COMMISSION OF THE EUROPEAN COMMUNITIES 
C0M(91) 104 fina 
Brussels, 11 ApriI 1991 
Proposal for a 
COUNCIL REGULATION (EEC) 
on financial and technical assistance to 
and economic cooperation with the developing 
countries in Asia and Latin America 
(presented by the Commission) 
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EXPLANATORY MEMORANDUM 
1. There are two main channels of cooperation between the Community and the 
developing countries in Asia and Latin America: 
(i) financial and technical assistance, and 
(ii) economic cooperation. 
Financial and technical assistance, which began in 1976, is the main 
instrument of development cooperation. The objectives of such aid and 
the rules for its administration are at present governed by Council 
Regulation (EEC) No 442/81. 
Economic cooperation, which was introduced more recently, comprises a 
number of different instruments (promotion of exports and European 
investments, training, cooperation in the fields of industry, energy, 
science and technology). It is relatively heterogeneous, involves 
rather small sums and, so far, has not been governed by legislation. 
2. In view of the profound changes which the developing countries concerned 
and the Community itself have undergone since such cooperation began, 
the Council and Parliament have asked the Commission to propose new 
long-term guidelines for adapting Community policy to the new situation 
and increasing its effectiveness. 
3. In June 1990 the Commission produced such a paper, 1 on the basis of 
which, in December 1990, the Council adopted conclusions on the general 
guidelines for Community cooperation with the developing countries in 
Asia and Latin America (ALA) over the next decade. 
In the light of these conclusions and in response to Parliament's desire 
that the legal basis of Community cooperation be adjusted in line with 
the new situation and so as to make such cooperation more effective and 
more transparent, the Commission undertook to present a new Regulation 
on cooperation policy. 
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4. This new Regulation has been drafted so as to enable all financial and 
technical assistance and economic cooperation to take place within the 
guidelines proposed by the Commission.1 
In short, the new guidelines cover the following: 
4.1 Greater attention to the question of human rights and democracy. 
The aim of cooperation is human development. Accordingly, its 
implementation requires the participation of both women and men. 
Furthermore, respect for human rights is recognized as fundamental 
to genuine development, in which cooperation itself is seen as 
contributing to the promotion of such rights. 
With this in view, development policy and cooperation take into 
consideration respect for, and enjoyment of, fundamental human 
rights and freedoms and democratic principles. Accordingly, 
increased Community support should be provided for those countries 
which are most committed to those principles and in particular for 
practical initiatives taken to apply such principles in those 
countries. Where human rights are violated and democratic 
principles not respected, the Community may alter its cooperation 
strategy by limiting cooperation to only those schemes which 
directly benefit needy sections of the population. 
4.2 The need to ensure that environmental considerations are 
systematically taken into account in all aid and cooperation schemes 
and that a significant proportion - not less than 10% - of total 
resources is set aside to finance specific projects in the field of 
environmental protection. 
Cooperation on the environment with the ALA developing countries is 
essential since problems which relate specifically to the developing 
countries (such as the protection of tropical rainforests) are 
matters of global concern, and since these countries clearly need 
technical support in handling problems relating to both the natural 
and the urban and industrial environment. 
1 C0M(90)176 final, 11.06.1990. 
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4.3 Financial and technical assistance must not only be continued and 
strengthened but also be better adapted to national and local needs. 
This form of aid must continue as in the past to be directed 
primarily at improving the living conditions of the least-favoured 
strata of society in the poorest countries, but may be extended, in 
some cases, to the relatively more advanced countries. 
Financial and technical assistance constitutes the main instrument 
of Community development aid, which also includes food aid, the 
export earnings stabilization mechanism, opportunities for 
co-financing operations undertaken by European NGOs and various 
types of emergency and humanitarian aid, which should be coordinated 
and, where necessary, combined. 
In general, development aid is the expression of the Community's 
support for the ALA developing countries, which face serious 
problems (population growth, mass poverty, financial and 
environmental difficulties), for which they alone cannot muster all 
the necessary resources and know-how. 
Within the range of development instruments, financial and technical 
assistance aims to transfer funds and to target know-how on specific 
operations (projects or programmes of a variety of types) with a 
view to solving general or sectoral problems or undertaking pilot 
schemes aimed at developing new strategies. 
