NoC 178/4 Official Journal of the European Communities 15. 7. 82 
Opinion on the proposal for a Council Directive amending for the seventeenth time 
Directive 64/54/EEC on the approximation of the laws of the Member States concerning 
the preservatives authorized for use in foodstuffs intended for human consumption 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 330 of 17 December 1981, page 7. 
A. LEGAL BASIS FOR THE OPINION 
On 14 December 1981 the Council referred the abovementioned proposal to the 
Economic and Social Committee in accordance with Article 100 of the Treaty estab­
lishing 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 
197th plenary session held in Brussels on 28 and 29 April 1982. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the Euro­
pean Economic Community, and in particular 
Article 100 thereof, 
Having regard to the request made by the Council 
of the European Communities on 14 December 
1981 for an opinion on the proposal for a Council 
Directive amending for the seventeenth time Direc­
tive 64/54/EEC on the approximation of the laws 
of the Member States concerning the preservatives 
authorized for use in foodstuffs intended for human 
consumption, 
Having regard to the decision taken by its Bureau 
on 14 December 1981 instructing the Section for 
Protection of the Environment, Public Health and 
Consumer Affairs to draw up an opinion on the 
matter, 
Having regard to the discussions at the 68th meeting 
of this Section, held on 30 March 1982, 
Having regard to the oral report made by the rap­
porteur, Mr van Campen, 
Having regard to the discussions at its 197th plenary 
session, held on 28 and 29 April 1982, 
HAS ADOPTED THE FOLLOWING OPINION 
by a unanimous vote: 1. The Committee approves the Commission's pro­
posals for the substances referred to below but 
would like to make a few comments. 
2. It is correct that potassium bisulphite should be 
added to the list under number E 225 along with the 
other sulphites already included. 
3. The Committee will not give an opinion as to 
whether thiabendazole should be regarded as a pre­
servative or pesticide. The Commission's future rules 
on the surface treatment of fruit will deal with this 
point. The present proposal will end the uncertainty 
about its use arising from the expiry of the deadline 
of 1 July 1982. 
The Committee is prepared to accept the Commis­
sion's solution provided that the future rules on the 
surface treatment of fruit are submitted by 1 July 
1983 at the latest. This condition therefore also 
applies to the proposal to delete paragraph (c) under 
E233. 
4. The proposal to permit natamycin as a preserva­
tive for cheese and sausage is based (a) on the view 
of the Scientific Committee for Food (Reports of the 
Scientific Committee for Food, 9th series, 1979) that 
natamycin is acceptable on certain conditions, these 
conditions having been taken over in full by the 
15.7.82 Official Journal of the European Communities No C 178/5 
Commission, and (b) on the fact that it is permitted 
in most Member States (including most recently 
Germany). 
5. The Committee considers that the phrase 'at the 
time of sale' is not precise enough and should read 
'at the time of sale to the consumer'. 6. In the Dutch version the term 'volvet' must be 
amended to read: 'de korst van hels geperste kaas, 
half hard of hard'. 
Done at Brussels, 29 April 1982. 
The Chairman 
of the Economic and Social Committee 
Tomas ROSEINGRAVE 
APPENDIX 
to the opinion of the Economic and Social Committee 
The following amendments were rejected during the discussions: 
Page 2 — paragraph 4 
Add the following sentence at the end of point 4: 
'The Committee nevertheless suggests that the phrase "at a depth greater than 5 mm" be 
replaced by the phrase "in the edible part" ', 
Reasons 
A depth of 5 mm may be too much or too little depending on the product in question. The legis­
lation of at least one Member State prefers the new version, which is more in line with actual 
needs. 
Voting 
For: 5, against: 52, abstentions: 9. 
Page 2 — paragraph 5 
Delete the paragraph. 
Reason 
Controls are easier at the outset. Natamycin is also degradable and the situation can change even 
with one and the same product if it is sold to the consumer at different times. 
Voting 
For: 5, against: 58, abstentions: 9.