31. 7. 78 Official  Journal  of the European  Communities No C 181/31 
Having  regard  to the opinion  adopted  by the Section  in 
accordance  with  the  written  procedure  on 15 March 
1978, 
Having  regard  to the  discussions  at its 157th  plenary 
session,  held  on 29 and  30 March  (meeting  of 29 March 
1978), 
Whereas  the  Inland  Transport  Committee  of  the 
Economic  Commission  for Europe  based  in Geneva  has 
approved  the  revision  of resolution  No  212  relating  to 
the facilitation  of health  and  quality  inspection  in the 
international  carriage  of goods  by rail;  whereas  the 
application  of the revised  version  of resolution  No 212 
will make  the  crossing  of national  borders  easier  by 
eliminating  unnecessary  and  superfluous  interruptions 
in the  movement  of perishable  goods  from  non-Com-
munity  countries  which  are  imported  into,  or transit 
through,  the Community; 
Done  at Brussels,  29 March  1978. Whereas  the  subject  concerned  by the  revised  resol-
ution,  namely  veterinary,  plant-health  and  quality  in-
spections  in trade  with  non-Community  countries,  is 
within  the competence  of the Community; 
Whereas  under  these  circumstances  it is up  to the 
Community  to approve  and  accept  the  revised  res-
olution, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
unanimously: 
The Committee  approves  the proposal  for a Decision. 
The Chairman 
of the Economic  and  Social  Committee 
Basil  de FERRANTI 
Opinion  on the communication  of the Commission  to the Council  and  to the European  Par-
liament  on the state  of the customs  union  of the European  Economic  Community 
The opinion  of the Committee  does  not  relate  to any  particular  text. 
A. LEGAL  BASIS  FOR  THE  OPINION 
At its 151st  plenary  session  held  on 27 and  28 September  1977  the Committee,  acting  on a 
proposal  from  its Bureau,  decided  to deliver  an opinion  on the  abovementioned  subject  on 
its own  initiative. 
B. OPINION  OF THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its opinion  at its 157th  plenary  session,  held 
in Brussels  on 29 and  30 March  1978. 
The opinion  is published  below. 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to Article  20 (4)  of its Rules  of Pro-
cedure, Having  regard  to its decision  of 27 September  1977,  on 
a proposal  from  its Bureau,  to deliver  an own-initiative 
opinion  on the  communication  of the  Commission  to 
the Council  and  to the  European  Parliament  on the 
state  of the  customs  union  of the  European  Economic 
Community, 
No C 181/32 Official  Journal  of the European  Communities 31. 7. 78 
Having  regard  to its decision  of 27 September  1977, 
instructing  the Section  for Industry,  Commerce,  Crafts 
and Services  to prepare  its work  on the matter, 
Having  regard  to the opinion  given  by the Section  for 
Industry,  Commerce,  Crafts  and  Services  on 8 March 
1978, 
Having  regard  to the  discussions  at its 157th  plenary 
session  on 29 and  30 March  1978,  session  of 30 March 
1978, 
Whereas  the  abolition  of customs  duties  between  the 
nine Member  States  of the  European  Economic  Com-
munity  on 1 July  1977  was  an important  event; 
Whereas  with  customs  duties  abolished,  the  customs 
union's  instruments  and  procedures  represent  the  de-
cisive  factor  in intra-Community  trade; 
WTiereas  it is consequently  important  to examine  to 
what  extent  the  customs  union  meets  the  needs  of 
businessmen  and  ordinary  individuals  throughout  the 
Community  and  fulfils  the aims  laid  down  in the Treaty 
establishing  the European  Economic  Community; 
Whereas  proposals  calculated  to improve  the function-
ing of the customs  union  are called  for, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
unanimously: 
On 1 July  1977,  residual  customs  duties  between  the six 
original  and  three  new  Member  States  of the European 
Economic  Community  were  abolished.  This  important 
achievement,  which  was  one  of the main  objectives  of 
the 1957  Treaty,  and was  often  considered  in the early 
days  to be nothing  more  than  a pipe  dream,  coincided 
with  the  abolition  of the  same  duties  on industrial 
goods  passing  between  the EEC  and  the seven  member 
countries  of EFTA. 