Financial and technical assistance continues to give priority to the 
rural sector since most of the population in the ALA developing 
countries belongs to this sector and the Community has solid 
experience in such matters. 
Consideration must also be given to other fields of action such as 
regional cooperation, the structural dimension of development, 
natural disasters, etc. When schemes are drawn up, particular 
attention must be given to aspects such as the role of women, 
problems relating to population growth, the fight against drugs, 
etc. 
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4.4 Substantially reinforced, well structured and efficient economic 
cooperation must be the second channel of cooperation with the ALA 
developing countries. 
The fact is that cooperation with these countries, and particularly 
the more advanced of them, cannot be limited to aid but must help 
them make the most of the prospects opened up by the growth of 
international trade, and in particular by the European single 
market. 
At the same time it must help European businessmen, technology and 
know-how to play an increasingly active part in these countries, 
thereby enabling the Community to benefit in the medium and long 
term from the economic and commercial, technological and cultural 
expansion of these high-potential countries. Finally, it will act 
as a catalyst to promote the transfer of European businessmen's 
resources (capital, technology, know-how and marketing networks) 
under market conditions to the ALA developing countries. 
Of necessity, economic cooperation makes use of a wide range of 
instruments, some of which are covered by separate legislation, 
either because of their links with other Community policies 
(research, energy, telecommunications) or because of their specific, 
horizontal nature (EC— MP). 
The purpose of this latter instrument is more particularly to enable 
the Community to promote joint ventures, thus helping to promote 
European investment in the ALA developing countries, which is one of 
the desired results of economic cooperation. 
All these instruments of economic cooperation must be integrated and 
coordinated with financial and technical assistance. Economic 
cooperation may also be directed towards promoting regional 
coopérât ion. 
4.5 In view of the new aid components described above and the May 1990 
revision of financial perspectives, the budgetary resources for aid 
and cooperation have been increased. 
This increase will be made within the framework of a five-year 
perspective for 1991-95 for the whole range of resources entered in 
the Budget under the heading of cooperation with the Asian and Latin 
American developing countries (Chapter B7-30) in order to enable 
indicative medium-term planning for aid and cooperation to be 
undertaken. The relevant indicative figures are shown in the 
attached financial statement. 
5. This renewal of Community cooperation policy means that its implementing 
procedures must be adjusted. 
5.1 Increasing dialogue is the means whereby the priorities for 
Community 'backing for each country can be established. This 
dialogue will principally take place in the Joint Committees for ALA 
developing countries which have Coopérât ion Agreements with the 
Community, and it primarily concerns the general guidelines, and the 
objectives and priorities, notably sectoral, to which aid and 
cooperation could contribute. It will be based on the assessment of 
each country's specific needs and the identification of all types of 
cooperation schemes most suitable for financing. 
5.2 Wherever possible, thanks to the multiannual financial framework for 
Community cooperation with the ALA developing countries, multiannual 
programming on the basis of objectives will be undertaken for each 
country and where appropriate by region. This programming - which 
will be of an indicative nature - is to help increase the impact of 
Community operations on the general policies of the countries 
concerned. It will take account of the possible contribution of 
other aid and cooperation instruments. 
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5.3 Resources will be allocated and schemes chosen for financial and 
technical cooperation by reference to: 
- the income levels and needs of the various countries; 
- the intrinsic value of operations in terms of development and 
their contribution to healthy, realistic macroeconomic policies; 
- the possibility of arousing the country's interest and/or 
mobilizing additional resources to assist certain sectors; 
- participation by the local population. 
For economic cooperation, schemes will be identified and chosen by 
reference to the initiatives and interests of the operators directly 
concerned. 
5.4 Community assistance will cover individual operations, clearly 
defined in terms of objectives to be attained and means to be 
deployed, notably projects and programmes and including, wherever 
feasible, integrated projects and sectoral programmes. 
5.5 All instruments of Community cooperation, whether in the form of 
financial and technical assistance or economic cooperation or other 
types of cooperation, should be carefully integrated so that they 
work together with maximum efficiency. Integration should be sought 
not only in overall planning of cooperation on a country-by-country 
basis but also when each project or programme is prepared. 
Integration of instruments particularly applies to food aid and Stabex 
counterpart funds. 
As much benefit as possible should also be drawn from the experience 
of European NGOs, notably in connection with the numerous projects 
co-financed with the Community. 
