No C 232/20 Official Journal of the European Communities 31. 8. 87 
— egg products must be sent for treatment to establishments 
approved in accordance with this Directive.' 
The old paragraph 3 becomes paragraph 4. 
2.6. Annex Chapter 5 
2.6.1. Annex Chapter 5, paragraph 6 
The Committee calls for a clear ban on certain breaking 
procedures liable to result in the contamination of egg 
contents. The proposed text is inadequate and the following 
wording is therefore suggested: 
'. . .of the egg contents. The manufacture of egg 
products by centrifuging or crushing eggs is prohibited. 
The remains . . .' 2.6.2. Annex Chapter 5, paragraph 9 
Egg products are obtained at treatment establishments, 
packing centres and at farms of production. As egg products 
destined for consumption have to be treated, it is suggested 
that untreated egg products destined for consumption be 
required to be despatched to an approved treatment 
establishment. The proposal does not explicitly require this. 
The first sentence should therefore be reworded to read: 
'9. Egg products collected in a non-approved 
establishment must be sent to an approved establishment 
for treatment. Particular attention should be paid to the 
following: 
(b) 
(c) 
Done at Brussels, 1 July 1987. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
Opinion of the Economic and Social Committee on the proposal for a Council Directive adapting to 
technical progress Directive 70/156/EEC on the approximation of the laws of the Member States 
relating to the type-approval of motor vehicles and their trailers (*) 
(87/C 232/12) 
On 13 April 1987 the Council decided to consult the Economic and Social Committee, under Article 
100 of the EEC Treaty, on the abovementioned proposal. 
The Section for Industry, Commerce, Crafts and Services was responsible for preparing the 
Committee's work on the subject. In the course of the work the Committee appointed Mr 
Perrin-Pelletier as rapporteur-general. 
At its 247th plenary session (meeting of 1 July 1987) the Economic and Social Committee adopted the 
following opinion unanimously: 
The Committee endorses the Commission's proposal subject to the following comments: 
1. Introduction 
1.1. The urgent need for a Community definition of 
off-road vehicles derives from the fact that a definition of 
such vehicles is either lacking or varies in the Member States. 
H OJNoC 108,23.4. 1987. This absence of a common definition creates both serious 
disadvantages for manufacturers and barriers to 
intra-Community exchanges in these vehicles. 
1.2. The present proposal concerns the inclusion in 
Annex 1 to Directive 70/156/EEC of the definitions of 
off-road vehicles within categories M (passenger cars) and N 
(motor vehicles used for the carriage of goods). The principal 
31. 8. 87 Official Journal of the European Communities No C 232/21 
parameters on which these definitions are based are, on the 
one hand, the traction afforded by the axles and hill-climbing 
ability and, on the other, the presence of a device for locking 
the differential or a mechanism producing a similar effect. 
1.3. The proposal does not seek to define ergonomic 
parameters. 
2. Comments 
2.1. For an off-road vehicle to be properly suited to and to 
be able to operate effectively on such terrain it must be 
designed with particular attention to the following 
parameters: 
— traction, 
— transmission of drive to the axles/wheels, 
— gradability, 
— ground clearances under all conditions of operation. 
The Commission's proposal is based on these parameters. 
2.2. The proposal is founded on the recognized 
international categories of motor vehicles, which will bring 
clarity in its application within the Community. 
2.3. The proposal provides, effectively, subtly different 
sets of criteria which vehicles must comply with depending 
upon their weight and classification (i.e. M,, M3 etc) and sets 
conditions for each case. 
2.4. The definition proposed by the Commission appears 
in general terms to be stringent enough to prevent vehicles 
which were not really designed for purposeful off-road use 
from being classified as 'off-road' and thus benefiting from 
the 1 or 2 dB(A) derogation provided in Directive 
84/424/EEC. Equally it is not so stringent as to 
unreasonably exclude vehicles which are truly designed for 
and actually operate in off-road situations. 
Done at Brussels, 1 July 1987. 2.5. However, in points 4.2. and 4.3. of the proposal, 
relating to the definition of the higher categories, an 
apparently compulsory condition on disengagement of axle 
drive is laid down. 
While agreeing with the variety of criteria on weight and 
classification (Mi, M3 etc.), the Committee takes the view 
that the fact that 'the drive to one axle can be disengaged' 
must not constitute a definition parameter. 
2.6. In addition to the traction/transmission criteria the 
definition is based on compliance with 
geometric/dimensional criteria established in an operating 
condition, i.e. loaded to the technically permissible 
maximum mass stated by the manufacturer (except in the 
case of Mi and Ni vehicles below 2 tonnes). 
2.7. The Committee recognizes that no definition in this 
particular field can ever be perfect when dealing with a 
vehicle type which has so many variants. The definition has 
to be optimized and marginal cases will have to be 
individually judged by the competent technical services of the 
Member States when type approval is being sought. 
2.8. Thus, in order to verify that the compliance criteria 
are indeed optimal and also to ascertain whether in the future 
attempts are made to authorize vehicles as 'off-road' when 
that is not in reality the use to which they will be put or the 
purpose for which they were designed, the Commission 
should recommend to the Member States that they should 
monitor applications for new type-approvals. 
2.9. It appears that some of the texts may have somehow 
suffered in translation and the detailed wording differs subtly 
and probably unintentionally from the proposal on which the 
Committee for Adaptation to Technical Progress gave its 
favourable opinion in 1986. These differences must be 
eliminated, however, as they actually change the manner in 
which the definition is to be interpreted. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT