4. 7. 88 Official Journal of the European Communities No C 175/11 
2.3. As regard points 19, 20 and 21, which concern 
mercury compounds, arsenic compounds and organo-
stannic compounds, the major matter of concern is 
clearly the protection of the environment. 
Nonetheless, the use of these substances in industrial 
processes, for example vacuum or pressure processes, 
is to remain authorized, as is their use on boats of over 
25 metres in length. Smaller boats are generally of the 
pleasure boat type which are kept moored to jetties 
for very long periods and which may therefore cause 
localized pollution. 
Selling only in packagings containing at least 20 1 is one 
possible way of ensuring that private users do not break 
these rules, given that these large packagings cost some 
1 000 ECU. 
2.4. With regard to these same points, the Committee 
considers that the very general wording may cause 
problems as regards the 'export notification' procedure, 
since the relevant Regulation stipulates that reference 
Done at Brussels, 27 April 1988. 
The Committee notes with interest the report from the 
Commission on the operation of the rapid information 
exchange system during the 4-year period 1984-1988, 
submitted in accordance with Article 8.2 of the Council 
Decision of 2 March 1984 (84/133/EEC); the Committee be made to the headings used in Directive 76/769/EEC 
and its subsequent amendments. 
One can understand that if the Commission was to use 
more specific terms, this would give rise to considerable 
complications, given the multitude of derived products. 
With regard to these export notification procedures, 
the Commission should therefore systematically take 
into account the restrictions set out in the right-hand 
column of the points in question. 
2.5. Point 22 concerns a new substance which has 
been recently notified to the EC authorities and which 
originates in a non-EC country. 
Provision has been made for an exemption, however, 
since a particular process is involved in which the user 
does not come into contact with the substance, of which 
there are only very slight traces in the finished product. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
also recalls that it issued an Opinion on this subject on 
26 March 198011). 
(!) OJ No C 182, 21. 7. 1980. Opinion on the proposal for a Council Decision amending Decision 84/133/EEC introducing 
a Community system for the rapid exchange of information on dangers arising from the use 
of consumer products 
(88/C 175/06) 
On 6 April 1988, the Council decided, in accordance with Article 235 of the Treaty establishing 
the European Economic Community, to ask the Economic and Social Committee for an 
Opinion on the abovementioned proposal. 
The Section for Protection of the Environment, Public Health and Consumer Affairs, which 
was responsible for the preparatory work, adopted ist Opinion on 5 April 1988, in anticipation 
of the referral by the Council. The rapporteur was Mrs Williams. 
At its 255th plenary session (meeting of 27 April 1988), the Economic and Social Committee 
adopted unanimously the following Opinion. 
No C 175/12 Official Journal of the European Communities 4. 7. 88 
The Committee approves the Commission proposal to Nevertheless, it recommends the expansion and exten-
extend the period of validity of the aforementioned sion of the present system during the forthcoming 
rapid exchange system by a further 6 years. period. 
Done at Brussels, 27 April 1988. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
Opinion on the general safety requirement for products 
(88/C 175/07) 
On 16/17 December 1987 the Economic and Social Committee, acting under the fourth 
paragraph of Article 20 of its rules of procedure, decided to draw up an own-initiative 
Opinion on product safety. 
The Section for Protection of the Environment, Public Health and Consumer Affairs, which 
was responsible for preparing the Committee's work on the subject, adopted its Opinion on 
5 April 1988 in the light of the report by Mrs Williams. 
At its 255th plenary session (meeting of 27 April 1988), the Economic and Social Committee 
adopted unanimously the following Opinion 
1. Introduction 
1.1. The objective 
The objective of this own-initiative Opinion, the autho­
rization for which was unanimously approved by the 
Committee in December 1987, is to urge the Com­
mission to propose legislation on consumer product 
safety. The legislation should make it obligatory for all 
those involved in the manufacture, supply and sale 
of consumer goods to comply with a general safety 
requirement. 
1.1.1. The objective mentioned above is reinforced 
by the two following considerations: 
— the implications for consumers of the completion 
of the internal market in 1992 and the consequences 
for them of the free movement of goods, 
— the implication of Article 100 A, paragraph 3, of 
the Single Act which states that the Commission in 
its proposals 'concerning health, safety, environ­
mental protection and consumer protection will 
take as a base a high level of protection'. In this 
Opinion the Committee interprets this Article to 
refer to both the on-going protection of consumers 
and the need for emergency action, including prod­
uct recall. 1.2. In addition, the Committee also takes into 
account the following points. 
1.2.1. There is a need for a move towards harmon­
ization in face of the growing amount of national 
legislation which differs in scope and content from one 
Member State to another and also a need to remove 
technical barriers to trade, and to dissuade Member 
States from using spurious health and safety standards 
to hinder free trade. 
1.2.2. In this context it is important to note that 
Article 36 of the EC Treaty states that, though barriers 
may be justified to protect the health and safety of 
citizens, they must not 'constitute a means of arbitrary 
discrimination or a disguised restriction on trade 
between Member States'. 
1.2.3. Specific legislation on particular subjects (i.e. 
'vertical' directives) already exists in the Community. 
These vertical Directives are limited in number, and 
though they include safeguard clauses which allow 
Member States to intervene in cases of danger, these 
protective measures apply only to the specific products 
which these Directives cover.