5.6 Coordination with other aid instruments should also be stepped up, 
particularly with the bilateral aid provided by the Member States; 
this would, furthermore, reinforce the European presence. 
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Co-financing is the closest possible form of coordination and thus 
deserves particular attention but at the same time the 
decision-making process and execution need to be made much less slow 
and cumbersome - the result of the number of decision-makers and the 
particular rules governing each of them. 
6. In view of these guidelines, the implementation of this renewed 
Community cooperation policy involves a substantial revision of 
existing legislation. 
This legislation must therefore be adapted to take account of the new 
priorities for financial and technical cooperation and must be 
supplemented by new administrative rules and provisions which, for the 
first time, will govern economic cooperation in respect of all those 
instruments which have no separate legal basis. 
7. Accordingly, the Commission hereby presents to the Council and the 
Parliament, for adoption as soon as possible, the attached proposal 
for a new Regulation to replace Regulation (EEC) No 442/81 in respect 
of financial and technical cooperation and to extend the scope to 
economic cooperation. 
Proposal for a 
COUNCIL REGULATION (EEC) 
on financial and technical assistance to 
and economic cooperation with the developing 
countries in Asia and Latin America 
THE COUNCIL OF THE EUROPEAN COMMUNITIES, 
Having regard to the Treaty establishing the European Economic Community, 
and in particular Article 235 thereof, 
Having regard to the proposals from the Commission, 
Having regard to the opinion of the European Parliament, 
Whereas, since 1976, the Community has been pursuing a policy of financial 
and technical cooperation with the developing countries in Asia and 
Latin America and has, in more recent times, also embarked on economic 
cooperation with those countries; whereas these forms of cooperation are 
part of an overall policy of cooperation with the developing countries as a 
whole which includes expansion of their trade by integration into the 
multilateral trade system, by appropriate measures to be taken within the 
relevant international organizations and by specific measures such as the 
Community system of generalized preferences; 
Whereas the current process of European construction and the growing 
influence of the Community worldwide justify the continuation of mutually 
advantageous economic cooperation with, and Community development aid to, 
the developing countries in Asia and Latin America, the extension of such 
policies to other countries or economic sectors, increased financing for 
such policies and efforts to ensure that they are better adapted to 
national and local needs within each region; 
Whereas the European Council has on a number of occasions confirmed the 
Community's political will to reinforce its cooperation with regions of the 
world where the level of development is still insufficient and to do so via 
an increased, coordinated and multi-faceted effort on the part of the 
Community and its Member States; 
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Whereas the European Parliament has examined the matter in detail on a 
number of occasions and has called for such reinforced cooperation and for 
a revision of present legislation in order to ensure greater efficiency and 
increased transparency; 
Whereas the Council has adopted conclusions supporting the Commission's 
suggested long-term guidelines for such cooperation with regard to the 
priorities and sectors for consideration and the desirability of increasing 
the resources to be allocated to them and of enabling indicative 
medium-term programming for those resources to be undertaken; 
Whereas both the Council and European Parliament, while confirming 
traditional fields of action, have identified new priorities relating, in 
particular, to the environment, the human dimension of development and the 
need for economic cooperation to take place in the mutual interest of the 
Community and its partner countries; 
Whereas the rules governing the administration of financial and technical 
assistance to, and economic cooperation with, the Asian and Latin American 
developing countries should be established; 
Whereas it is therefore necessary to repeal Council Regulation (EEC) 
No 442/81 of 17 February 1981 on financial and technical aid to non-
associated developing countries,1 and to replace it with this Regulation; 
Whereas the Treaty does not provide specific powers of action for the 
adoption of this Regulation other than those contained in Article 235, 
HAS ADOPTED THIS REGULATION: 
Article 1 
The Community shall continue and broaden Community cooperation with the 
developing countries in Asia and Latin America, not being signatories to 
the Lomé Convention and not benefiting from the Community's policy of 
cooperation with the Mediterranean region, hereinafter referred to as "ALA 
developing countries". This cooperation shall involve financial and 
1 OJ No L 48, 21.2.1981, p. 8. 
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technical development assistance and economic cooperation. In this 
connection the Community attaches the utmost importance to promoting human 
rights, freedom of trade and of cultural exchanges and environmental 
protection, by means of an increasing dialogue on political, economic and 
social issues within a perspective of mutual interest. 
Article 2 
All the ALA developing countries shall be eligible for financial and 
technical assistance and economic cooperation. 
