will indicate design codes and technical 
product standards necessary to support each essential 
requirement. 
These documents should be submitted for approval by 
the Council in cooperation with the European Parlia­
ment and after consultation with the Economic and 
Social Consultative Assembly. 
The Committee asks that an Article providing for this 
procedure should be added to the Directive. 
1.20. The Committee believes that the Commission 
should not undertake further technical work on the 
essential requirements once the interpretation docu­
ments have been agreed. The production of Eurocodes 
by the Commission, using a mixture of Member State 
public and private sector resources, should not be 
repeated. 
1.21. The Committee attaches great importance to 
testing and certification procedures and understands 
that the Commission will be submitting proposals in 
this area in the near future on which the Committee 
will give its Opinion. 
1.22. The Committee draws attention to its Opinion 
on the proposal for a Council Directive on the harmon­
ization of the laws of the Member States relating to 
simple pressure vessels [COM(86) 112 final] (l): 
'Technology is a dynamic component of social pol­
icy: Rules governing safety technology have an 
(!) OJ No C 328, 22. 12. 1986. important role to play in balancing economic and 
social interests (including health protection). Partici­
pation of the social groups is therefore called for.' 
1.23. The Committee considers for this reason, 
coupled with the unique complexity of the construction 
industry that the Commission should set up a mechan­
ism whereby it can make available to itself the experi­
ence and advice of the partners in the industry: the 
manufactures of construction products, the workers 
who make, install, operate and maintain them, the 
designers who specify them, the contractors who install 
them and the building owners and users. The Com­
mittee does not see this as a widening of the Standing 
Committee (Art. 19 of the proposed Directive) nor 
as a further Advisory Commitee which could lead to 
confusion. 
1.24. It regards the creation and successful operation 
of this proposed body as a key element for communi­
cation between the partners in the construction sector 
and the Commission and for mutual understanding of 
the interests of consumers, workers and producers. Its 
usefulness could extend to other areas affecting an 
internal market in construction. 
1.25. The Committee considers, furthermore, that 
the standardization mandates and draft standards con­
cerning or affecting workers' health and safety must be 
examined by a tripartite body providing an influential 
role for workers' representatives. 
1.26. Progress of implementation of the Directive 
The Committee realizes that when the Directive has 
been adopted an interim period will be required during 
which the Directive will be developed to its full potential 
by the Commission working together with CEN and 
the Member States. This may take several years. 
1.27. Initially Member States will review their laws 
and regulations and make suitable modifications to 
encompass the essential requirements. 
1.28. The Commission will write interpretative 
documents to guide CEN in the necessary work to 
encode and classify the essential requirements. 
1.29. As climatic and other conditions throughout 
the Community differ widely, essential requirement 
levels will also differ in the Member States. Member 
States will be free to choose levels of performance in 
each essential requirement to call up in their laws and 
No C 95/32 Official Journal of the European Communities 11. 4. 88 
regulations while leaving their consumers free to choose 
an appropriate level from the national standards. This 
will achieve the objective of Article 100 A of the Single 
European Act. 
1.30. The Committee urges the Commission to give 
high priority to this area of implementation. 
1.31. Simultaneously work to achieve the other 
objective to remove restraints to trade by harmonizing 
technical specifications must proceed. Such work will 
be in the hands of CEN and has already begun. Priority 
is being directed towards products for which a consider­
able transfrontier trade exists and where the lack of a 
harmonized standard may lead to barriers to trade or to 
increased cost arising from the necessity for a multiple 
product range. The procedures outlined in Chapter VI 
of the Directive are particularly appropriate in this area. 
1.32. The Committee believes that the harmonis-
ation of test methods, accuracies and acceptance levels 
and of classification of performance is most urgent 
and urges the Commission to consider all available 
resources for this work, including the possible use of 
facilities within the Joint Research Centre. It notes with 
satisfaction that the Commission is already making use 
of a DG XIII programme for small and medium-sized 
enterprises to fund a programme for the harmonisation 
of fire test results. 
1.33. Standards organisations should not be pressed 
for any reason to influence them to accept ready-made 
standards or standards proposals put forward by indi­
vidual Member States with available resources to the 
possible detriment of the interests of other Member 
States. The Commission should be responsible for a 
fair balance of interest of all Member States in so far 
that it issues mandates for work to be undertaken. 
