No C 263/34 Official  Journal  of the  European  Communities 17.11.  75 
But in the Federal  Republic  of Germany  at least  and 
probably  in all the  other  Member  States,  many 
institutions  are  already  engaged  on model-building. 
Therefore,  it  should  be  examined  whether 
comparable  results  cannot  be obtained  for less  than 
the 3 940 000 units  of account  proposed  by the 
Commission  by amalgamating  or extending  existing 
systems  models.  Finally,  the collection  of information 
of this  sort  is only  justifiable  if it is made  available  to all interested  parties  at the right  time  and  provides  a 
realistic  aid to decision-making. 
Done  at Brussels,  28 May  1975. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Directive  on the collection,  regeneration  and/or 
destruction  of polychlorinated  biphenyls  (PCB's) 
The text  referred  to the Committee  was  published  in Official  Journal  of the European 
Communities  No  C 49 of 1 March  1975,  page  1. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 21 February  1975,  the  Council  referred  the  abovementioned  proposal  to the 
Economic  and  Social  Committee  under  Article  198  of the  Treaty  establishing  the 
European  Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 130th  plenary  session, 
held in Brussels  on 28 and  29 May  1975. 
The Opinion  is published  below. 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to  the  Treaty  establishing  the 
European  Economic  Community  and,  in particular, 
Article  198  thereof; 
Having  regard  to the  referral  on 24 February  1975 
by the Council  of the European  Communities,  of the 
proposal  for  a Council  Directive  on the  collection, 
regeneration  and/or  destruction  of polychlorinated 
biphenyls  (PCB's); 
Having  regard  to the decision  taken  by its Bureau  on 
25 February  1975  instructing  the  Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  to draw  up an Opinion  and  a 
report  on the matter; 
Having  regard  to the  Opinion  adopted  by  the 
Section  for  Protection  of the  Environment,  Public 
Health  and  Consumer  Affairs  on 13 May  1975  and 
the oral  report  made  by  the  Rapporteur,  Mr 
Jaschick; Having  regard  to the discussions  at its meeting  on 28 
May  1975  (130th  plenary  session  of 28 and  29 May 
1975), 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a unanimous  vote: 
Subject  to the  following  comments,  the  Committee 
approves  the  aims  set  out  in the  Commission's 
proposal. 
1. General  comments 
1.1. The  proposal  lays  down  special  provisions 
dealing  with  particularly  dangerous  wastes,  and 
comes  within  the overall  framework  of the  Council 
Directive  on  waste  disposal.  It is the  necessary 
adjunct  to the  Directive  concerning  restrictions  on 
17.11.  75 Official  Journal  of the European  Communities No C 263/35 
the marketing  and  use  of  certain  dangerous 
substances  and  preparations,  a directive  which,  inter 
alia, relates  to polychlorinated  biphenyls  (PCB's). 
The Committee  is pleased  that  the Commission  has 
acted  on its recommendation  that  the  provisions 
covering  PCB's  should  be supplemented  as soon  as 
possible  (x). 
1.2. The  Committee  considers  that  the  serious 
threats  which  these  substances  pose  for  the 
environment  make  it very  desirable  indeed  to 
implement  as quickly  as possible  the  mandatory 
provisions  covering  their  disposal.  The  Committee 
therefore  suggests  that  the necessary  measures  to be 
taken  by the  Member  States  in pursuance  of the 
present  proposed  Directive  should  at the  latest  be 
published  and  implemented  concurrently  with  the 
Directive  concerning  restrictions  on the  marketing 
and use of PCB's. 
1.3. The  Committee  would  also  draw  attention  to 
the serious  environmental  hazard  which  continues  to 
exist  because  of the  current  absence  of immediately 
applicable  provisions  with  respect  to the  collection 
and treatment  of PCB's. 
1.4. Bearing  this  in mind,  the Committee  wonders 
whether  it is advisable  to limit  the  scope  of the 
present  proposal  by confining  it to very  general 
provisions,  thereby  leaving  it to the  Member  States 
to spell  out  the  details  at national  level.  The 
Committee  believes  that  the  proposal  should  reflect 
more  of a Community  approach,  and  specify  more 
clearly  how  its objectives  are to be achieved. 
1.5. The  Committee  also  considers  it advisable  to 
review  — at the  very  latest  when  a later,  more 
comprehensive  Directive  on the  disposal  of various 
other  particularly  dangerous  wastes  is adopted  — the 
present  Directive  in the  light  of its fifth  recital  in 
order  to discover  to what  extent  its fragmentary 
provisions  should  be  integrated  into  a more 
comprehensive  concept.  The  purpose  here  would  be 
to ensure  that  holders  of dangerous  wastes  do not 
lose sight  of the relevant  provisions  because  they  are 
inundated  by a wave  of specific  solutions  for other 
related  problems. 
