6. 8. 84 Official Journal of the European Communities No C 206/7 
3.12.2. The Committee recognizes that the Com­
mission is already in discussion with many of the 33 
signatories of the Convention on ways and means to 
Done at Brussels, 23 May 1984. 
1. The Committee considers the protection of the 
health, safety and well-being of consumers as the 
first priority, and accordingly regards the proposed 
Directive as a step in the right direction and as 
being in conformity with the general principles on 
solvents set out in Directive 73/241/EEC (') on 
cocoa and chocolate products and in Directive 77/ 
436/EEC (2) on coffee and chicory extracts. Never-
(') Directive 73/241/EEC of 24 July 1973 on the approxi­
mation of the laws of the Member States relating to 
cocoa and chocolate products intended for human 
consumption (see Article 5); OJ No L 228, 16. 8. 1973, 
p. 23. 
(2) Directive 77/436/EEC of 27 June 1977 on the approx­
imation of the laws of the Member States relating to 
coffee extracts and chicory extracts (see Article 3); OJ 
No L 172, 12. 7. 1977, p. 20. reduce emissions overall in Europe and it stresses 
the great importance of this work. 
theless, the Committee makes a number of signifi­
cant observations which it feels must be taken into 
account. 
General observations 
2. Scientific Committee for Food 
2.1. The Committee accepts the evidence and 
expert opinion on solvents provided by the Scien­
tific Committee for Food, an internationally 
accepted independent body, and set out in report 
EUR 7421 (11th series). The Chairman 
of the Economic and Social Committee 
Franccois CEYRAC 
Opinion on the proposal for a Council Directive on the approximation of the laws of the 
Member States on extraction solvents used in the production of foodstuffs and food 
ingredients 
(84/C 206/02) 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 312 of 17 November 1983, page 3. 
A. LEGAL BASIS FOR THE OPINION 
On 21 November 1983 the Council decided to consult the Economic and Social 
Committee under Article 100 of the Treaty establishing the European Economic 
Community on the abovementioned matter. 
Procedure: 
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 26 and 27 April 1984, in the light of the report by Mrs Williams. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
At its 217th plenary session, meeting of 23 May 1984, the Economic and Social Com­
mittee unanimously adopted the following opinion: 
No C 206/8 Official Journal of the European Communities 6.8.84 
2.2. The Committee regrets, therefore, that the 
views of the Scientific Committee have not been 
adequately covered in the Commission's proposal, 
and that in fact in some cases the conditions now 
put forward are less stringent that those proposed by 
the Scientific Committee, and in one case (anhy­
drous solution of ammonia) a new element has been 
added on which the Scientific Committee has not 
commented (see the Appendix to this opinion which 
lists the discrepancies). 
2.3. The Committee stresses the need for more 
rapid progress in respect of this proposal for a 
Directive, in view of its importance for public health 
and safety. In particular, the Committee urges the 
Commission not to wait indefinitely for further con­
sultations and research but to put forward the pro­
posed Directive based on the best information cur­
rently available, including the recommendations 
made in this opinion. 
3. Specific criteria 
3.1. In its preamble and in Articles 4 and 5 the 
proposal states that both general and specific purity 
criteria for extraction solvents should be 'estab­
lished' and 'specified'. 
3.2. Specific criteria are not yet established, how­
ever, and the Committee questions whether the pres­
ent proposal can have any practical value if it is 
adopted without first introducing purity criteria. 
Without these, toxicological evaluation has no basis. 
Purity criteria must therefore be introduced at the 
same time as the proposal itself, possibly using 
manufacturer's 'foodstuff grade specifications' as a 
basis. 
Specific observations 
4. Unavoidable residues 
4.1. The proposal is defined as applying to extrac­
tion solvents used in the production of foodstuffs or 
food ingredients (Article 1); no distinction is made 
between maximum permissible residues in food­
stuffs for retail sale, and such residues in foodstuff 
ingredients used in the production process, some of 
which are also sold to the consumer (see Annex, 
Part II, column 4). 4.1.2. The Committee considers that there is confu­
sion on the implications of this matter for industry, 
and that the Annex should make a distinction 
between maximum permissible residues for sales or 
exchanges at industrial level or for sale to the final 
consumer. 
4.1.3. In particular the Committee is concerned 
that such maximum permissible residues, if applied 
at industrial level, might have the effect of driving 
certain industries out of business, or force them to 
resort to other and possibly less innocuous extrac­
tion solvents. 
4.1.4. Accordingly the Committee proposes that 
Part II of the Annex be amended as follows: 
'Under the headings "Light petroleum" and 
"Propan-1-ol" the phrase in column 4 of Part II 
which describes the maximum residues for the 
preparation of protein products and defatted 
flours should be changed from "20 mg/kg in the 
protein product of flour" to read "20 mg/kg in 
the final food containing the ingredient".' 
4.2. In Article 1 the proposal defines extraction 
solvents as those which, although 'removed' may 
still leave residues whose presence is described as 
'technically unavoidable'. 
4.2.1. The Committee considers that it must not be 
assumed that such residues are unavoidable, as 
future technological research may render this 
assumption incorrect, by reducing minimum 
residues to zero. 
4.2.2. It would be better, then, to remove the con­
cept of unavoidability from the present proposal 
and to define an extraction solvent as one which 
leaves the minimum possible residue in accordance 
with the best state of the art at any given time. But 
in all cases this residue must be below the maximum 
thresholds mentioned in the last column of Part II 
of the Annex. 
5. Notifica tion period 
5.1. The proposed Directive envisages that the 
provisions relating to the list of substances cited in 
6.8.84 Official Journal of the European Communities No C 206/9 
Article 2 (4) shall be re-examined within five years 
of notification of the Directive. 
5.2. The Committee considers that this period is 
too long and should be substantially reduced. A 
reduction from five to three years is suggested. 
6. Positive lists 
6.1. The Committee agrees with the principle of 
the positive list, as set out in Articles 2 and 7 i.e. 
substances on the list are permitted; substances not 
on it are not permitted. This is in accordance with 
the Committee's position on previous proposals of 
this type (')• 
6.2. The Committee draws attention once again to 
the Annex to the present opinion settingout a num­
ber of discrepancies and in particular considers it 
anomalous that two substances — butyl acetate and 
propan-2-ol — which the Scientific Committee for 
Food described as 'temporarily acceptable' should 
be included in Part I of the Annex to the proposal 
under the category of 'extraction solvents for which 
conditions of use are unspecified', and suggests that 
they be reclassified. 
6.3. The Committee considers however that a sim­
ple non-bureaucratic procedure should be introd­
uced to allow the addition to the positive list of sol­
vents newly identified by research. 
7. Derogations 
7.1. The Committee notes that under Article 3 a 
Member State may, by way of derogation, authorize 
the use within its national territory of extraction sol­
vents not on the Directive's positive list, provided 
that it notifies the Commission within two months. 
7.2. Article 3 further stipulates that supporting 
documentation must be submitted to the Commis­
sion within three years. The Committee considers 
that such supporting documentation should be sub­
mitted at the same time as the original notification, 
not up to three years later. 
(') 1. Colouring matters (OJ No C 113, 7. 5. 1980); 
2. Preservatives and antioxidants (OJ No C 348, 
31. 12. 1980); 
3. Flavourings (OJ No C 138, 9. 6. 1981). 8. Sampling 
8.1. The Committee notes the provisions in Artir 
cles 5 and 8 for the establishment of procedures and 
methods for sampling and analyzing extraction sol­
vents as laid down in these Articles, but draws atten­
tion to the necessity from the consumers' point of 
view, that there must be relevant tests made at the 
retail as well as at other stages of the food produc­
tion chain. 
9. Qualified voting procedure 
9.1. The Committee considers that the powers of 
the Standing Committee for Foodstuffs in this parti­
cular case should be clearly delimitated and not left 
too wide. 
9.2. This would be in conformity with Article 2 of 
Council Decision 69/414/EEC setting up the 
Standing Committee for Foodstuffs which provides: 
'The Committee shall, in the cases and under 
the conditions provided for therein, carry out 
the duties devolving upon it under the instru­
ments relating to foodstuffs adopted by the 
Council.' 
10. Exports and imports 
10.1. The Committee feels that it is unnecessary to 
state categorically that the proposed Directive does 
not apply to exports, as it might only encourage the 
disposal of less pure products in external markets. 
