8. 8. 88 Official Journal of the European Communities No C 208/7 
2.2. Annex I, Part 11 
The Commission is asked to estimate how many 
storage sites are to be affected by the provisions 
contained in Annex I, Part II, and in particular the 
threshold quantities proposed in item 2. 
This may show that the classification categories 
and/or the threshold quantities need to be adjusted, 
if they are to allow the relevant authorities to moni­
tor effectively the safety of truly dangerous storage 
Done at Brussels, 2 June 1988. 
1. General remarks 
1.1. The Committee believes that it is self-evident 
and an accepted fact that emissions from motor vehicles 
have been and continue to be a cause for concern in 
environmental-protection terms: it accepts this basic 
fact and addresses itself to the details of implementation 
within the proposed amending Directive. 
1.2. The Luxembourg agreement of June 1985 laid 
down the basic principles of the future exhaust emission sites and to ensure that the burden shouldered by 
businesses is commensurate with the danger posed. 
Point 4, third line 
Correct 'item 2' to read 'item 3'. 
2.3. Annex U (Annex VU) 
The Commission is advised to review and specify 
more clearly the information and data required, 
with a view to ensuring that this information is 
practical and unambiguous. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
limitation requirements for motor vehicles in the Euro­
pean Community. The EEC Directive 88/76/EEC(2) is 
the result of that agreement, accepted by Council on 
3 December 1987. 
1.3. Council Directive 88/76/EEC (amending the 
Directive 70/220/EEC) makes it clear that petrol and 
diesel engined vehicles are included in the measures, 
with the exception of agricultural tractors and machin­
ery and of public work vehicles, but including military 
vehicles of less than 1,4 litres. Opinion on the proposal for a Council Directive amending Directive 70/220/EEC on the 
approximation of the laws of Member States relating to measures to be taken against air 
pollution by gases from the engines of motor vehicles — European emission standard for 
cars below 1,4 litres (l) 
(88/C 208/04) 
On 26 February 1988 the Council decided, in accordance with Article 100A of the Treaty 
establishing the European Economic Community, to consult the Economic and Social Com­
mittee on the abovementioned proposal. 
The Section for Industry, Commerce, Crafts and Services was instructed to prepare the work 
on this topic and adopted its Opinion on 4 May 1988 on the report by Mr Pearson. 
The Economic and Social Committee, at its 256th plenary session, meeting on 2 June 1988, 
adopted the following Opinion by 86 votes to 10 with 11 abstentions (vote recorded). 
(!) OJ No C 56, 27. 2. 1988, p. 9. (2) OJ No L 36, 9. 2. 1988, p. 1. 
No C 208/8 Official Journal of the European Communities 8. 8. 88 
1.4. The Luxembourg agreement is undoubtedly an 
important milestone towards the improvement of the 
environment with the setting of the level of permissible 
exhaust emissions. Nevertheless the Committee thinks 
that the stages and the targets set are perhaps not as 
ambitious as they might have been. There has been 
continued progress towards less harmful emissions—on 
average an amending Directive every three years—and 
this progress has to be maintained although it must 
also be recalled that the agreement in Luxembourg 
clearly states that '... to the maximum extent possible 
the European standards should be achievable at reason­
able cost and by different technical means'. 
1.5. The Committee notes that the Council has 
recently adopted exhaust emission limits for motor 
vehicles in excess of 1,4 litres and has taken account of 
the Committee Opinion 965/86(1) therein. 
1.6. The current proposal therefore deals with small 
cars of less than 1,4 litres. Bearing in mind how they 
are owned and the pattern of their use, this category 
of vehicle is estimated to be responsible for 45% of 
NO emissions from the European car pare. This contri­
bution will soon rise to 60% of those NOx emissions 
unless action is taken. The stated Commission aim is 
to reduce the exhaust emissions from all vehicles by 
54% in 1992/1993 compared to the present legal level: 
it should nevertheless also, as a further step, as quickly 
as possible prepare proposals to bring limit values into 
conformity with the more stringent values already being 
applied in certain countries. 
1.7. The European motor industry has awaited the 
setting by Council of the new permissible standard in 
order to proceed with the necessary production require­
ments and the Commission proposal is seen as being 
a further step in the right direction. It is considered 
disappointing that there has been delay even to achieve 
the current situation, as there are higher standards 
already in practice in some other European countries. 
Nevertheless the Committee believes that current inten­
sive research and development programmes will bring 
about further technical progress in the field of engine 
emission controls and will confirm the feasibility of 
meeting more ambitious goals. These programmes 
should be given priority for evaluation in line with the 
fourth environment action programme and indepen­
dently from the 1992/1993 deadline. 
