17. 6. 91 Official Journal of the European Communities No C 159/51 
and size of the workforce would not justify the employ­
ment of separate environmental health and industrial 
safety officers, could cover themselves by providing 
additional training (in environmental protection or 
industrial safety). In this way one employee could be 
responsible for both areas. 
3.3. If these proposals are implemented, manage­
ment should also have the opportunity to use environ­
mental knowledge in quality circles to develop environ­
ment-friendly products and production processes. This 
will facilitate the introduction by management of Qual­
ity Assurance applied to environmental protection. 
This does not exclude the possibility of a firm seeking 
outside environmental advice. 
Done at Brussels, 24 April 1991. 
1. Preliminary comments 
1.1. The Committee notes the difficult situation on 
the agricultural markets caused by the continuing 
increase in production, stationary or declining con­
sumption, reduced export opportunities, rising imports 
of cereal substitutes and of calves for fattening. 3.4. Environmental work should be handled separ­
ately, i.e. by an internal department separate from the 
safety and health committees. 
The quality circles referred to in 3.3 would undoubtedly 
be an appropriate place. While safety is directly relevant 
to all of a firm's workers, the environment affects not 
only the firm and its workers but also the outside world, 
e.g. sub-contractors, suppliers, customers and, of 
course, the final consumer. 
3.5. If the above proposals are implemented, atten­
tion will have to be paid to the danger of a distortion 
of competition affecting small and medium-sized busi­
nesses (SMB). Consideration should also be given to 
economic and social cohesion, especially in cross-border 
situations. 
The Chairman 
of the Economic and Social Committee 
Francois STAEDELIN 
1.2. This difficult situation is reflected in falling pro­
ducer prices and falling or stagnant farm incomes, 
growing surpluses held in stock, rising expenditure on 
export refunds and intervention. 
1.3. As a result the budget guidelines laid down by Opinion on the Commission Proposals on the prices for agricultural products and on related 
measures (1991/1992) 
(91/C 159/16) 
On 14 March 1991 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned proposals. 
The Section for Agriculture and Fisheries, which was responsible for preparing the Comittee's 
work on the subject, adopted its Opinion on 11 April 1991. The Rapporteur was 
Mr Schnieders. 
At its 286th plenary session (meeting of 25 April 1991), the Economic and Social Committee 
adopted the following Opinion by a large majority with 2 votes against and 8 abstentions. 
No C 159/52 Official Journal of the European Communities 17. 6. 91 
the Council in 1988 will be reached or exceeded in 
1991/1992. 
1.4. The internal problems of agriculture, which 
have led to the increasing sales difficulties, have been 
exacerbated by external developments, such as the fall 
in the dollar (though this has recovered considerably of 
late), a loss of sales in the wake of the Gulf crisis, a 
loss of market outlets caused by the growing economic 
difficulties in Eastern Europe and the full accession, 
without any transitional period, of the five new German 
Lander where agricultural production and marketing 
had been geared to completely different ends than those 
of the Community. 
1.5. Here it should also be mentioned that the series 
of related measures which were intended to accompany 
the 1988 budget guideline and stabilizers have not been 
fully implemented. 
1.5.1. While the prices of agricultural products have 
fallen dramatically once the fixed guaranteed quantities 
are exceeded, implementation of the related measures 
provided for in the Council Decision of February 1988, 
which were designed to present the guaranteed quanti­
ties being reached, has been unsatisfactory. This applies 
to the effectiveness of EC-wide set-aside, the introduc­
tion of a premium for cereals used in animal feed, a 
satisfactory curb on imports of substitutes and greater 
encouragement for the introduction of renewable raw 
materials. 
1.6. The Committee acknowledges that the present 
budgetary situation obliges the Commission to propose 
measures to safeguard funding. 
1.7. In its communication of 1 February 1991 (x) on 
the development and future of the common agricultural 
policy (CAP), the Commission sums up the dilemma: 
'The contrast between, on the one hand, such a 
rapidly growing budget and, on the other, agricul­
tural income growing very slowly, as well as an 
agricultural population in decline, shows clearly 
that the mechanisms of the CAP as currently applied 
are no longer in a position to attain certain objec­
tives prescribed for the agricultural policy under 
Article 39 of the Treaty of Rome' (2). 
1.8. The Commission states that the consequence is 
a crisis of confidence regarding the CAP among farmers, 
consumers and the Community's trading partners on 
the world market. This is so fundamental that the CAP 
should be comprehensively reformed. 1.8.1. The Commission's aims in this are: 
— to keep as many farmers as possible on the land, 
— to improve protection of nature and the environ­
ment, 
— to develop and launch raw materials for non-food 
uses, in addition to food production, 
— to promote regional economic development com­
prehensively, 
— to curb agricultural production through lower 
prices, quantitative controls and extensification, so 
that balance is restored to the market and account 
taken of regional characteristics, the demands of 
environmental protection and the potential of 
renewable raw materials. 
1.8.2. The Committee will shortly examine the pro­
posals for CAP reform. 
1.9. The Commission feels, however, that it cannot 
wait until discussion of its Reflections Paper on the 
future development of the CAP is complete. It states 
the following: 
'Taking into account that in depth reform of a 
number of common market organizations is needed 
and that specific proposals to do so will be presented 
this year, the Commission would have preferred, at 
this stage, to propose a simple roll-over of present 
institutional prices for one year until the reform 
measures have been adopted and come into effect. 
However, the considerable deterioration of the 
budgetary situation for 1991 and the worsening 
prospects for 1992, obliges the Commission, in the 
interests of budgetary discipline, to supplement its 
roll-over price proposals for the 1991/92 marketing 
year by a number of specific proposals designed to 
contain agricultural expenditure in 1991 within the 
limits of the agricultural guideline, and to make the 
maximum savings in 1992'(3). 
1.10. The Committee would also point to the brief 
which the Council gave the Commission for the nego­
tiations (4) of the General Agreement on Tariffs and 
Trade (GATT) to put forward specific proposals as 
quickly as possible which embody appropriate financial 
solidarity, offer Community farmers a viable future 
and are compatible with GATT commitments. This 
approach could be based on the following factors: 
— safeguarding the competitiveness of EC agriculture, 
(') COM(91) 100 final. 
(2) COM(91) 100 final, Chapter I. point 1, 3rd paragraph. (3) COM(91) 72 final, Vol. I, page 14, point 27. 
(4) SN/286/1/90. 
17. 6. 91 Official Journal of the European Communities No C 159/53 
— a fair reform of farm support, based on the diversity 
of farm and production structures, which keeps 
production under control and ensures a reasonable 
level of income support, 
— reinforcement of structural aids, including aid not 
connected with the volume of production, with the 
emphasis to be placed on those groups of producers 
or regions experiencing the greatest difficulties in 
adjusting to the new situation and greater import­
ance to be attached to measures to protect the 
environment and product quality. 
2. General comments 
2.1. The Committee notes the Commission's assess­
ment of the market situation and the figures for Euro­
pean Agricultural Guidance and Guarantee Fund 
(EAGGF) expenditure. 
2.2. A lack of time has meant that the Committee 
has been unable to examine some details of the price 
proposals in depth. 
2.3. In the light of the following arguments it never­
theless recommends that the Commission proposal be 
amended as set out below. 
2.4. Some of the price cuts and related measures 
proposed by the Commission will result in substantial 
loss of income for farmers. Bearing in mind the situation 
of farmers, and with due regard for the comments made 
in 2.4.1 and 1.6, the Committee considers that no price 
reductions should be made before the reform dis­
cussions are concluded. The Commission itself states 
that: 
'The per capita purchasing power of those engaged 
in agriculture has improved very little over the 
period 1975-89. This development is all the more 
worrying in that over the same period the Com­
munity's active agricultural population has fallen 
by35%'(1). 
2.4.1. The Commission's budgetary latitude should 
be used to the full. 
2.4.1.1. The Committee would point out that the 
introduction of stabilizers resulted in considerable 
savings in the 1989 and 1990 financial years. 
2.4.1.2. The overrun in EAGGF expenditure is large­
ly due to exceptional circumstances which have their 
origins both inside and outside agriculture. 
2.4.1.3. The Committee is of the view that the 
additional funds to be provided for German unifi-
(l) COM(91) 100 final, p. 2. cation—in line with Parliament and Council Declar­
ations and Decisions—should be taken up. In this way 
the 480 million ECU overrun of the agricultural guide­
line forecast by the Commission could be easily 
absorbed. The Committee does not consider it justifi­
able that farmers should be the only ones to suffer from 
political developments. 
2.5. Bearing in mind the GATT negotiations too, the 
Commission should avoid measures which undermine 
its negotiating position. Consequently the Committee 
urges that only a few urgent measures be taken, which 
ease the situation on the markets but do not further 
reduce farm incomes. 
2.6. In the light of the foregoing, the Committee 
proposes that the 1990/91 prices be retained, that only 
a limited number of measures be adopted in connection 
with the structural surpluses in cereals, beef/veal and 
milk, and that a few changes be made in the proposals 
for Mediterranean products. 
2.6.1. In view of the marketing difficulties and 
declining consumption of some farm products (meat 
and milk for instance), the Committee advocates special 
measures to raise sales. 
2.6.2. Accompanying measures will also reduce 
budgetary expenditure. 
3. Specific comments 
3.1. Cereals 
3.1.1. The Committee supports the Commission's 
set-aside proposals. They represent a first opportunity: 
— to prevent a further increase in financing require­
ments; 
— to prevent a further reduction in farm incomes; 
— to reach a fair agreement in the GATT negotiations 
on how to restore order to world markets. 
3.1.2. This measure is for one year only. The Com­
mittee would ask the Commission to ensure that it does 
not have adverse repercussions in the most disadvan­
taged regions. 
3.1.3. The Committee would, however, point out 
that set-aside is a market measure and should receive 
more Community funding than hitherto. It calls on the 
Commission to ensure, through appropriate measures, 
that all regions participate adequately in the set-aside. 
No C 159/54 Official Journal of the 
3.1.4. With regard to the administrative aspect of 
the measures, the Committee calls on the Commission 
to submit practical proposals which obviate the need 
for unnecessary transfers of funds between vendor and 
buyer. 
3.2. Durum wheat 
3.2.1. The Committee can accept the 7% reduction 
in the price of durum wheat, but only if such a reduction 
is offset in full by a corresponding increase in pro­
duction aid in the traditional durum wheat growing 
areas of the Mediterranean. 
3.3. Rice 
3.3.1. The Committee thinks that the intervention 
prices should not be reduced and that aid for indica 
rice production in 1991/1992 should remain at the level 
of the preceding marketing year. 
3.4. Oilseeds, soya, protein crops, flax and linseed 
3.4.1. The Committee advocates dropping the 3% 
reduction of the guide and intervention prices and the 
minimum and target prices and the abolition of the 
premium for OO rapeseed; in particular it proposes 
awaiting the results of the proposed set-aside scheme 
which is expected to cut oilseed production by reducing 
the area under cultivation. 
3.4.2. Producer prices for rapeseed fell by a total of 
21 % between 1986 and 1990 as a result of the stabil­
izers. Income from protein crops, flax and linseed has 
been declining for years. The shortfall in supplies of 
these crops, which are extremely valuable from an 
environmental angle, also justifies abandoning the pro­
posed measures. 
3.4.3. In addition, the market regime for oilseeds is 
closely linked to the results of the GATT negotiations. 
3.4.4. The abolition of the OO rapeseed premium 
is premature. The currently available OO rapeseed 
varieties are still not as reliable as the previous varieties. 
3.4.5. The postponement of the official harvest esti­
mates for rapeseed, sunflower seed and soya will delay 
settlement between producers and first buyers. It is 
therefore proposed that this measure be dropped. 
3.5. Olive oil European Communities 17. 6. 91 
next three marketing years. The Committee has, for 
some considerable time, been calling for an increase in 
the MGQ and protection for small producers against 
the effects of stabilizers. 
3.5.2. The 500-kg limit for aid to small producers 
has been retained. This threshold must be raised. 
3.6. Sugar-beet 
3.6.1. The white sugar intervention price and the 
minimum beet price should not be reduced by 5%, 
especially as the costs of disposing of Community pro­
duction surpluses are not met from the EC budget. 
Production is controlled by the quota system. Beet 
and sugar production in the Community has developed 
efficiently under this system. In view of the difficult 
situation of arable farmers, existing sources of income 
should not be curbed. 
3.7. Tobacco 
3.7.1. The Committee reiterates its proposal of 
27 January 1988 (*) that the imbalance in the tobacco 
market be gradually eliminated by adopting socio-struc-
tural measures in the less developed regions. It further 
calls for a coherent policy for tobacco and tobacco 
products. 
3.7.2. The Committee notes that a change in the 
present market organization machinery is expected 
soon. Basic mechanisms are to be proposed and 
implemented in time for the 1992 harvest. 
3.8. Fruit and vegetables 
3.8.1. The Committee calls for a vigorous, market-
oriented quality policy to be pursued in all the Member 
States. 
3.8.2. The intervention thresholds for apples should 
not be further reduced to 3 % of the average production 
for the last 5 years. 
3.9. Nuts 
3.9.1. In view of the serious situation in the Com­
munity dry fruits sector and the expectations aroused 
by the adoption of Regulation (EEC) No 789/89, it 
makes no sense whatsoever to amend this Regulation 
3.5.1. The maximum guaranteed quantity (MGQ) 
has not been changed and indeed has been fixed for the (J) OJ No C 112, 7. 5. 1990. 
17. 6. 91 Official Journal of the European Communities No C 159/55 
again a little more than a year after its adoption on 
account of budgetary problems, especially as the Com­
munity is heavily in deficit for hazel nuts and almonds. 
3.9.1.1. It must be borne in mind that this aid benefits 
quality and marketing rather than production, is 
described as fundamental in the communication on the 
development and future of the CAP, does not distort 
the markets and is in accordance with GATT. 
3.10. Cotton 
3.10.1. The MGQ has been retained. It should, how­
ever, be increased since the clearcut economic con­
ditions prevailing at the time it was fixed no longer 
obtain. In addition, this product is in short supply in 
the Communty. 
3.11. Beef and veal 
3.11.1. The proposal to maintain institutional prices 
at their present level merely creates an illusion of price 
stability. The terms of intervention, which are based 
on these prices, are to be changed in away which will 
probably lead to further falls in prices. 
3.11.1.1. The proposed abolition of the so-called 
'safety net', along with the drastic reduction in the 
trigger levels for intervention buying, undermine inter­
vention to such an extent that it is worthless as an 
instrument of market support. The Committee rejects 
the proposed measures. Any cutback in the intervention 
measures should take the form of a limitation of inter­
vention buying to certain times of the year, while main­
taining the present quantitative restrictions intact. The 
triggers for intervention buying should remain at their 
present levels. According to the Committee, the Com­
mission should reexamine its procedures in relation to 
storage costs, depreciation of stocks and disposal of 
stocks in order to determine whether part of the necess­
ary saving can by borne by off-farm interests. 
Done at Brussels, 25 April 1991. 3.11.1.2. If intervention is to be cutback, the present 
premium system, i.e. the granting of premiums for 
cattle, should be extended by way of compensation. 
Measures to restore balance to the beef and veal market 
are urgently needed. A linking of premiums to the 
stocking rate per hectare forage crops—with a realistic 
ratio of 2.5 livestock units per hectare main forage 
area—would be acceptable. It is the small farmer who 
suffers most if environmental or operating restrictions 
are carried too far. 
3.11.1.3. To restore balance to the market, imports 
of fattening calves into the EC should be limited as 
long as the surpluses persist. As part of the EC's extensi-
fication programme, incentives should also be provided 
for the temporary or partial set-aside of cattle-fattening 
capacity. 
3.12. Milk 
3.12.1. A change in the guaranteed quantity during 
the current year will raise major problems between the 
regions for which there are no satisfactory solutions 
(e.g. substantial fluctuations in milk production accord­
ing to the month). The Committee notes the Com­
mission's statement that, for legal reasons, it will no 
longer be possible to change the guaranteed quantity 
after 1 April. As a reduction in the guaranteed quantity 
is in the interests of market stability, the EC should 
immediately propose a voluntary programme to buy 
out structural milk surpluses. 
3.12.1.1. Any change in the guaranteed quantity 
must be discussed in the context of CAP reform. 
3.12.1.2. The Committee calls on the Commission 
not to aggravate sales difficulties on the international 
market by adopting a restrictive approach to prices and 
aid. 
3.13. Agrimonetary proposal 
3.13.1. Since green money will be phased out by the 
end of 1992, and since the remaining gaps (apart from 
the drachma) are small, the gaps should now be nar­
rowed by at least half and not one third as suggested 
by the Commission. 
The Chairman 
of the Economic and Social Committee 
Francois STAEDELIN 
No C 159/56 Official Journal of the European Communities 17. 6. 91 
APPENDIX 
(Article 43, fourth paragraph of the Rules of Procedure) 
The following proposed amendment was rejected by the Plenary Session: 
Point 1.8.2 
Insert the following at the beginning of 1.8.2: 
'The Committee endorses these aims and will look into what measures are needed to achieve them.' 
Voting 
For: 25, against: 45, abstentions: 10. 
Opinion on the amendment to the Proposal for a Directive on the approximation of the laws 
of the Member States relating to compulsory use of safety belts in vehicles of less than 
3,5 tonnes (!) 
(91/C 159/17) 
On 28 January 1991 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned amendment to the Proposal. 
The Section for Transport and Communications, which was responsible for preparing the 
Committee's work on the subject, adopted its Opinion on 10 April 1991. The Rapporteur 
was Mr Tukker. 
At its 286th plenary session (meeting of 25 April 1991), the Economic and Social Committee 
adopted the following Opinion unanimously. 
1. Introduction 
1.1. The Council has already adopted a number of 
Directives on the approximation of Member State laws 
relating to safety belts and their anchorages in various 
categories of motor vehicles. Directives 81/575/EEC 
and 82/318/EEC stated that their provisions were to 
come into effect by 30 September 1982, the correspond­
ing date for the proposed Directive COM(88) 544 is 
1 January 1993. 
1.2. These Directives specify that front and rear-seat 
belts must be used in three categories of motor vehicles: 
— Category Ml: Vehicles used for the carriage of 
passengers and comprising no more than eight seats in 
addition to the driver's seat. 
(*) OJ No C 308, 8. 12. 1990, p. 11. — Category M2: Vehicles used for the carriage of 
passengers, comprising more than eight seats in 
addition to the driver's seat, and having a maximum 
weight not exceeding 3,5 metric tonnes. 
— Category Nl: Vehicles used for the carriage of goods 
and having a maximum weight not exceeding 3.5 metric 
tonnes. 
1.3. Broadly speaking, these three Directives only 
apply to persons aged 12 or more. With respect to 
children aged less than twelve, they merely specify that 
they must sit on a rear seat and not on a front seat. 
2. Specific comments 
2.1. The proposed amendment to COM(88) 544 final 
clearly states where and how children up to twelve 
years (i.e. aged eleven or less) may use category I, II 
and III vehicles. The use of safety systems is prescribed