The recipients of aid and partners in cooperation can include not only 
States and regions but decentralized authorities, public agencies, local or 
traditional communities, private institutes and operators, including 
cooperatives and non-governmental organizations. 
Financial and Technical Assistance 
Article 3 
The principal aim of financial and technical assistance shall be to improve 
the living standards of the neediest sections of the population and to 
implement measures in areas where domestic resources are hard to mobilize 
but which are of strategic importance either for the development of the 
countries concerned or for the international community as a whole. 
It shall be targeted primarily on the poorest ALA developing countries. 
Article 4 
Financial and technical assistance shall give priority to developing the 
rural sector and improving the level of food security. 
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Furthermore, consideration shall be given in all operations to protecting 
the environment and natural resources, to the human dimension of 
development, notably the role of women, to the problems of population 
growth and to matters concerning the relations between towns and the 
countryside. 
A significant proportion of the aid shall be set aside for projects more 
specifically aimed at environmental protection. 
Aid may also take the form of action to fight drugs, to improve living 
conditions in large cities, and to contribute to the structural dimension 
of development. 
Part of the aid may be used for rehabilitation and reconstruction following 
disasters of all kinds and for preventive measures. 
Regional cooperation among developing countries shall be considered an 
important area for financial and technical cooperation, particularly in the 
fol lowing fields: 
- cooperation on the environment; 
- the development of intra-regional trade; 
- the strengthening of regional institutions; 
- support for integration and the establishment of joint policies and 
activities among developing countries; 
- communications, particularly as regards standards, networks and 
services, including telecommunications; 
- research and training connected with development; 
- cooperation in the sphere of energy. 
Article 5 
Financial and technical assistance may be extended to the relatively more 
advanced countries of Asia and Latin America in specific fields or in cases 
where Community action is taken in response to disasters or implements new 
operations or policies which are essential at regional or international 
level in the following sectors: 
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drugs; 
the environment and natural resources; 
the strengthening of institutions; 
pilot schemes to help particularly under-privileged sections of the 
population; 
regional cooperation. 
E conom i c Coope ration 
Article 6 
Economic cooperation shall contribute to the development of the ALA 
developing countries by helping them make the most of the prospects opened 
up by the growth of international trade and by the European single market, 
and by enhancing the role of European businessmen, technology and know-how. 
Economic cooperation shall be aimed in particular to supporting countries 
pursuing macroeconomic and sectoral policies open to trade and investment 
and conducive to technology transfers, notably by ensuring the protection 
of industrial and intellectual property rights. 
Article 7 
Economic cooperation shall include three sectors: 
1. Improvement of scientific and technological potential and of the 
economic, social and cultural environment in general by means of 
training schemes and the transfer of know-how. It shall be directed 
chiefly at executives, economic decision-makers and instructors, and 
shall cover all economic, scientific and technical fields and, in 
particular energy, industrial and urban ecology and services technology. 
2. Improvement of the institutional structure, in order to render the 
legislative, administrative and social climate more conducive to 
development. 
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3. Support for undertakings, for example by means of training and technical 
assistance schemes, by the establishment of direct contacts between 
undertakings and by schemes to facilitate access to bigger markets 
without prejudice to the specific provisions on joint ventures laid down 
by Council Regulation (EEC) No ... [on EC 11P].* 
Regional cooperation must be regarded as an important sector for economic 
cooperation, in particular: 
- cooperation on industrial and urban ecology; 
- intra-regional trade; 
- regional institutions for economic integration; 
- regional policies; 
- communications, including telecommunications; 
- research and training; 
- cooperation in the sphere of energy. 
IMPLEMENTING PROCEDURES 
Article 8 
Financial and technical assistance and economic cooperation shall be 
provided mainly in the form of grants and shall draw on the financial 
resources fixed by the general budget of the European Communities. 
Co-financing with the Member States or other donors shall be sought through 
greater coordination. The Community nature of the aid must, however, be 
maintained as far as possible. 
Article 9 
1. Financial and technical assistance may cover all the expenditure on 
imports and local expenditure required to carry out projects and 
programmes. 
* OJ No L 
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Maintenance and operating expenses for economic cooperation operations, 
training and research programmes and for development projects and 
programmes may be covered subject to the proviso that in the case of the 
latter such expenses may be covered only at the launching stage and in 
decreasing amounts. 