The linking  together  of 16 countries  representing  almost 
the whole  of Western  Europe  by means  of a customs 
union  (for  the Nine)  and  free  trade  agreements  is an 
event  of major  significance.  Outside  a few  specialist 
circles,  however,  1 July  1977  passed  by almost  un-
noticed  and  ordinary  people  in the EEC  failed  to see it 
as a tangible  expression  of European  unity,  as one 
would  have  liked. Nevertheless,  the  customs  union  has  been  a consider-
able success.  Between  1958  and  1976  intra-Community 
trade  increased  more  than  tenfold  (in terms  of value  (US 
dollars)  ) and  now  accounts  for  more  than  50 % of 
most  Member  States'  foreign  trade.  And  although  gen-
eral economic  growth  during  this  period  was  obviously 
a factor  in the expansion  of trade,  one  cannot  disregard 
the very  large  contribution  made  by the customs  union. 
Hence  it is true  to say that  the Community  is gradually 
becoming  a 'single  market  covering  more  than  250  mill-
ion inhabitants'. 
A close  look  at the real  problems  involved  in the move-
ment  of goods  and  persons  within  the  EEC  shows, 
however,  that  a great  deal  of progress  still  has  to be 
made.  The  customs  union  after  all is not the be-all  and 
end-all  of the common  market;  it is but one  of the step-
ping-stones  on the way  to economic  union,  and  unfor-
tunately  there  are a number  of other  factors  that  make 
for continued  fragmentation  of our  'single  market  of 
250 million  inhabitants'.  Looking  back  over  the period 
of close  on 20 years  that  has elapsed  since  the founding 
I of the EEC,  we can  see that  the customs  union  has been 
one of the mainstays  of the Community  — and  virtually 
the only  one  for which  methods  and  means  are clearly 
defined  in the Treaty  of 1957.  However,  if the abolition 
of customs  duties  is now  a fact,  it is also  true  to say that 
it 'has  not  been  accompanied  by an appreciable  change 
in the  customs  formalities  to be complied  with'.  For 
both  an EEC-based  company  and  an ordinary  traveller, 
there  is practically  no difference  between  crossing  an 
intra-Community  border  and  crossing  a border  with  a 
non-member  country.  The  formalities  are as complex, 
the rules  as restrictive,  and  the tax relief  for exports  the 
same.  And  when  — as is often  the  case  — a non-
member  country  no longer  levies  customs  duties  on 
imports  from  the EEC  because  of agreements  concluded 
with  the Community,  then  it is perfectly  understandable 
if a Community  businessman  is not  fully  aware  of be-
longing  to a unified  whole  and  is not clear  in his mind 
about  the benefits  of the customs  union. 
The Committee  finds  this situation  disturbing,  especially 
since  the present  difficulties  in world  trade  are tending 
in many  cases  to make  national  economies  inward-look-
ing. It consequently  felt  that  it should  consider  this  situ-
ation  in its entirety  taking  as its basis  the specific  ob-
servations  made  by members  in the  sector  they  repre-
sent,  rather  than  setting  out from  theoretical  economic 
research. 
1. The  inadequacies  of the European  customs  union 
1.1. It has  become  commonplace  to say  that  the 
Community  is a tariff  union  rather  than  a customs 
union.  There  is but one  single  Common  Customs  Tariff 
and goods  imported  from  outside  the  Community 
theoretically  attract  the  same  duties  in all Member 
States.  Unfortunately  the  manner  in which  tariffs  are 
31.17.  78 Official  Journal  of the European  Communities No C 181/33 
applied  applied  varies  from  country  to country.  For 
example,  customs  authorities  in countries  with  a long 
trading  tradition  naturally  adopt  a more  flexible  ap-
proach  than  their  counterparts  in countries  which  tra-
ditionally  lay more  emphasis  on the protective  function 
of tariffs. 
Such  differences  in approach  are  compounded  by the 
shortcomings  of the  EEC's  system  of rules  and  regu-
lations.  A good  many  provisions  (on  warehousing  pro-
cedures,  free  zones,  inward  processing,  etc.)  have  had  to 
be adopted  in the  form  of Directives,  and  Directives 
prescribe  ends  but  not  means.  In other  words,  in such 
fields  Member  States  are free  to choose  whatever  pro-
cedures  they  like.  These  procedures  differ  accordingly 
from  country  to country,  place  uneven  burdens  on users 
and lead  to a situation  where  a uniform  customs  tariff 
has variable  effects,  depending  on the country  applying 
it. 
Furthermore,  in the  absence  of Community  rules  in 
several  major  areas  of customs  legislation  (occurrence 
and settlement  of customs  debts,  repayment  or re-
mission  of customs  duties,  exemptions  from  customs 
duties,  etc.)  the  treatment  of Community  businessmen 
continues  to vary  according  to the  Member  State  in 
which  they  are based. 
1.2. Another  source  of concern  is the situation  in in-
tra-Community  trade,  where  there  is not even  any  uni-
fying  force  like  the Common  Customs  Tariff.  With  the 
disappearance  of customs  duties  subject  to Community 
rules  and  controls,  we have  here  national  regulations 
superimposed  on (rather  than  merged  with)  common 
rules  on the organization  of a single  market. 
1.2.1.  The  following  are some  of the main  deficiencies 
in the customs  sphere: 
— the  multiplicity  of forms  and  formalities; 
— the  lack  of uniform  procedures; 
— differing  policies  followed  with  regard  to the 
guarantees  required  for customs  clearance,  storage, 
temporary  admission,  etc.; 
— the  need  to obtain  prior  authorization  in certain 
Member  States  for clearing  goods  through  customs 
for third  parties; 
— the  variable  application  of international  customs 
conventions  (ATA  Convention,  TIR  Convention); 
— the  different  customs  clearance  arrangements  (in 
some  cases  there  are border  controls,  in others  there 
are checks  at the place  of domicile,  and  in yet other 
cases  the customs  authorities  operate  on the basis  of 
firms'  accounts). This  state  of affairs  can  be summed  up by the  stark 
observation  that,  with  the customs  union  being  what  it 
is, customs  brokers  would  be totally  at sea  if they 
wanted  to clear  goods  through  customs  in a Member 
State  other  than  their  own. 
2. The  inadequacies  of alignment  in other  fields 
2.1. Blame  for the situation  described  above  cannot  be 
laid solely  at the door  of the customs  union.  Customs 
clearance  in fact  has never  just  involved  the  collection 
of customs  duties  but has  always  been  a focal  point  for 
enforcing  a whole  panoply  of restrictive  national  rules 
and regulations.  With  the  disappearance  of customs 
duties,  the other  components  of the customs  clearance 
process  have  gained  in importance  in many  cases. 
2.1.1.  The  system  used  in taxing  goods  is basically 
VAT.  The  uniformity  which  this  mechanism  ought  to 
guarantee  is, however,  vitiated  by the fact  that  there  are 
various  VAT  rates  and  that  products  are classified  dif-
ferently.  Similarly,  systems  of collection  (or non-collec-
tion)  of VAT  and  the  rules  governing  deductions  etc. 
differ  so much  from  Member  State  to Member  State 
that a wide  range  of formalities  have  to be complied 
with  by importers  and  exporters.  Above  all,  however, 
business  firms  are faced  with  extremely  variable  residual 
tax burdens.  Notwithstanding  the  improvements  that 
can be expected  when  the provisions  of the Sixth  Direc-
tive on VAT  come  into  force,  the Committee  feels  that 
the present  situation  is likely  to lead  to what  might  be 
termed  a reappearance  of customs  barriers  between 
Member  States  in the form  of taxes. 
2.1.2.  Currency  variations  have  the  same  effect,  and 
the remedies  applied  in certain  sectors  (e.g.  monetary 
compensatory  amounts)  complicate  formalities  further 
without  really  achieving  their  objectives.  Intra-Com-
munity  trade  is also  hampered,  and  customs  formalities 
complicated  further,  by exchange  controls  — the  re-
grettable  consequence  of the  Community's  failure  to 
achieve  monetary  unity. 
2.1.3.  The  fact  that  the  compilation  of statistics  has 
not been  harmonized  is also  a very  great  drawback. 
What  is required  in the  way  of statistics  varies  from 
country  to country  and  only  a handful  of codes  (codes 
for countries,  codes  for  regions)  have  actually  been 
standardized.  There  is a common  nomenclature  as far as 
the Common  Customs  Tariff  is concerned  but  the 
nomenclature  used  for statistics  varies  despite  the exis-
tence  of NIMEXE.  Above  all, however,  each  individual 
Member  State  collects  statistical  information  in its own 
way.  Any  goods  transaction  between  Member  States 
thus involves  at least  three  statistical  declarations: 
(a) for export,  (b) for transit,  and  (c) for import.  All of 
this adds  to the complexity  of customs  declarations. 
2.1.4.  Finally,  the organization  of Community  markets 
basically  works  by means  of checks  on intra-Com-
munity  trade.  This  is especially  true  of agricultural  pro-
No C 181/34 Official  Journal  of the European  Communities 31. 7. 78 
ucts,  but  it also  applies  to other  sectors.  The  Regu-
lations  which  are  issued  can  generally  be justified  but 
are always  excessively  detailed,  so much  so that  it is 
legitimate  to ask  whether  they  can  really  be applied  in 
practice.  It is only  logical  that  checks  on compliance 
with  such  Regulations  should  be nowhere  so stringent 
as in the field  of intra-Community  trade. 
