No C 178/30 Official Journal of the European Communities 15. 7. 82 
Opinion on the draft Council recommendation on the principles of a Community policy 
with regard to retirement age 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 16 of 21 January 1982, page 12. 
A. LEGAL BASIS FOR THE OPINION 
On 12 January 1982 the Council referred the abovementioned proposal to the Econo­
mic and Social Committee in accordance with Article 198 of the Treaty establishing 
the European Economic Community. 
B. OPINION OF THE ECONOMIC AND SOICIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
197th plenary session held in Brussels on 28 and 29 April 1982. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the Euro­
pean Economic Community, and in particular 
Article 198 thereof, 
Having regard to the request made by the Council 
of the European Communities on 12 January 1982 
for an opinion on the draft Council recommenda­
tion on the principles of a Community policy with 
regard to retirement age, 
Having regard to the decision taken by its Bureau 
on 26 January 1982, instructing the Section for 
Social Questions to draw up an opinion and a report 
on the matter, 
Having regard to the opinion adopted by the Sec­
tion for Social Questions on 15 April 1982, 
Having regard to the report submitted by the rappor­
teur, Mr Blasig, 
Having regard to the discussions during the 197th 
plenary session, held on 28 and 29 April 1982, 
HAS ADOPTED THE FOLLOWING OPINION 
with no dissenting votes but with 11 abstentions: 
General remarks 
1.1. The Economic arid Social Committee wel­
comes the Commission's recommendation as a step towards the implementation of arrangements for a 
flexible retirement age. 
1.2. The Committee accepts the gradual approach 
outlined in this draft recommendation. The Com­
mittee is pleased that the Commission views the 
resolution as an initial step and will, if occasion 
demands, propose further measures, in the light of 
the reports which are to be submitted by the Mem­
ber States. 
1.3. The Committee approves the principle that 
workers should be free to choose the age at which 
they retire. Workers should be entitled, but not 
obliged, to draw their retirement pension early, and 
should be entitled to choose when to do so. 
1.4. The introduction of arrangements for a flexi­
ble retirement age entails specific problems. The 
most significant ones are outlined below this. Con­
sideration must be given to these problems, so that 
the employees concerned, the employer and society 
at large can derive the maximum advantage from 
the provisions for early retirement. 
2. Size of pension 
2.1. The Committee is in favour of the principle 
that workers opting to take up their right to early 
retirement should be guaranteed an adequate pen­
sion. ' 
15. 7. 82 Official Journal of the European Communities No C 178/31 
The pension should be in keeping with the length of 
time the individual has been in a pension scheme 
and/or the contributions he has paid into it in so far 
as these factors are fundamental to the size of the 
pension. 
2.2. To ensure that there is genuine freedom to 
decide when to retire, reductions in pension pay­
ments made to persons opting for early retirement 
should not, in the Commission's view, jeopardize 
their right to take advantage of this facility. 
3. Demographic considerations and the possibility 
of the proposed measures being revised 
3.1. A close watch must be kept on population 
trends and their possible consequences on the fund­
ing of social security. 
3.2. The Committee believes that there should be 
freedom to choose a lower — or, within limits, a 
higher — pension age. It feels that this is essential 
because there is likely to be a marked change in the 
age-structure of the population in the Community in 
future years. 
4. Cost of the measure 
4.1. The Committee feels that the costs incurred as 
a result of lowering the retirement age could pose 
further problems. It notes with interest that the 
Commission has already started to prepare studies 
on the funding of social security schemes, and that 
these should soon be completed. The Committee 
feels that the question of a flexible retirement age 
should occupy a prominent position in these 
studies. 
4.2. The funding of social security schemes poses 
serious problems in view of the radical changes in 
the economic situation in the Community as a 
whole and individual Member States. Low growth 
rates (or, in some instances, zero growth) coupled 
with the shaky state of the finances of the bodies 
responsible for funding social security payments put 
a different construction on the question of financing 
social measures. In introducing a flexible retirement 
age, the cost aspect is accordingly a major consider­
ation. 
4.3. Although the cost of lowering the retirement 
age can of course be offset to some degree against 
savings in unemployment benefit, it is difficult to 
assess the scale of these savings. Furthermore, sur­
veys of the effects (measured in terms of the number of jobs vacated) of schemes adopted in individual 
Member States have produced conflicting results 
which are difficult to compare. 
4.4. This being the case, the Committee is of the 
view that a recovery in the growth rate and an 
improvement in the employment situation are the 
main prerequisites for resolving the problems con­
nected with retirement age. 
4.5. The Committee awaits with interest the Com­
mission's promised memorandum on social security 
costs in the Community. 
5. Apart from the costs, there are other aspects of 
these measures which the Committee considers of 
major importance. 
5.1. Small and medium-sized companies are a 
special case, in this respect. If facilities for a flexible 
retirement age come into force, such companies 
could be faced with a serious shortage of skilled per­
sonnel, since older workers with special experience 
and skills are not easily replaced — and this is espe­
cially true in the case of small and medium-sized 
companies. The Committee feels that, provided free­
dom of choice as to training institutions is pre­
served, specially-tailored vocational training would 
make it possible to produce skilled workers who 
could rapidly take over from older workers who 
wanted to retire. 
