1. 10. 79 Official Journal of the European Communities No C 247/67 
2.4. The Committee notes that the Commission's 
proposal to reduce the intervention price for Erzegovina 
and Perustitza from 90 to 80% of the norm price 
complies with Article 13 (3) and (4) of Regulation (EEC) 
No 727/70, but comes at a time when both the 
Community and growers are taking measures to improve 
the situation of these two varieties. 
2.5. Moreover, the Committee notes that the 
Commission's proposal penalizes equally all the 
producers of these varieties, whereas — while taking into 
account the fact that recourse to intervention is to be 
exceptional — it should have considered the efforts made 
by those producers who normally sell their output on the 
open market and who sell to the intervention agency only 
intermittently and in situations that are very difficult in 
objective terms (e.g. the world market situation). 2.6. In conclusion, the Committee points out that, in 
contrast to Article 13 (3), the Commission's proposal 
provides for the adoption by the Council of specific 
measures which are valid for two harvests. Furthermore, 
it does not lay down measures to safeguard the position 
of those growers who normally sell their output on the 
open market — this could be done, for example, by 
stipulating that the reduction in the intervention 
guarantee given to growers is to vary according to the 
percentage of their output which they sell to the 
intervention agency. 
2.7. The Committee therefore urges the Commission 
to consider amending its proposal in the light of the 
above comments, and of the present state of the market. 
Done at Brussels, 27 June 1979. 
The Chairman 
of the Economic and Social Committee 
Raffaele VANNI 
Opinion on the proposal for a Council Regulation on investment aid at the marketing and 
processing stage of milk products 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 88 of 4 April 1979, page 9. 
A. LEGAL BASIS FOR THE OPINION 
On 28 March 1979 the Council referred the abovementioned proposal to the Economic and 
Social Committee in accordance with Articles 43 and 198 of the Treaty establishing the 
European Economic Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
169th plenary session held in Brussels on 27 and 28 June 1979. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Articles 43 and 
198 thereof, 
Having regard to the request made by the Council of the 
European Communities on 28 March 1979 for an 
opinion, Having regard to the decision taken by its Bureau on 
3 April 1979 instructing the Section for Agriculture to 
draw up an opinion on the matter, 
Having regard to its previous work on the matter, and in 
particular its opinion on farm prices for the 1979/80 
marketing year and other related measures (1), 
(*) OJ No C 171, 9. 7. 1979, p. 1. 
No C 247/68 Official Journal of the European Communities 1. 10. 79 
Having regard to the opinion issued by the Section for 
Agriculture at its meeting held on 31 May 1979, 
Having regard to the oral report submitted by the 
rapporteur, Mr Schnieders, 
Having regard to the discussions at its 169th plenary 
session held on 27 and 28 June 1979 (meeting of 27 June 
1979), 
HAS ADOPTED THE FOLLOWING OPINION 
with no votes against and six abstentions: 
The Committee has the following comments to make on 
the Commission's proposals: 
1. It is true to say that there are considerable problems 
on the milk market. But the Committee would point out 
that surpluses are not caused by the structure of 
processing firms. Processing firms' size normally depends 
on how much milk is produced from processing. 
Processing capacities are tailored to production, and not 
vice versa. 
2. The Committee has noted that the ban on national 
aid does not apply to general economic and tax measures 
affecting all firms and sectors of the economy. 
The Committee would like the Commission to ensure 
that the Regulation cannot be undermined by exceptions 
of this kind, especially as the measures proposed are 
altogether not very comprehensive. Tax and cyclical 
measures in many countries may be more extensive and 
have a greater impact. 
3. Milk processing and marketing firms must be 
modernized even with the present surpluses. Such 
modernization should aim at achieving the following 
three things in particular: 
(a) a rationalization of plant, so that marketing and 
processing costs per kilogram of treated milk can be 
brought down; 
Done at Brussels, 27 June 1979. (b) a switch to new and better products, so as to boost 
sales within the Community; 
(c) the construction of plant to produce products that 
will provide greater sales opportunities in non-EEC 
countries with different consumer habits. 
Such measures should therefore continue to receive aid 
provided that the proposed structural changes cannot 
result in an increase in the Community's production 
capacity. To ensure this, restructuring plans are 
necessary. The Committee therefore suggests that the 
Commission has another look at its proposal bearing 
these needs in mind. 
4. The Commission's proposal is particularly 
inadequate for Community regions such as hill and 
mountain areas and certain regions of Italy where milk 
production, although low, is the only possible 
alternative. In such regions it is necessary to create and 
modernize infrastructures for processing and marketing. 
5. The Committee has noted that rights acquired by 
virtue of national provisions existing before the entry 
into force of the Regulation are to be regulated 
nationally. It therefore asks the Commission to ensure, 
either through the EC structure committee or in some 
other way, that the same criteria are employed in the 
Member States. 
6. Any exemptions from the aid ban in the proposal 
should lead to efficient structures. 
7. The Committee would further point out that it is 
inconsistent to allow aid in the future for the 
development of new products when these can only be 
produced by reducing the output of what is produced 
now. Such a situation would defeat the whole object of 
developing new products, which is to create a bigger 
market. 
8. Steps must be taken to ensure that any new 
products developed contain a minimum quantity of milk; 
otherwise the Commission's fear of encouraging milk 
substitutes would become reality. 
The Chairman 
of the Economic and Social Committee 
Raffaele VANNI