24. 4. 89 Official Journal of the European Communities No C 102/9 
ory role. The adaptation Committee procedure used to 
date has achieved results and in particular has provided 
considerable expertise during the preparation of Com­
munity legislation. This procedure should be retained 
for the sake of its clarity, simplicity and speediness. 
Done at Brussels, 22 February 1989. 
1. General comments 
1.1. The Committee welcomes this proposal for a 
Directive. It notes that the essential aim of the proposal 
is to harmonize the composition and the levels of trace 
elements in fertilizers. 
1.2. This is therefore not an environmental protec­
tion Directive, although environmental protection is 
involved (see, in particular, the end of Article 4, and 
Article 5). 
(•) OJ No C 304, 29. 11. 1988, p. 8. Article 2 
The Committee would point out that Community 
Directives usually enter into force eighteen months after 
adoption and publication in the Member States. The 1 
October 1989 deadline seems to the Committee to be 
unrealistic. Bearing in mind the facts it therefore pro­
poses that the Directive enter into force one year after 
adoption and publication in the Member States. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
1.3. It should be noted that: 
— trace elements are important for the quality of crops 
and influence their quantity, 
— they should, however, be carefully dosed, to avoid 
residues which might find their way into the food 
chain. 
1.4. The introduction of 'complexed' trace elements 
is interesting in that the combination of these with 
chelating agents of organic origin makes it possible to 
reduce the dose of these trace elements significantly 
while increasing their effectiveness. Opinion on the proposal for a Council Directive on the approximation of the laws of the 
Member States in respect of the trace elements boron, cobalt, copper, iron, manganese, 
molybdenum and zinc contained in fertilizers (*) 
(89/C 102/06) 
On 11 November 1988 the Council decided to consult the Economic and Social Committee, 
under Article 100 A of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Industry, Commerce, Crafts and Services, which was responsible for preparing 
the Committee's work on the subject, adopted its Opinion on 1 February 1989. The rapporteur 
was Mr Proumens. 
At its 263rd plenary session (meeting of 22 February 1989) the Economic and Social Committee 
adopted the following Opinion unanimously. 
No C 102/10 Official Journal of the European Communities 24. 4. 89 
1.5. It is of course important that the chelating and 
complexing agents should not also have properties 
which might entail an environmental or health hazard. 
1.6. It should be remembered that fertilizers have 
been subject to a variety of rules for nearly a century. 
The European Commission has been harmonizing these 
rules for about 25 years. 
This draft Directive is the fourth for this purpose. 
2. Specific comments 
2.1. Article 2 of the draft Directive states that EEC 
fertilizers complying with the provisions of Article 1 
shall be packaged. The Committee takes the view that 
the idea of such products being sold in bulk should be 
accepted, since this practice is spreading (particularly 
in agricultural cooperatives), although its desirability is 
rather questionable. 
However, the invoice and/or the accompanying docu­
ments should in that case clearly indicate the compo­
sition, as laid down in Article 3. The invoice and/or 
accompanying documents should also include rec­
ommendations for use—either compulsory or optional, 
but at all events corresponding to those on the packages 
referred to. 
2.2. The last paragraph of Article 3 might seem to 
be too lax. In fact the Commission intends the optional 
declaration to apply more particularly to traces which 
are so to speak always present in the raw materials. As 
these traces are difficult to measure, the declaration, 
while recommended, remains optional to avoid creating 
difficulties for small or medium-sized enterprises. 
2.3. In the paragraph of Article 4 beginning with 
'The trace element content...', the Committee suggests 
the addition of: 'In the case of products sold in liquid 
form, the trace element content in kilograms per 
100 litres at a temperature of 20 °C shall also be 
stated.' 
2.4. At the end of Article 4, the term 'recognized 
need' in the proposed instructions should, in the Com­
mittee's view, be changed. The following wording is 
preferred: 'To be used only in the case of a deficiency 
or specific needs. Do not exceed the appropriate dose 
rates.' 2.5. Article 5: this Article would enable the Member 
States to authorize the inclusion of additional infor­
mation useful to the farmer, without such information 
being made compulsory or becoming an obstacle to free 
movement. 
2.6. The Committee wonders whether the Com­
mission should not add to this Article a provision to 
the effect that the Member States should encourage 
those responsible for the marketing of the fertilizer on 
their territory to make maximum use of this possibility, 
provided of course that no marketing barriers are cre­
ated. 
3. Examination of the Annex 
3.1. In view of the complexity of the annex and of 
the changes which may be made to it, the Committee 
feels that its content should be dealt with by the experts 
of the Commission, the Member States and industry. 
3.2. However, it is important that this expert clarifi­
cation should adhere to the general lines of the Direc­
tive. 
4. Specific cases 
4.1. The list of chelating agents as given in Chapter E 
of the Annex does not include every category of chelat­
ing agents widely used at European level. The following 
are omitted: 
— hydroxyethylidene diphosphonic acid (HEDP) = 
— nitrilotriacetic acid (NTA) = C6 H9 N06, 
— the polyamines = CnHm(N02) p. 
It is therefore important for the Commission to include 
them in this new list before the final changes are made 
to the present text of the proposal. 
4.2. Since the development of trace elements in com-
plexed or chelated form is desirable, the list in 
Chapter E of the Annex will probably require sub­
sequent revision. The matter is important: 
— for the industry, which is developing new products, 
— for users and consumers, in terms of ensuring that 
the organic chelating or complexing agents are non­
toxic. 
This is why the Committee would suggest that the 
Committee on adaptation to technical progress (CATP) 
should have its powers extended to include the toxico-
logical examination of chelating and complexing 
agents. 
24. 4. 89 Official Journal of the European Communities No C 102/11 
4.3. Once the CATP had these new responsibilities, 
it would be possible to make purely technical changes to the current list, without amending the basic Directives. 
Done at Brussels, 22 February 1989. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
Opinion on the proposal for a Council Regulation amending Regulation (EEC) No 3/84 
introducing arrangements for movement within the Community of goods sent from one 
Member State for temporary use in one or more other Member States (]) 
(89/C 102/07) 
On 5 December 1988 the Council decided to consult the Economic and Social Committee, 
under Article 100 A of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Industry, Commerce, Crafts and Services, which was responsible for preparing 
the Committee's work on the subject, adopted its Opinion on 1 February 1989. The rapporteur 
was Mr Broicher. 
At its 263rd plenary session (meeting of 22 February 1989) the Economic and Social Committee 
unanimously adopted the following Opinion. 
The Committee supports the Commission's proposal for a change in the procedure for the 
temporary use of goods. 
It sees in the expansion of the range of goods covered, the simplification of the procedures 
and the abolition of controls an exemplary step towards completion of the internal market. 
Regardless of the objective of complete abolition of internal frontiers as from 1993, it is 
important that the public should be offered now substantial facilities which should not pose 
any serious problems for the Member States. 
Done at Brussels, 22 February 1989. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
(') OJ No C 324, 13. 12. 1988, p. 8.