1.6. From  a general  point  of view,  the Committee 
would  stress  the advisability  of promoting  the use,  as 
(!) OJ  No C 16, 23. 1. 1975. far as possible,  of substitutes  for PCB's,  particularly 
in the manufacture  of products  (for  example,  small 
condensers)  which  have  proved  very  difficult  to 
collect  and  may  therefore  escape  the  proposed 
provisions. 
1.7. As  regards  the implementation  by Article  5 of 
the 'polluter  pays'  principle,  the  Committee 
approves  the proposed  wording,  especially  in view  of 
the fact  that  it conforms  to the standpoint  expounded 
by the Committee  in its Opinion  on the proposal  for 
a Directive  on the disposal  of waste  oil (2). 
2. Specific  comments 
2.1. Article  1 
2.1.1.  The  Committee  calls  upon  the Commission 
to check  whether  the proposed  Directive  completely 
covers  the entire  PCB  field  and  to ensure  that  there 
are no  other  compounds  which  should  also  be 
covered. 
2.2. Article  3 (2) 
2.2.1.  The  Committee  sees  a certain  contradiction 
between,  on the one  hand,  the provisions  of Article  2, 
which  imply  a general  ban  on  the  uncontrolled 
discharge,  dumping  and  deposit  of objects  containing 
PCB's  and,  on the  other  hand,  an obligation  which 
in certain  language  versions  appears  to cover  only 
recovery  of reutilizable  PCB's  from  equipment. 
2.2.2.  In  order  to avoid  any  element  of uncertainty 
and to ensure  conformity  between  Article  3 and  the 
general  rules  set out  in Article  2, the  Committee 
proposed  that  Article  3 (2) be amended  as follows: 
'The  Member  States  shall  take  the  necessary 
measures  to make  compulsory  the  removal  and 
collection  of  waste  PCB's  and  of  PCB's 
contained  in  equipment  no  longer  in  use, 
whenever  this  is technically  possible'. 
2.3. Article  8 
2.3.1.  The  Committee  suggests  that,  for  the 
reasons  given  in the  general  comments,  this  Article 
should  be amended  to read: 
'The  Member  States  shall  bring  into  force  the 
measures  necessary  to comply  with  this  Directive, 
not later  than  1 October  1976,  and  shall 
(2) OJ  No C 125,  16. 10. 1974. 
No C 263/36 Official  Journal  of the European  Communities 17.11.75 
forthwith  inform  the Commission  thereof'. 
2.4. Article  9 
2.4.1.  Article  9 states  that  the Member  States  are 
to inform  the  Commission  of all proposed  laws, 
regulations  and  administrative  provisions  in the 
relevant  field.  The  Committee  would  stress  that  the 
purpose  of  this  stipulation  is  to  allow  the Commission  to act  to prevent  disparities  between 
such  proposals. 
Done  at Brussels,  28 May  1975. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Decision  establishing  a common  procedure  for 
the preparation  and  constant  updating  of a European  inventory  of sources  of 
information  on the environment 
The text  referred  to the Committee  was  published  in Official  Journal  of the European 
Communities  No  C 134  of 16 Tune  1975,  page  114. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 17 March  1975,  the Council  referred  the abovementioned  proposal  to the Economic 
and Social  Committee  under  Article  198  of the  Treaty  establishing  the  European 
Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 130th  plenary  session, 
held in Brussels  on 28 and  29 May  1975. 
The Opinion  is published  below. 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to  the  Treaty  establishing  the 
European  Economic  Community,  and  in particular 
Article  198  thereof; 
Having  regard  to the referral  on 20 March  1975,  by 
the Council  of the  European  Communities,  of the 
proposal  for  a Council  Decision  establishing  a 
common  procedure  for the preparation  and  constant 
updating  of a European  inventory  of sources  of 
information  on the environment; 
Having  regard  to the decision  taken  by the Bureau  of 
the Economic  and  Social  Committee  on 18 March 
1975  in anticipation  of  an  imminent  referral, 
instructing  the  Section  for  Protection  of  the 
Environment,  Public  Health  and  Consumer  Affairs  to 
draw  up an Opinion  and  a report  on the matter; 
Having  regard  to the  Opinion  adopted  by  the 
Section  for  Protection  of the  Environment,  Public Health  and  Consumer  Affairs  to draw  up  an 
Opinion  and  a report  on the matter; 
Having  regard  to the  Opinion  adopted  by  the 
Section  for  Protection  of the  Environment,  Public 
Health  and  Consumer  Affairs  at its meeting  on 13 
May  1975; 
Having  regard  to the discussions  at its meeting  on 28 
May  1975  (130th  plenary  session  of 28 and  29 May 
1975), 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a unanimous  vote: 
The Economic  and  Social  Committee  approves  the 
proposal,  subject  to the following  comments. 
1. The  Committee  applauds  this  initiative  of the 
Commission,  which  is taken  under  the  European 
Communities  programme  of  action  on  the