1.34. The Committee considers that the ultimate 
objective must be to remove all barriers to use so that 
consumers may freely and knowledgeably exercise their 
choice. To do this it will be important to have a 
clear information structure and a common terminology 
throughout the Community. Systems should be 
arranged to assist designers and builders to assess the 
fitness for purpose of the products available to them. 
The Committee suggests that the Commission study 
this problem with the aim of making proposals for 
actions. 
1.35. Each Member State will have its own pro­
cedures for verification by testing of its requirements; 
for certification of conformity of product by product 
marking, initially on a type approval procedure and continually by quality assurance schemes; and for the 
accreditation of its testing and certification bodies. 
1.36. To achieve the requirements for an internal 
market in construction products by the end of 1992 a 
programme of harmonization will have to be 
implemented by the Member States. This will involve 
a coordinated programme by the Commission and CEN 
working together. The Commission will need to pro­
duce interpretative documents dealing with each of 
the essential requirements, to define design codes and 
technical requirements which will need to be called up 
in support of each requirement. 
1.37. Member States should be in a position to apply 
the same laws and regulations as they do at present to 
enforce control of the use of building products under 
their modified building regulations. However, the con­
trol of the marketing of products which do not satisfy 
the Directive is a different matter and the Committee 
considers that it should be given further attention. 
1.38. The Committee urges that the Commission 
prepare a programme of priorities and a timetable for 
the implementation of this Directive. This should be 
published for wide public comment followed by appro­
priate amendment. 
1.39. The Committee believes that the Commission 
will need to inform all partners in the construction 
sector of the benefits which will arise from implemen­
tation of the Directive. 
1.40. The involvement of the European Free Trade 
Association (EFTA) 
The Committee welcomes the involvement of the EFTA 
nations in the work of CEN and the agreement between 
CEN and EFTA for mandated work which parallels the 
agreement between CEN and the Commission. Thus 
EFTA will contribute financial and human resources to 
the production of harmonized design codes and techni­
cal product standards. Such cooperation between the 
Community and the EFTA nations should result in a 
wider European market. 
Undoubtedly there will be difficulties and conflicts of 
interest. The Committee urges the Commission to 
ensure that there is a mechanism for early identification 
of problem areas and their solution. 
2. Specific Comments 
2.1. The Committee assumes that as a consequence 
of the adoption of the Single European Act, this Direc­
tive will be altered to invoke Article 100 A rather than 
Article 100. 
IL^.DD COfficialjournai of the European Communities l^oC^A^ 
^. Arr^^ 
TheCommittee further considers thatArticleL^. should 
be redrafted to define construction products as all prod 
ucts which are used in construction works above and 
below ground and in fi^ed works at sea^ Aproduct 
shouldbedefinedasa materialorcomponenttransD 
ported to or fabricated upon the site ofaconstruction 
work.The Committee would prefer that the examples 
of products in Article!^ are omitted since suchalist 
can never be complete and mav cause confusion. If the 
list is to be maintained then it should be broadened with 
the clear provision that it is not exhaustive. Specifically 
Article L^^e^ should be amended to read^ 
5.. for example domestic installations for water 
supplv^waste disposal and drainage equipmentB 
Article l.^^should be amended^ 
prefabricated constructions such as houses and 
garages^ 
in order that there shouldbe no confusionabout the 
scope of the directive. 
The Commission is asked to consider whether this 
directive should applvto^ 
— power generation and distributions roads^ railway 
tunnels^ mines^ water distributions sewage oper 
ations and underwater constructions^ 
— agricultural buildings^ both temporary and perma 
nent^andsilos^ 
— mobile homes^ caravans and similar structures. 
The Committee asks that the Loirective be amended 
accordingly 
^, The Committee considers that the presumption 
of fitness for purpose will rest uponatesting and test 
house accreditationprocedure vet tobepublishedbv 
the Commission. The performance of thecompleted 
construction work incorporating the product will 
depend upon the design specifying the appropriate 
product anduponthe correct workmanshipininstal 
lation. This foirective covers neither of these matters. 
The Committeedoes notconsider that Article^is 
compatible with the new approach. It is also in conflict 
with the generalparagraphofAnne^L Itshouldbe 
deleted. 
Lhe Committee considersthat the constructionprod 
ucts must not onlv be fit for use but also such as not to harm the health and safetv of workers who 
manufactured assembled emplov or maintain them. 