National  standards  still  diverge  too frequently  and  there 
are even  divergences  within  one  and  the same  Member 
State.  And  when  Community  standards  are  enacted, 
they are often  applied  more  strictly  in intra-Community 
trade  than  elsewhere. 
2.1.5.  The  fluctuating  nature  of the multifarious  rules 
and regulations  leads  ultimately  to uncertainty  in trade, 
particularly  in the  marketing  of consumer  goods.  A 
company  which  restricts  itself  to a few  products  can still 
hope  to keep  up with  changes  in the  rules  and  regu-
lations  applicable  thereto,  but  a firm  engaged  in the 
import  or export  of a variety  of manufactured  articles 
within  the  Community  no longer  knows  exactly  how 
these  articles  will  be treated  in this  or that  Member 
State  and  has  therefore  no certainty  or guarantee  as to 
formalities  and  cost. 
2.2. It is clear  from  the above  that  customs  formalities 
for trade  between  Member  States  are often  more  com-
plex than  those  for  trade  with  non-member  countries 
involving  the payment  of customs  duties. 
3. Development  of the customs  union 
3.1. The  Committee  has  already  drawn  attention  to 
the role  of the  customs  union  as a mainstay  of the 
Community.  The  difficulties  referred  to above  are  in-
deed  a major  shackle  on the  union's  further  develop-
ment  but must  not under  any  circumstances  be taken  as 
a pretext  for a standstill.  In other  words  it would  be 
dangerous  to require  the problems  stemming  from  fis-
cal, monetary  and  various  other  divergences  to be 
solved  before  any  new  action  is undertaken  on the cus-
toms  union. 
3.2. The  customs  union  is not the be-all  and  end-all  of 
the Community,  but  — with  the Treaty  as it is at pre-
sent —  all  Community  activities  find  expression 
through  it. The  Committee  therefore  hopes  that  the 
customs  union  will  evolve  along  the  lines  it has  itself 
advocated  more  than  once  in the past,  and  calls  in par-
ticular  for  the  development  of trade  within  a liberal 
framework  in the  interests  of both  traders  and  users 
(either  as consumers  or persons  moving  within  the 
Community). 
3.3. Methods  of running  the  customs  union 
The Committee  maintains  that  rapid,  accurate  decisions 
such  as can  only  be provided  by a flexible  decision-making  procedure  are needed  to administer  the customs 
union  and  ensure  a proper  response  to fluctuations  in 
trade  and  the economy.  However,  in its communication 
the Commission  underlines  'the  cumbersome  nature  of 
the decision-making  machinery'  and  notes  that  at least 
two years  are  needed  for  the  slightest  amendment  to 
existing  legislation.  In fact  nine  draft  Regulations  or 
Directives  on customs  matters,  on which  the Committee 
duly  delivered  its opinions,  are currently  held  up pend-
ing a Council  Decision,  even  though  a number  of them 
(e.g. the Directive  on procedures  for the release  of goods 
for free  circulation)  need  to be adopted  urgently.  In this 
connection  the Committee  wholeheartedly  endorses  the 
European  Parliament's  resolution  of 9 April  1977.  The 
methods  used  to operate  the customs  unioA  are in too 
many  cases  unsuited  to a modern  economy  and  are not 
in keeping  with  the normal  profitability  criteria  applied 
by firms. 
3.4. This  situation  has  been  further  aggravated  by the 
disparate  character  of the  measures  adopted  since  the 
start  of the customs  union.  It is true,  though,  that  con-
siderable  efforts  have  been  made  and  a substantial  body 
of Community  Regulations  has been  produced. 
These  texts,  however,  lack  cohesion.  There  have  been 
numerous  shortcomings,  including  in particular: 
— the  large  number  of repetitions,  which  lead  to con-
fusion; 
— possible  discrepancies  between  provisions; 
— the  failure  to distinguish  clearly  between  the  func-
tion of a Regulation  and  that  of a Directive.  Many 
Directives  lay  down  specific  requirements  which 
really  belong  to the sphere  of Regulations; 
— difficulties  encountered  by the authorities  and  users 
in interpreting  the texts  and  the consequent  risk  of 
diverging  interpretations; 
— a host  of management  committees  (creation  of new 
committees  whenever  Regulations  or Directives  are 
adopted). 