(J) OJ No C 333, 29. 12. 1986, p. 17. 
Done at Brussels, 2 June 1988. 1.8. The Luxembourg agreement recognizes three 
categories of motor cars: small, medium and large. The 
Committee insists that these categories are maintained 
by the European Community so that a unified, ordered 
approach can be maintained. 
1.9. Subject to the aforegoing reservations the Com­
mittee agrees that the proposed amending Directive 
should be accepted. It reiterates however that the setting 
of limits for 1992/1993 should not deter continued 
progress towards the reduction of harmful exhaust 
emissions from motor vehicles. 
2. Specific remarks 
2.1. The Committee recognizes that the emission 
levels set for the manufacturer apply at the point of 
sale. The Member States have to be increasingly vigilant 
to see that the operating levels are adhered to: cars 
should not be modified to circumvent the regulation 
and regular inspection of satisfactory engine exhaust 
emission controls should be included in the regular 
safety checks; also a uniform procedure for these inspec­
tions should be applied which covers amongst other 
things, the different performances relevant to kilo­
metres travelled. 
2.2. The methods open to the manufacturers include 
the lean-burn engine or a combination of various cata­
lyst systems (with or without the lean-burn engine). 
There is some concern that even conventional engines 
are becoming so complicated that servicing costs are 
reaching a level at which less than a proper minimum 
maintenance is being carried out by owners. Training 
and updating training of motor vehicle technicians need 
to keep pace with new and changing conditions. 
The lack of availability of lead-free petrol in the periph­
eral areas of the Community causes a problem for cars 
fitted with a catalyst. These are areas, very often, with 
a tourist trade; Member States—in accordance with 
Directive 85/210/EEC(2)—should see that not only are­
as of high density have lead-free petrol available with­
out delay. The correct octane level of petrol and cetane 
level of diesel fuels must also be available for those cars 
meeting the new regulations, be they large or small 
vehicles. Likewise the quality of commercial fuels must 
match the quality of the reference fuels. 
(2) OJ No L 96, 3. 4. 1975, p. 25. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
8. 8. 88 Official Journal of the European Communities No C 208/9 
APPENDIX 1 
to the Opinion of the Economic and Social Committee 
The following members, present or represented, voted in favour of the Opinion: 
Mr/Mrs/Miss: Arena, Arets, Bagliano, Beltrami, Bleser, Breyiannis, Briganti, Cal, Campbell, Carroll, Cavaz-
zuti, Ceyrac, Christie, Gavel, Collas, Alves-Conde, Coyle, Curlis, van Dam, Dassis, Delhomenie, Delia Croce, 
Dodd, Donck, Dos Santos, Droulin, Forgas, Frandi, Fresi, Gardner, Gayetot, Glesener, Gomez-Martinez, 
Green, Hammond, Hancock, Jenkins, Kenna, Kirchfield, Kitsios, Kroger, Laka-Martin, Lancastre, Laur, 
Low, Machado Von Tschusi, Mainetti, Magalef-Masia, Masprone, Moreland, Morselli, Mourgues, Muniz-
Guardado, Murphy, Neto Da Silva, Noordwal, de Normann, Orsi, Pardon, Pearson, Pelletier, Perrin-Pelletier, 
Petropoulos, Poeton, Polyzos, Proenca, Pronk, Proumens, Riera-Marsa, Robinson, Rolao Goncalves, Rouzier, 
Salmon, Santillan-Cabeza, Schade-Poulsen, Schopges, Silva, Spijkers, Stadelin, Tamlin, Vallejo-Calderon, 
Vanden Broucke, Velasco-Mancebo, Vercellino, Wagner, Wick. 
The following members, present or represented, voted against the Opinion: 
Mr/Mrs/Miss: Ataide-Ferreira, Flum, Gredal, Haas, Hilkens, Jaschick, Larsen, Muhr, Rangoni-Machiavelli, 
Williams. 
The following members, present or represented, abstained: 
Mr/Mrs/Miss: Aspinall, Burnel, Eulen, Geuenich, Horsken, Kazazis, Nielsen B., Nielsen P., Schmitz, Solari, 
Zufiaur-Narvaiza. 