6. Paid employment taken up after retirement 
6.1. The Committee has often drawn attention to 
the serious repercussions of undeclared work on 
companies — and here again, the hardest hit are the 
small and medium-sized firms. The Committee 
takes the view that particular attention should be 
paid to this point in the context of the draft recom­
mendation. Many of the older workers who might 
apply for early retirement are still healthy and 
active, and it is to be expected that they will not 
want to give up work altogether. The prospects of 
their doing undeclared work are quite high. 
6.2. The Committee also realized, however, that 
workers opting for early retirement should not be 
prohibited from seeking any further employment at 
all. However, any employment taken up after retire­
ment should be subject to stringent restrictions, and 
there should be a certain amount of vetting to 
ensure that there is no abuse of the right to take up 
part-time employment following retirement. 
NoC 178/32 Official Journal of the European Communities 15.7.82 
7. Retirement age 
7.1. The Committee accepts the Commission's 
proposal to refrain for the time being from fixing a 
uniform retirement age. 
7.2. The Committee believes that the question of 
establishing a fixed retirement ago should be dis­
cussed again at a later stage, when Commission 
research has determined what consequences the 
introduction of arrangements for a flexible retire­
ment age are likely to have (number of workers 
expected to take advantage of the scheme, cost, 
impact on employment). The aim should be to fix 
the retirement age at 60. 
7.3. In principle, the Committee agrees that the 
retirement age should be the same for men and 
women but, in this respect too, serious problems are 
posed by existing legislation and collective agree­
ments in the individual Member States. 
8. Phased retirement 
The Committee feels that early retirement and part-
time work for the elderly are two separate issues. 
While it acknowledges the value of temporary 
arrangements for making the transition from work­
ing life to retirement an easier process, the Com­
mittee wishes to point out that it would undoubt­
edly be more effective to deal with this matter in a 
separate context. 
9. Self-employed workers 
The introduction of arrangements for a flexible 
retirement age for self-employed workers is a special 
issue, and the Section feels that it would be pre­
ferable not to discuss it in conjunction with the 
question of a flexible retirement age for employees. 
It can be assumed that those who are self-employed 
are generally free to decide when they will retire. In 
many cases, they will also have made their own 
arrangements concerning a retirement pension and 
will accordingly have been in a position to deter­
mine its size. Their situation is essentially different 
from that of employees, who are required by the law 
to belong to social security schemes and whose 
rights are governed by legislation and — in excep­
tional cases — by collective agreements. 
Done at Brussels, 28 April 1982. 10. Probable effects on employment 
10.1. It has already been mentioned that it is diffi­
cult to determine how and to what extent the intro­
duction of flexible retirement arrangements would 
affect the employment situation, and that — as 
stated in the Report — the results are in dispute. 
10.2. The Committee notes that flexible retirement 
is one of several possible employment policy mea­
sures, and that comprehensive measures are the only 
means of achieving real and sustained improvement 
in the employment situation. 
SPECIFIC COMMENTS 
The Committee approves the Commission's draft 
recommendation, subject to the general remarks and 
the following specific comments: 
1. In the third recital, 'the objective needs and 
wishes of the persons concerned' should be 
amended to read 'the individual needs and wishes of 
the persons concerned'. 
2. A recital should also be added to the effect that 
particular consideration should be given to the 
potential cost of the recommended measure to 
public finances and the social security system. 
3. Page 2, first paragraph. For the reasons outlined 
in the foregoing point 9, delete self-employed work­
ers. 
4. The Committee proposes that, for the reasons 
given in point 8 above, consideration be given to 
whether point 5 (point 2 in the German version) 
should be incorporated in another proposal for a 
Directive to be drawn up. 
5. Point 7 (point 4 in the German version) should 
make it clear that in the event of early retirement, 
paid employment will only be permissible within 
strict limits and, once these limits are exceeded, a 
deduction may if necessary be made from the pen­
sion payment. 
6. Point 8 (point 5 in the German version) should 
be deleted. If conselling services are set up for those 
who are about to retire, they should be available to 
all workers and not merely to those workers who are 
covered by this recommendation. The reference to 
special retirement preparation programmes can also 
be deleted. 
The Chairman 
of the Economic and Social Committee 
Tomas ROSEINGRAVE 
15. 7. 82 Official Journal of the European Communities No C 178/33 
APPENDIX 
to the opinion of the Economic and Social Committee 
The following amendments were rejected during the discussion: 
Page 3, paragraph 2.3. (new) 
A paragraph should be added, reading as follows: 
'Reductions in pension payments should not be made arbitrarily. The Section accordingly takes 
the view that objective measures, such as for instance actuarial calculations, should be used as a 
basis for determining the aforementioned pensions payable in the event of early retirement. It 
must, however, be ensured that, whatever criteria or methods are adopted, they are financially 
just and socially acceptable.' 
Voting 
For: 45, against: 51, abstentions: 4. 
Page 7, paragraph 7.2. 
The last sentence should read as follows: 
"The long-term aim should be to fix the retirement age at 60.' 
Reason 
In view of the difficulty of financing retirement pensions and also the different circumstances 
obtaining in the individual Member States, the lowering of the retirement age to 60 can only be 
achieved in the long term. 
Voting 
For: 32, against: 60, abstentions: 12.