3.5. Unsatisfactory  both  from  a legal  and  a practical 
point  of view,  this  situation  is made  even  worse  by the 
total  absence  of a Community  system  of penalties  for 
infringements  of Community  customs  Regulations.  In 
the end  it is necessary  to have  recourse  in each  case  to 
national  law  with  the consequent  danger  that  penalties 
may vary  from  country  to country,  or that  complicated 
procedures  (such  as through  transit  advice  notes  in the 
case of the Community  Transit  Regulation)  may  have  to 
be introduced  in order  to ascertain  which  Member  State 
should  be made  responsible  for  applying  penalties. 
However,  it would  be possible  on the  basis  of the 
Community  provisions  to work  out  in each  Member 
State  Community  definitions  of customs  offences  and 
uniform  penalties. 
31.17.  78 Official  Journal  of the European  Communities No C 181/35 
3.6. In opinions  on drafts  submitted  to it, the  Com-
mittee  has  repeatedly  drawn  the attention  of the Com-
mission  and  the  Council  to this  undesirable  situation 
and proposed  remedies.  Regrettably,  however,  its pro-
posals  have  fallen  on deaf  ears  so far. 
4. Proposals 
The Committee  would  basically  like  to put  forward 
concrete  and  realistic  proposals  which  can  be put  into 
effect  in accordance  with  a specific  time-table.  On this 
point  it supports  the  wishes  expressed  by the  Com-
mission  and  it also  endorses  the European  Parliament's 
recommendations. 
4.1. General  proposals 
4.1.1.  Community  texts  are  too  numerous,  too  de-
tailed  and  sometimes  contradictory.  The  authorities  and 
users  have  difficulties  with  them.  Fewer,  less  detailed 
decisions  must  be taken,  existing  texts  must  be unified 
and the adoption  of texts  still  under  discussion  must  be 
speeded  up. 
4.1.2.  The  Community  should  also  establish  uniform 
definitions  of infringements  and  a uniform  system  of 
penalties,  at least  in the customs  sphere,  without  wait-
ing for the still  hypothetical  alignment  of national  penal 
legislation.  The  present  situation  offends  common  sense. 
The fact  that  liability  varies  from  Member  State  to 
Member  State  means  that  the parties  concerned  — and 
particularly  operators  of ancillary  transport  services  and 
customs  brokers  — do not  know  the  extent  to which 
they will  be liable  in the event  of incidents  or difficul-
ties. 
4.1.3.  The  Committee  would  also  like  to see practical 
and uniform  procedures  introduced  to enable  users  to 
appeal  against  the  application  of Community  rules. 
These  rules  are very  detailed  and  disputes  are often  due 
to divergent  technical  interpretations.  National  pro-
cedures  for  lodging  appeals  often  vary  greatly  with 
regard  to their  duration  and  their  repercussions  on the 
people  involved.  And  recourse  to the European  Court  of 
Justice  — which  is always  possible  — is too  cumber-
some  a legal  procedure  for  solving  the thousand-and-
one commercial  disputes  that  arise  in the  course  of 
trade.  What  is needed,  therefore,  is a standardized 
Community-wide  procedure  for  appealing  to, say,  an 
arbitration  body  operating  along  simple,  speedy  and 
inexpensive  lines. 4.1.4.  In line  with  the  suggestions  it has  put  forward 
over  the past  10 years  (1), the Committee  proposes  the 
creation  of a single  customs  administration  committee 
to supersede  the  very  many  committees  currently  in 
existence.  This  solution  would  simplify  contacts  with 
the Customs  Advisory  Committee  set up in connection 
with  the  administration  of the  customs  union,  which 
would  thus  be able  to comment  on the  general  line 
taken  in texts  when  they  were  being  drafted  by the 
Commission  and  experts. 
4.1.5.  These  proposals  will  be fully  effective  only  if 
there  is a Community  customs  law,  which  should  con-
solidate  current  provisions  and  also  fill in the numerous 
gaps  in the  customs  union's  rules  and  regulations,  so 
that in the end  there  is a coherent  and  practical  body  of 
law. There  is enough  at stake  to warrant  the  Corn-
emission  releasing  special  funds  for  this  top-priority 
consolidation  exercise.  It is clear  that  without  such 
special  funds  the administration  of the  customs  union 
will be unable  to tackle  this  extra  work,  occupied  as it 
is with  daily  business  and  the  examination  of new 
drafts.  Bearing  this  in mind,  national  consideration 
should  be  given  to  the  temporary  secondment 
of national  officials  to the administration  of the customs 
union.  In this  way,  these  officials  would  be able  to 
familiarize  themselves  better  with  Community  rules  and 
with  errors  of interpretation  at national  level,  while 
contributing,  after  a period  of initiation,  to a better 
consolidation  of the existing  provisions.  The  consolida-
tion of the Regulations  on Community  transit  (2) shows 
just what  can  be done  and  what  advantages  are to be 
gained.  Work  must  be started  now  in finalizing  an over-
all plan  for  Community  customs  legislation  without 
waiting  until  the  texts  under  discussion  have  been 
adopted.  The  prospect  of new  members  joining  the 
Community  makes  it even  more  necessary  to act quick-
ly. New  members  would  find  it very  hard  to understand 
the present  maze  of legal  instruments  and  the  special 
measures  that  would  probably  have  to be taken  to 
satisfy  their  particular  needs  and  would  no doubt  com-
plicate  matters  further.  Finally,  the current  negotiations 
must  in no way  jeopardize  the progress  already  made  in 
this area. 
4.2. Specific  proposals 
4.2.1.  Programme  to simplify  customs  procedures 
4.2.1.1.  The  Committee  hopes  that  there  will  be an 
annual  progress  report  on the 1975  simplification  pro-
gramme,  along  the lines  of the  Commission's  progress 
report  of 1 April  1977. 
(1) Opinion  of 27 March  1968  on warehousing  procedures; 
opinion  of the same  date  on deferred  payment;  opinion  of 
29 July  1968  on inward  processing,  etc. 
(2) OJ No L 38, 9. 2. 1977. 
No C 181/36 Official  Journal  of the European  Communities 31.17.  78 
4.2.1.2.  It would  like  all the import,  transit  and  export 
documents  necessary  for transactions  between  Member 
States  to be systematically  scrutinized  with  a view  to 
their  simplification,  the aim  being  to have  one  single 
form  in the end.  It notes  with  interest  the introduction 
on 1 January  1978  of an outline  Community  export 
declaration  form.  It hopes  that  this  form  will  really  be 
used  by all the Member  States  and  that  efforts  will  con-
tinue  with  a view  to arriving  at a really  uniform  export 
form  representing  a synthesis  of genuine  Community 
needs  rather  than  an aggregation  of the  needs  of the 
individual  Member  States. 
4.2.1.3.  The  same  should  be done  about  a Community 
import  declaration  form. 
4.2.1.4.  The  Committee  would  also  like  to draw  the 
attention  of the  Commission  and  the  Council  to the 
usefulness  of the  work  being  done  by various  bodies, 
particularly  the UN  Economic  Commission  for Europe 
in Geneva  and  customs  simplification  bodies  set up by 
the Member  States,  on  the  harmonization  and 
rationalization  of international  trade  documents  and 
procedures. 
4.2.1.5.  The  Committee  would  like  the normal  com-
mercial  documents  drawn  up by firms  to be able  to be 
used  more  widely  as the  basis  for  the  procedures  in 
intra-Community  trade.  It also  maintains  that  the 
rationalization  of such  documents  and  their  alignment 
on a standard  model,  which  is what  has  already  hap-
pened  in a number  of Member  States,  would  be of con-
siderable  help  in this  respect.  Adoption  throughout  the 
Community  of the  standard  model  for  international 
invoices  is particularly  desirable. 
4.2.1.6.  The  need  for  simplification  should  not  be 
overlooked  when  new  documents  (e.g.  certificates  of 
origin)  are drawn  up.  Requirements  should  be reduced 
to the  strict  minimum,  for the supporting  data  can  be 
obtained  from  existing  documents. 
4.2.2.  Community  transit 
4.2.2.1.  The  Committee  would  point  out  that  one  of 
the original  aims  was  to gradually  transform  Com-
munity  transit  into  a system  governing  intra-Commun-
ity trade  through  use  of the transit  form  firstly  for the 
declaration  of exports  and  later  for the declaration  of 
imports.  Community  transit  has  already  led to the dis-appearance  of the free  movement  certificate  but things 
are still  moving  too  slowly  in the view  of the Commit-
tee. The  Committee  would  particularly  like  to see the 
export  declaration  form  rapidly  amalgamated  with  the 
transit  declaration  form  in a single  document. 
4.2.2.2.  The  Committee  regrets  that  Member  States 
have  made  little  use  of the  opportunities  provided  by 
the Regulation  to bring  in simplified  bilateral  import-
export  procedures  and  that  the  authorities  in question 
have  been  dragging  their  feet  here. 