APPENDIX 2 
to the Opinion of the Economic and Social Committee 
The following amendment, based on the Section Opinion and tabled in accordance with the Rules of 
Procedure was rejected during the debate: 
'Point 1.6. — 4th sentence 
Fourth sentence should read as follows: 
'Despite the clear progress which has been made, the Committee proposes to the Council of Ministers and 
the Commission that the more stringent limit values(*) which are already in force in Austria, Switzerland 
and Scandinavia should be prescribed from 1992/1993. The Committee is convinced that this is technologically 
feasible.' 
(*) (Carbon monoxide: 20 g per test, hydrocarbons and nitrogen oxides: 5 g per test) 
Reason 
In its Opinion on the fourth environmental action programme the Committee argued—in line with the 
Commission's general thrust—that technological progress should also be taken into account when tightening 
up limit values for vehicle exhaust emissions. 
The Commission proposal was not however bold enough since it did not provide a sufficiently forward-
looking definition of technological progress. The Council of Ministers for its part decided that it had to be 
possible to achieve the prescribed emission limits by more than one technical means. On the European car 
market, there are already 28 models with an engine capacity of 1,4 litres or less which conform to the more 
stringent limit values for emissions. 
Furthermore, it is not logical that the population and plant life of Switzerland, Sweden and Austria (to be 
followed shortly by Norway and Finland) should be more effectively protected than those of the European 
Communities. Discrepancies between the European Free Trade Association (EFTA) and the EC markets 
cannot be in the interests of industry since different limit values for emissions will create technical trade 
barriers. This should be averted particularly in view of the discussions now being conducted between the EC 
and EFTA representatives. 
The provisions for small cars should therefore already be geared to the improved level of protection by 1992/ 
1993.' 
Voting 
For: 35, against: 46, abstentions: 7. 
No C 208/10 Official Journal of the European Communities 8. 8. 88 
APPENDIX 3 
to the Opinion of the Economic and Social Committee 
Following the vote by name on the Opinion as a whole, those members of the 'consumers' category who 
voted against made the following minority declaration: 
'The 'consumers' category cannot support the Opinion of the Economic and Social Committee. 
The 'consumers' category is in disagreement with the Commission proposal and considers that the more 
stringent limit values already in force in other European countries (20 g per test in the case of carbon 
monoxide, 5 g per test in the case of hydrocarbons and nitrogen oxides) should be prescribed from 1992/ 
1993. The 'consumers' category is convinced that this is possible given current levels of technology. 
The following comments need to be made in connection with the Opinion: 
State of technology 
The Commission proposal is not bold enough since it does not provide a sufficiently forward-looking 
definition of technological progress. 
In its Opinion on the fourth environmental action programme of the European Communities the Committee 
argued—in line with the Commission's general thrust—that technological progress should also be taken into 
account when tightening up limit values for vehicle exhaust emissions. Opel turns out two models which 
meet stringent standards at no extra cost. The Fiat Uno exists in a model equipped with a catalytic converter 
costing, in the Federal Republic of Germany, only 6-7% more than the model without a pre-adjusted 
catalyser. The Council of Ministers has for its part decided that it must be possible to achieve the prescribed 
emission limits by more than one technical means. Apart from the catalytic converter technology, the 
Commission proposal cites the examples of the Opel car manufacturers. Volvo has also recently presented a 
small-engine car which meets stringent limit values without being equipped with a pre-adjusted catalytic 
converter. On the European car market there are already 28 models with an engine capacity of 1,4 litres or 
less which conform to the more stringent limit values for emissions. 
Costs 
The Commission has calculated in its proposal that the price will go up 13-15% if a pre-adjusted catalytic 
converter is fixed and, implicitly, if more stringent gas emission standards are to be met. It considers that 
such an increase cannot be imposed on buyers. Nevertheless, consumer protection organizations have voted 
in favour of more stringent limit values since damage to the environment also has a price which has to be 
paid. They are therefore ready to make certain sacrifices. We can assume with absolute certainty that the 
mass production of such cars will give rise to rationalization measures with the result that more favourable 
consumer prices can be set. 
EC/EFT A relationship 
Discrepancies between the EFTA and the EC markets cannot be in the interests of industry since different 
limit values for emissions would create technical trade barriers. 
Furthermore, it is not logical that the population and plant life of Switzerland, Sweden and Austria (to be 
followed shortly by Norway and Finland) should be more effectively protected than those of the European 
Communities. 
Summary 
For the reasons mentioned above the provisions for small cars should therefore already be geared to the 
improved level of protection by 1992/1993.' 
Mrs Gredal, Mrs Rangoni-Machiavelli, Mrs Williams 
Mr Ataide-Ferreira, Mr Hilkens, Mr Jaschick.