10.1.1. The Committee would prefer to see this 
problem tackled the other way round: Community 
standards must apply unless a non-member State 
lays down specific and compulsory standards in res­
pect of imported extraction solvents, foodstuffs or 
ingredients. 
10.1.2. Accordingly, the Committee proposed that 
Article 10 (2) be revised or struck out. 
10.2. On the other hand, as far as import controls 
are concerned, the Committee recognizes that the 
Community cannot legislate for non-Community 
countries in the matter of solvent standards, but is 
concerned that solvents produced in third countries 
below the proposed Community standards will find 
their way to the Community market. 
No C 206/10 Official Journal of the European Communities 6. 8. 84 
10.3. The Commission should point out to the 
Member States that they should take appropriate 
measures to ensure that no foodstuffs can be imported from non-Community countries if they 
contain solvents in excess of Community standards. 
Done at Brussels, 23 May 1984. 
The Chairman 
of the Economic and Social Committee 
Francis CEYRAC 
APPENDIX 
The recommendations of the Scientific Committee for Food which were not clearly and specifi­
cally incorporated in the Commission's proposal are set out below (quotations from Doc. EUR 
7421, page 6 et seq. — following order of citation in Annex to the Commission's proposal, Parts I 
and II). 
Annex to Commission'sproposal 
PART I 
(i) Butyl acetate 
'The Committee considers this substance temporarily acceptable as an extraction solvent.' 
(ii) Propan-2-ol 
'The Committee considers this compound temporarily acceptable as an extraction solvent.' 
(iii) Acetone 
'The Committee recommends that the specification should include a limit of 10 ppm for mesity-
loxide, (and) considers the use of this substance acceptable as extraction solvent for food prov­
ided residues are kept to 5 mg/kg food as consumed.' 
(iv) Nitrous oxide 
'The specification should exclude the presence of other oxides of nitrogen.' 
A nnex to Commission's proposal 
PART II 
(i) Diethyl ether 
'The specification should contain limits for named stabilizers.' 
(ii) Light petroleum 
'A specification is needed with limits for unsaturated aliphatic hydrocarbons and polycyclic 
aromatic hydrocarbons.' 
This substance is also described by the Scientific Committee in the following terms: 'This 
material is difficult to specify but comprises a mixture of saturated aliphatic hydrocarbons with a 
specified distillation range, containing up to 50 % hexane and various amounts of heptane.' 
6. 8. 84 Official Journal of the European Communities No C 206/11 
This description of 'light petroleum' should be compared with that given in a footnote in Part II 
of the Annex to the Commission's proposal. 
(iii) Propan-1-ol 
'The Committee considers the use of this compound temporarily acceptable as extraction solvent 
if residues from this use in food as consumed do not exceed 5 mg/kg.' 
(iv) Methyl ethyl ketone 
'The Committee recommends that the specification should limit the amount of hexane in MEK 
to 50 mg/kg.' 
The Scientific Committee does not comment on the following substance which is included in 
Part II of the Annex to the Commission's proposal: 
Anhydrous solution of ammonia in methanol, ethanol, propan-1-ol, propan-2-ol or butan-2-ol. 
Opinion on the draft Council recommendation concerning the adoption of a European 
emergency health card 
(84/C 206/03) 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 21 of 28 January 1984, page 7. 
A. LEGAL BASIS FOR THE OPINION 
On 10 January 1984 the Council decided to consult the Economic and Social Com­
mittee in accordance with Article 198 of the Treaty establishing the European Econo­
mic Community on the abovementioned draft recommendation. 
Procedure: 
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 26 and 27 April 1984, in the light of the report by Mr Brassier. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
At its 217th plenary session, meeting of 23 May 1984, the Economic and Social Com­
mittee adopted the following opinion by a unanimous vote: 
1. The Committee wholeheartedly endorses the 
point of view expressed by the European Parliament 
in its resolution of 13 October 1981 calling for the 
introduction of a European emergency health card. 2. Travel is on the increase among some sections 
of the Community population. This includes per­
sons suffering from serious or chronic illnesses (8 to 
10% of the population) who may need swift and 
appropriate medical attention in the event of an 
accident or illness occurring during a business or 
pleasure trip. 
Therefore, it approves the recommendation submit­
ted to the Council by the Commission. 2.1. Under such circumstances the sick or injured