4.2.2.3.  It proposes  abolition  of the  internal  transit 
guarantee.  There  could,  however,  be two  exceptions: 
— when  goods  are subject  to special  controls  or excise 
duties, 
— when  natural  or legal  persons  do not offer  sufficient 
guarantee  of integrity  in tax matters,  on the basis  of 
objective  criteria  that  will  have  to be precisely  de-
fined. 
4.2.2.4.  The  Committee  would  refer  to its proposals 
concerning  the  establishment  of a uniform  system  of 
penalties  for  customs  infringements.  Such  a system 
would  enable  transit  advice  notes  to be abolished. 
4.2.2.5.  Finally,  the  Committee  calls  for  an all-out 
effort  to eliminate  the  need  for  stops  at frontiers  by 
vehicles  carrying  goods  in Community  transit. 
4.2.3.  Origin 
The Committee  calls  for  the  unification  and  simplifi-
cation  of the various  systems  used  for defining  the ori-
gin of goods  and  the procedures  for applying  these  sys-
tems. 
4.2.4.  Statistics 
The Committee  notes  that  statistical  requirements  entail 
an enormous  amount  of work  for  users  and  the 
authorities. 
It recognizes  that  precise  statistics  are  necessary  and 
useful  not only  for Community  bodies  and  the Member 
States  but  also  for  users  themselves.  The  statistical 
formalities  can,  however,  be reduced  by unifying  codes, 
standardizing  rules  on the compilation  of statistics,  and 
harmonizing  the  various  categories  of data  included. 
Above  all, it proposes  that  the bulk  of statistical  data  on 
31. 7. 78 Official  Journal  of the European  Communities No C 181/37 
intra-Community  trade  should  be furnished  once  only 
for a given  transaction  and  that  Member  States'  special 
needs  should  be satisfied  by other  means.  It asks  the 
Commission  to draw  up  a specific  programme  of 
measures  in this  area. lers crossing  intra-Community  borders.  The  Committee 
regrets  in this  connection  that  the proposals  for increas-
ing travellers'  duty-free  allowances  have  still  not  been 
put into  effect.  It also  calls  for the rapid  adoption  of the 
Community  passport  proposal. 
4.2.5.  VAT 
4.2.5.1.  The  Committee  regrets  that  diverging  rates  of 
VAT  and  differing  methods  of collection  result  at pre-
sent in controls  on intra-Community  trade.  It expects 
that application  of the Sixth  Directive  on VAT,  which  is 
largely  concerned  with  standardization  of the  basis  of 
assessment  for  VAT,  will  improve  the  situation.  It 
points  out that  the abolition  of checks  on goods  traffic 
between  Member  States  is still  the goal  in intra-Com-
munity  trade. 
4.2.5.2.  The  Committee  nevertheless  considers  that 
trade  between  the Member  States  could  be greatly  sim-
plified  if methods  of collecting  or recording  VAT  due  on 
imported  goods  were  aligned.  Despite  the  differences 
between  national  tax systems  and  the ways  the relevant 
government  departments  are  organized,  it proposes 
introduction  of a uniform  system  for  recording  VAT 
liability  in customs  offices  at borders  within  the Com-
munity,  with  sums  due  being  entered  in the  monthly 
VAT  accounts  of the  firms  concerned.  This  system 
would  be made  available  to firms  that  import  on a regu-
lar basis  and  offer  all the requisite  guarantees. 
4.2.5.3.  The  Committee  further  proposes  that  the col-
lection  of VAT  on freight  charges  be generally  deferred 
to the  point  of final  destination  to prevent  vehicles 
being  delayed  at border  crossings.  This  is provided  for 
in Article  23 of the  Sixth  Directive.  Finally,  tax  re-
missions  on exported  goods  should  be easily  obtainable 
even  when  the goods  are exported  by private  individu-
als. 
4.2.6.  Movement  of samples,  professional  equipment, 
etc. 
The Committee  regrets  that  the movement  of samples, 
professional  equipment,  works  of art for  exhibitions, 
etc. within  the Community  is still  covered  by the ATA 
International  Convention.  It thinks  that  the  progress 
made  by the customs  union  should  have  enabled  a sim-
pler Community  system  to be introduced. 
4.2.7.  Movement  of persons  and  goods  carried  by 
private  individuals 
The progress  made  by the customs  union  should  also  be 
reflected  in the easing  of customs  restrictions  on travel-In addition,  the Commission  should  have  steps  taken  to 
reduce  the  red-tape  difficulties  sometimes  experienced 
by private  individuals  (imports,  transit  or export  of 
goods  and  vehicles,  tax  exemptions,  etc.).  Tax  har-
monization  would  overcome  most  of these  difficulties. 
5. Time-table 
5.1. The  20 years  the  Community  has  been  in exist-
ence  have  shown  that  it is always  easier  to implement 
measures  when  a precise  time-table  is laid  down.  What 
the customs  union  lacks  is a programme  to be im-
plemented  in stages  over  a given  period  of time.  The 
Committee  proposes  that  a time-table  be drawn  up for 
implementation  of both  the  measures  currently  under 
examination  and  the proposals  it has itself  put forward. 
In view  of present  economic  difficulties,  steps  should  be 
taken  as a matter  of urgency,  to ensure  that  business-
men do not  have  to exhaust  their  energies  to no useful 
purpose  in complying  with  formalities  and  overcoming 
red tape.  The  complications  that  will  arise  if new 
members  join  the EEC  add  to the urgency  of this  mat-
ter. 
The year  1980  should,  therefore,  be chosen  as the dead-
line for  implementing  the  most  important  measures, 
especially  those  which  are already  finalized  on paper,  so 
that the tariff  union  can  develop  into  a genuine  customs 
union. 
5.2. However,  the Community  must  allocate  sufficient 
manpower  and  other  resources,  to such  a programme  if 
it is to be put  into  effect.  The  administration  of the 
customs  union  should  be considered  a priority  task. 
6. Conclusion 
In conclusion,  the Committee  would  like  to pay  tribute 
to what  has  been  achieved.  The  considerable  import-
ance  of this  work  has  been  obscured  by difficulties  that 
should  be easily  overcome.  The  Committee  considers 
that solutions  will  be found  more  readily  by working 
out new,  original  and  truly  Community  measures, 
rather  than  engaging  in wearisome  (and  often  fruitless) 
efforts  to approximate  the  provisions  in force  in the 
Member  States.  It is aware  of the  limitations  of the 
No C 181/38 Official  Journal  of the European  Communities 31.17.  78 
customs  union.  Europe  will  not  be built  solely  by the 
work  of experts  or by means  of technical  measures. 
What  is needed  are economic  and  political  decisions. 
The Committee  would  stress,  however,  that  the  Com-
munity  has  made  normal  progress  whenever  there  has 
Done  at Brussels,  30 March  1978. been  a precise  time-table  for  the  development  of the 
customs  union.  Now  that  customs  duties  have  been 
abolished,  it is important,  if the Community  is to move 
stage-by-stage  towards  economic  union,  to identify 
clearly  the major  tasks  still  to be carried  out  in the cus-
toms  sphere. 
The Chairman 
of the Economic  and  Social  Committee 
Basil  de FERRANTI 
Opinion  on education  and  vocational  training  for young  workers 
The opinion  of the Committee  does  not  relate  to any  particular  text. 
A. LEGAL  BASIS  FOR  THE  OPINION 
At its 149th  plenary  session  held  on 25 and  26 May  1977  the Committee,  acting  on a pro-
posal  from  its Bureau,  decided  to deliver  an opinion  on the  abovementioned  subject  on its 
own  initiative. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its opinion  at its 157th  plenary  session,  held 
in Brussels  on 29 and  30 March  1978. 
The opinion  is published  below. 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to Article  20 (4)  of its Rules  of Pro-
cedure, 
Having  regard  to the  decision  of the  Economic  and 
Social  Committee  at its plenary  session  of 25 May  1977 
following  a proposal  from  its Bureau  on 24 May  1977 
to deliver  on its own  initiative  an opinion  on education 
and training  of young  people  in the  Member  States  of 
the European  Community, 
Having  regard  to the  decision  taken  by its Bureau  on 
24 May  1977  inviting  the Section  for Social  Questions  to 
draw  up an opinion  and  a report  on the matter, Having  regard  to the  opinion  issued  by that  Section  at 
its meeting  held  on 16 March  1978, 
Having  regard  to  the  oral  report  made  by  the 
rapporteur,  Mr Sloman, 
Having  regard  to the  discussions  at its 157th  plenary 
session,  held  on 29 and  30 March  1978  (meeting  of 30 
March  1978), 
Whereas  education  is a basic  human  right  and  is crucial 
both  for the individual  and  for the society  of which  he is 
a member; 
Whereas  educational  programmes  must  change  in re-
sponse  to changing  needs  and  circumstances;