2. Systematic efforts must be made to seek financial contributions from 
partners (countries, local communities, undertakings, individual 
recipients) within the limits of their possibilities and according to the 
nature of each operation. Taxes and duties and the purchase price of land 
shall be excluded from Community financing. 
3. Study costs and the short and long-term use of experts to assist the 
recipients and the Commission in devising general policies, identifying and 
preparing operations, and monitoring and evaluating them shall normally be 
covered by Community resources, either as part of the financing for 
individual operations or separately. 
Article 10 
Participation in invitations to tender and purchasing and other contracts 
shall be open on equal terms to all natural or legal persons of the 
Member States. 
With regard to financial and technical assistance, such participation shall 
usually be extended to the recipient State and may also be extended, case 
by case, to other developing countries. 
In exceptional cases which are duly justified, other countries of origin 
may be allowed for specific components. 
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Article 11 
1. Aid projects and programmes for which Community funding exceeds 
ECU 2 million and also any substantial modifications and necessary overruns 
of more than 20% of the amount initially agreed for these operations shall 
be adopted according to the procedure laid down in Article 12(2). 
2. The procedure laid down in Article 12(3) shall be followed, if need be, 
for the adoption of acts required to establish: 
- coordination between Community cooperation schemes and bilateral schemes 
that may be undertaken by the Member States, 
- the indicative multiannual guidelines that apply to the main partner 
countries, 
- the areas of cooperation according to subject or sector. 
Article 12 
1. The Commission shall be assisted by a committee composed of the 
representatives of the Member States and chaired by the representative of 
the Commission. 
2. The representative of the Commission shall submit to the committee a 
draft of the measures to be taken. The committee shall deliver its opinion 
on the draft within a time limit which the chairman may lay down according 
to the urgency of the matter. The opinion shall be delivered by the 
majority laid down in Article 148(2) of the Treaty in the case of decisions 
which the Council is required to adopt on a proposal from the Commission. 
The votes of the representatives of the Member States within the committee 
shall be weighted in the manner set out in that Article. The chairman 
shalI not vote. 
The Commission shall adopt measures which shall apply immediately. 
However, if these measures are not in accordance with the opinion of the 
committee, they shall be communicated by the Commission to the Council 
forthwith. In that event, the Commission may defer application of the 
measures which it has decided for a period of one month. 
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The Council, acting by a qualified majority, may take a different decision 
within the time limit referred to in the second subparagraph. 
3. The representative of the Commission shall submit to the committee a 
draft of the measures to be taken. The committee shall deliver its opinion 
on the draft within a time limit which the chairman may lay down according 
to the urgency of the matter, if necessary by taking a vote. 
The opinion shall be recorded in the minutes; in addition, each Member 
State shall have the right to ask to have its position recorded in the 
minutes. 
The Commission shall take the utmost account of the opinion delivered by 
the committee. It shall inform the committee of the manner in which its 
opinion has been taken into account. 
Article 13 
The Commission shall submit to the Council and the European Parliament an 
annual report on the implementation of this Regulation, setting out the 
results achieved and presenting the projects and programmes financed during 
the year. 
In addition, a comprehensive report giving the results of the regular 
evaluation undertaken shall be presented at the end of each five-year 
per iod. 
Article 14 
Regulation (EEC) No 442/81 is hereby repealed. 
Any reference to that Regulation shall be deemed to be a reference to this 
Régulât ion. 
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Article 15 
This Regulation shall enter into force on the third day following that of 
its publication in the Official Journal of the European Communities. 
This Regulation shall be binding in its entirety and directly applicable in 
a 11 Member States. 
Done at Brussels, For the Counci 
The President 
O. I OUUVOnuwii « • ww » 
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FICHE FINANCIERE 
IMPLICATIONS FINANCIERES 
1. Intitulé de l'action 
Projet de règlement relatif à la mise en oeuvre de l'aide technique 
et financière et coopération économique avec les pays en voie de 
développement d'Amérique Latine et d'Asie. 
2. Lignes budgétaires concernées 
B.7. 3000 - 3001 - 3002 - 3003 
B.7. 3010 - 3011 - 3012 - 3013 
B.8. 7300 - 7301 et 7304 
B.8. 7310 - 7311 et 7314 3004 
3014 
Base légale 
Article 235 du Traité 
Description de l'action 
4.1 Objectifs spécifiques de l'action 
Accroissement 
développement 
l'objectif de 
champ d'appli de l'effort de l'aide communautaire au 
notamment dans les PVD-ALA les plus pauvres dans 
répondre à une demande pressante d'extension du 
cation de cette forme d'aide (protection de 
l'environnement, dimension humaine du développement, coopération 
régionale, dimension structurelle du développement, catastrophes 
naturel les, etc ...). 
Renforcement et diversification de la coopération économique 
afin d'accélérer, essentiellement dans les PVD les plus avancés, 
le développement par un transfert de "Know-How" européen dans un 
esprit de bénéfices mutuels afin que ces pays puissent tirer 
avantage de perspectives nouvelles ouvertes par le grand marché 
européen. 
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4.2 Durée 
Indéterminée 
4.3 Population visée par l'action 
Les populations de tous les pays d'Amérique Latine et d'Asie, 
soit plus de 3.500 millions de personnes dans 41 pays - et en 
particulier les couches de population les plus défavorisées dans 
les pays les plus pauvres. 
5. Classification de la dépense ou des recettes 
5.1 D.N.O. 
5.2 CD sauf B 7 3002 et B7 3012 et les lignes "minibudget" qui sont 
CND 
5.3 Ce règlement n'engendre pas de recettes spécifiques. 
6. Nature de la dépense 
6.1 Subvention à 100 % : oui sauf co-financement au titre de 
l'article 16 du règlement 
6.2 Dans certains cas, subvention par co-financement avec d'autres 
donateurs d'aide 
6.3 Aucune bonification d'intérêt 
6.4 Autres : r ien 
6.5 Pas de remboursement prévu 
6.6 Pas de recettes 
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7. Incidence financière sur les crédits d'intervention (partie B du 
budget) 
7.1 Mode de calcul 
La dotation anuuelle sera fixée par l'autorité budgétaire. La 
Commission, dans son document COM (90) 176 a proposé pour la 
période 1991 - 1995 un montant global au prix de 1991 de 
2.900 MECU. Il s'agit d'un montant indicatif(1). 
7.2 La part du mini-budget 
Cette part se situe entre 2,5 % et 3 % 
7.3 Echéancier indicatif des crédits d'engagements et de paiements 
Sur l'ensemble des lignes citées en 1.2, l'échéancier estimatif 
se présente à ce stade de la façon suivante : 
1991 1992 1993* 1994* 1995* 
Crédits engagements 428 518 537 558 588 
Crédits de paiements 293 329 390 470 540 
(*) Prix 1992. Sous réserve des résultats d'une reconduction 
éventuelle de la perspective financière dans le cadre de 
raccord inter-institutionnel sur la discipline budgétaire. 
8. Dispositions anti-fraude prévues dans la proposition. 
Il s'agit de dépenses essentiellement mises en oeuvre par les pays 
tiers et par la Commission qui exerce sur la totalité des dépenses 
son contrôle normal. 
(1) réparti comme suit : 
Chapitre B7-30 crédits pour engagements en m.écus 
1991 1992 1993 1994 1995 
448 580 600 620 652 
A noter que le Conseil pour sa part a accepté le 18 décembre 1990 un 
montant global de 2.750 m.écus. 
- 22 -
FICHE D'IMPACT DE CERTAINS ACTES LEGISLATIFS SUR LES PME ET L'EMPLOI 
1. OBLIGATIONS ADMINISTRATIVES DECOULANT DE L'APPLICATION DE LA 
LEGISLATION POUR LES ENTREPRISES 
AUCUNE 
2. AVANTAGE POUR L'ENTREPRISE 
OUI 
LESQUELLES 
La coopération au développement pourra engendrer des avantages 
pour les PME dans les domaines services et fournitures de 
mater iel. 
3. INCONVENIENTS POUR L'ENTREPRISE 
NON 
CONSEQUENCES 
4. EFFETS SUR L'EMPLOI 
Aucun effet négatif prévisible sur l'emploi dans la Communauté 
5. A-T-IL EU CONCERTATION PREALABLE AVEC LES PARTENAIRES SOCIAUX ? 
NON 
AVIS DES PARTENAIRES SOCIAUX 
6. Y A-T-IL UNE APPROCHE ALTERNATIVE MOINS CONTRAIGNANTE ? 
NON 
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