Lhe Committee suggests that for practical reasons 
Article^.! be amended^ 
^Theappropriate references shall bepublishedin 
the form of lists inthe^C^series of the C^^^ 
The Committee considers that the phrase^and private 
bodies^ in Article ^.1 shouldbedeletedandthatthe 
application of this lOirective should be restricted to 
Member States Governments and those bodies over 
which thev have regulators control. The Committee 
asks that Article^.! be redrafted in the form ofatotallv 
clear definition of application. 
The directive should not attempt to cause Member 
Statestointroducelegislationwhichcould affect the 
choice of products bvdesigners^ contractors and their 
customers. 
^.D, In accordance with the principle outlined in 
points L^and L^above^oncethisLarectiveisin 
operations such restraints to free trade in the Com 
munitv will become apparent. After appropriate consuP 
ration the Commission will be able to deal with them 
bv separate and appropriate Community measures. 
^, Arr^^^ 
Lhe Committee asks that in Article^the procedure for 
giving mandates to European standardization bodies 
and the relationship and involvement of the Articled 
Committee with the procedure of the draft Council 
foirective to amending foirective D^l^EEC l^doc. 
CC^M^^final|beclearlv defined 
^. The Committee endorses the expression of the 
resulting standards as far as practicable in product 
performance terms ^point l.^abovePThis willtake 
account of the widelv differing climatic conditions and 
working practices in the enlarged Communitv and will 
accelerate the programme of voluntarv harmonization. 
In view of the obligation in Articled.1 to publish in the 
COfficial]ournal^ this Article is unnecessary and should 
be deleted. 
No C 95/34 Official Journal of the European Communities 11. 4. 88 
2.10. Article 7 
The Committee welcomes the role set out in the pro­
posed Directive for the European technical approval 
procedure given the significant proportion of individual 
products for which no standards exist. 
European technical approvals will be of particular value 
in the initial phase when European standards exist for 
a few products only. In respect of products which 
are basically amenable to standardization, the special 
procedures described in Chapter VI should be followed. 
2.11. The Committee urges the Commission to give 
priority to the harmonization of test methods (point 
1.29 above) and to procedures for mutual acceptance 
of text results. 
2.12. Article 8 
Annex II which provides guidelines for European tech­
nical approval, should be made more specific in respect 
of the content of the guidelines; notably to include 
specific product requirements, definitions of test pro­
cedure and methods for evaluating and assessing test 
results. 
The criteria for approval bodies should also be stated 
more specifically. 
2.13. Chapter IV, Articles 11 and 12 
These Articles dealing with the use of national or other 
technical specifications are not viable for purely practi­
cable reasons. There is no short cut to the process of 
European standardization as practised by the European 
standards bodies other than the consideration of one 
or more national comparable standards as reference 
documents. The Committee urges the Council to ask 
the Commission to reconsider this Chapter. 
2.14. Chapter V and Annexes HI, IV and V 
The Committee has not considered these parts of the 
Directive in detail since it understands that a separate 
Communication is expected from the Commission 
which will supersede the present proposals. The Com­
mittee endorses the need for proposals on a horizontal 
basis to cover matters of attestation of conformity, the 
use and protection of EC conformity marks, factory 
quality control (Annex III), and approval of testing 
laboratories, inspection bodies and certification bodies 
(Annex V). 
However, the following points are important. 2.15. Quality control is a crucial aspect of construc­
tion product surveillance for safety and health reasons. 
Certification is secondary in comparison. In its ultimate 
form the Directive should deal first with quality control 
procedures and then with the subsequent certification. 
In this connection attention is drawn to the European 
quality standard to be adopted by CEN. 
2.16. Mutual recognition of national certification 
arrangements should form the basis of European Com­
munity marking. To underpin the Directive in this 
respect and to avoid creating unnecessary bureaucracy, 
a European testing and certification framework should 
operate at national level through the ISO/IEC Guides 
now available. In the manner of EC marking the differ­
ence between full independent product certification and 
manufacturers declaration should be readily apparent 
and quality system certification ('capability assess­
ment') should on no account be confused with product 
conformity marking. 
2.17. In accordance with the operation of existing 
certification systems with regard to the GATT-Agree-
ment on technical barriers to trade, EC marking should 
be accessible to EC and third country manufacturers 
alike for the purpose of trading within the Community. 
2.18. It should be clearly stated what criteria and 
rules will apply to the type of certification which is 
considered appropriate for a product. Self-certification 
could lead to difficulties with construction products 
even though it may be appropriate in some other indus­
tries. 
