No C 35/12 Official Journal of the European Communities 9. 2. 84 
Reason: 
It is not clear why the self-employed should be covered to any extent by the Directive. 
Article 119, from which the draft Directive stems, is concerned with wages or salaries which a 
worker receives 'in respect of his employment from his employer'. There is no employer/ 
employee relationship in the case of the self-employed, and therefore their pension arrangements 
should be excluded from this Directive. 
Voting on the amendment: 
For: 38. Against: 63. Abstentions: 4. 
Page 9, point 2.6 
Substitute for second sentence: 
'It is suggested that the implementation date should be not less than five years from its noti­
fication to the Member States.' 
Reason: 
This is in keeping with the timetable for the corresponding Directive relating to statutory schemes 
(Council Directive of 19 December 1978), and is considered the minimum practical timetable for 
necessary full consultation with employee representatives and trustees, and for necessary revision 
of schemes' rules, and approval of changes by supervisory authorities. 
Voting on the amendment: 
For: 42. Against: 62. Abstentions: 8. 
Opinion on the proposal for a Council Decision on the comparability of vocational 
training qualifications between the Member States of the European Community 
(84/C 35/05) 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 264 of 4 October 1983, page 5. 
A. LEGAL BASIS FOR THE OPINION 
On 30 September 1983 the Council referred the abovementioned proposal to the 
Economic and Social Committee in accordance with Article 128 of the Treaty estab­
lishing the European Economic Community. 
Procedure 
The Section adopted its opinion by 24 votes to one, with one abstention, at its 166th 
meeting, held on 10 November 1983. 
9.2.84 Official Journal of the European Communities No C 35/13 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Committee adopted its Opinion with no votes against and five abstentions during 
its 213th plenary session held on 14 and 15 December 1983. 
The full text of the opinion is as follows: 
1. The Commission proposal for a Council Deci­
sion on the comparability of vocational training 
qualifications between the Member States of the 
European Community (COM(83) 482 final) is based 
on the Council Decision of 2 April 1983 laying 
down general principles for implementing a com­
mon vocational training policy in accordance with 
Article 128 of the EEC Treaty. According to the 
eighth principle, a common vocational training 
policy must be so framed as to enable levels of 
training to be harmonized progressively. 
2. The Committee recognizes the enormous diffi­
culties standing in the way of harmonization of 
training levels and thus full comparability and tran­
sparency of the systems of qualifications in the 
Member States. Comparison of these qualitative 
data requires first of all the establishment of a com­
mon frame of reference like the structure of five 
training qualifications that has been laid down: 
1. semi-skilled; 
2. skilled; 
3. technician; 
4. higher technician; 
5. full university. 
Work on filling in this framework by comparative 
listing of the admission requirements for the indivi­
dual training levels has also been taken in hand, but 
the results must be made more accessible and more 
useful to the competent bodies at national level, if 
the goal of better comparability of diplomas, certifi­
cates and other evidence of qualifications between 
the Member States is to be achieved. 
The Committee therefore expressly welcomes the 
Commission's initiative in the form of the present 
proposal for a Decision, even though it represents 
only a first milestone on the path to the goal set by 
the Council in its Decision of 2 April 1963. 
3. The Committee takes the view that further 
efforts are needed in this area in order to attain complete freedom of movement through transpar­
ency and effective coordination of the labour mar­
kets. A sine qua non here is the Member States' will 
to give full support to this Community initiative. 
The vocational training systems of the Member 
States will have to converge if one is to achieve har­
monization of the standards required for success in 
final examinations, a precondition for the mutual 
recognition of certificates and similar documents 
confirming completion of vocational training, which 
was called for by the Council in its resolution of 
6 June 1974. Here the Committee expressly endorses 
the Commission's view that the diversity of training 
systems in the Community is not to be regarded as a 
disadvantage, as long as the requirements of econo­
mic and social progress are met. This does not 
mean, however, that the qualification objectives at 
the various training levels in the Member States 
could not be better coordinated. 
Such action could be prepared through the closer 
cooperation on the basis of the present Decision. 
Any mental or formal reservations in individual 
Member States standing in the way of mutual recog­
nition must be overcome. Steps must also be taken 
to promote bilateral and multilateral meetings and 
initiatives, exchanges of experience and a compari­
son of the existing possibilities and the results 
obtained, with a view to making further progress in 
the alignment of qualifications and vocational train­
ing and instruction methods. 
4. The Committee agrees with the Commission 
that a Council Decision addressed to the Member 
States is at present the most suitable form of initia­
tive. If this Decision is to be effective, however, the 
Commission itself and the Member States must do 
everything in their power to implement it. Checks 
should be made at regular intervals to determine 
whether the necessary progress can be achieved on 
this legal basis. This should be done through evalua­
tion of the reports to be submitted by the Member 
States every three years, under the draft Decision. 
These reports should at all events indicate how 
recognized certificates of other Member States are 
registered, as well as which and how many qualifi-
No C 35/14 Official Journal of the European Communities 9.2.84 
cations have already been recognized. The Commis­
sion should also explain once more how it envisages 
these reports being utilized in the further work 
towards the objectives. 
5. The Committee endorses the procedure pro­
posed by the Commission, viz.: 
— selection of the relevant occupations, 
— drawing-up of job descriptions for these occu­
pations, 
— matching of the recognized vocational training 
qualifications with these job descriptions, 
— establishment of comparative tables of occupa­
tional titles and corresponding vocational train­
ing qualifications, with reference to the Com­
munity structure of training levels, 
— publication in the Official Journal of the Euro­
pean Communities, 
— dissemination of information to all appropriate 
bodies. 
Done at Brussels, 14 December 1983. 
Francis CEYRAC 
Opinion on the 
— proposal for a Council Directive on the approximation of the laws of the Member 
States concerning the safety of toys 
— proposal for a Council Directive on common technical safety standards concerning 
the physical and mechanical properties of toys 
— proposal for a Council Directive on common mechanical safety standards concerning 
the flammability of toys 
(84/C 35/06) 
The text referred to the Committee has been published in Official Journal of the Euro­
pean Communities No C 203 of 29 July 1983, page 1. 
A. LEGAL BASIS FOR THE OPINION 
On 4 July 1983 the Council referred the abovementioned proposal to the Economic 
and Social Committee in accordance with Article 100 of the Treaty establishing the 
European Economic Community. As regards the selection of the relevant occupations 
or groups of occupations, attention should be 
focused first of all on those occupations or groups 
of occupations which offer special prospects for the 
persons in question in the light of technological 
change. 
Account should be taken of the results of relevant 
work by the European Centre for the Development 
of Vocational Training (Cedefop). 
6. To sum up, the Committee thinks that the Com­
mission is setting about a task of importance for the 
integration of the Community. Given the very div­
erse vocational training systems and structures that 
have evolved over time in the countries and regions 
of the Community, great caution is needed however, 
in pursuing the objective of harmonization of train­
ing levels, if problems such as harmonization down­
wards are to be avoided. Although the path will be 
neither short nor easy, the necessary steps must be 
taken to accelerate this process which is so impor­
tant for the present and the future course of Euro­
pean integration. 
The Chairman 
of the Economic and Social Committee