2.19. The Committee believes that a procedure for 
third party certification in conjunction with a procedure 
for quality assurance will be the most appropriate for 
construction products to ensure that the objectives of 
the Directive to safeguard health and safety are 
achieved. 
2.20. Manufacturers (self)certification would be sat­
isfactory for large companies which are well established 
and have the requisite test facilities. The Committee 
considers, however, that the consumer requires the 
added protection of third party certification for the 
products of small or new companies which may not 
have adequate resources and which may cease to trade. 
Third party certification will create more equal con­
ditions for medium-sized and smaller companies. 
2.21. The Committee hopes that the Commission 
will take into consideration the voluntary systems of 
third party certification in operation in Member States 
11. 4. 88 Official Journal of the European Communities No C 95/35 
and will not jeopardize their continued existence. This 
precedent is well established by the low voltage Direc­
tive which also recognizes nominated safety marks by 
official organizations in Member States. 
2.22. It is assumed that the Commission will give 
consideration to the problem of monitoring the per­
formance of approval bodies which have been ac­
credited so that products which are substandard do not 
enter the market. 
2.23. Chapter Vlll 
Article 19 requires that a standing committee be set up, 
consisting of two representatives of each Member State 
and chaired by the Commission. 
Article 20 requires that the Commission shall consult 
the Committee on six specific areas. 
The Committee cannot judge if this list of specific areas 
is complete. It would prefer to see some wording such 
as 'The Commission shall consult the Committee on 
all matters affecting the attainment of the objectives 
and the smooth working of this Directive.' 
The Committee accepts that this should be an advisory 
committee but it urges the Council to ensure that the 
Commission apply to its operation the same principles 
that have led to the Committee, created by the Directive 
83/189/EEC, working effectively and in the interests of 
both the Community and the Member States. 
2.24. The Council is urged to ask the Commission 
to set up the advisory body proposed in paragraph 1.23, 
above. 
There is a precedent in the research field with the 
successful operation of the Industrial Research and 
Development Advisory Committee (IRDAC-CORDI) 
on which the social partners are represented. 
The Committee suggests that the appropriate European 
representative bodies be invited by the Commission to 
consider setting up such an organization for themselves 
in collaboration with and with the support of the Com­
mission. 
2.25. Essential requirement 4 - Safety in use 
This essential requirement refers specifically to the 
safety of the consumer and of the operator in the 
finished construction work. The Committee considers that it should also apply to 
the safety of maintenance workers. 
The safety and health of workers involved in the pro­
duction and fabrication of construction products does 
not form a part of this Directive and this should be 
stated specifically. The International Labour Organ­
ization (ILO) is currently working on a new convention 
to cover health and safety of construction workers 
while the Commission is proposing a Directive on safety 
at the workplace. 
Essential requirement 5 - Durability 
Durability should not be listed as an essential require­
ment as this is inappropriate in the light of the specific 
conditions of the construction sector. It is not covered 
by Article 100 A of the Single European Act except in 
so far as it affects health and safety. 
The Committee believes that building owners will con­
sider the life span they require for their buildings 
together with the maintenance cost and the practicality 
of maintenance. This will affect the choice of the prod­
uct to use. 
As part of their indication of fitness purpose standards 
need to give a reasonable guide to the expectation of 
life of the product and hence the consideration of the 
various degrees of durability and their expression in 
graded standards. 
The Committee therefore considers that durability 
should not be considered in isolation but in conjunction 
with all of the essential requirements. 
2.26. Essential requirement 6 - Protection against noise 
The Committee asks the Commission to note that prob­
lems of noise in construction design are complex and 
vary greatly in different locations and with quality 
of workmanship. Common terminology and common 
methods of assessment and test must be achieved. 
2.27. Annex 11 - European technical approval 
The Committee suggests in point 3.2 the deletion of 
'the Standing Committee may appoint an ad hoc expert 
group invited to express their ideas and wishes on the 
subject'. 
No C 95/36 Official Journal of the European Communities 11. 4. 88 
The creation of such a group of experts could lead to 
blockage since in the same paragraph (3.2) it is made a 
condition that there should be a consultation of the 
joint European body. This latter body is already a group of experts each of which can in turn consult with 
other experts. In principle the Committee disagrees with 
the need to consult with two groups of experts in the 
same area. 
Done at Brussels, 25 February 1988. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT