No C 252/20 Official Journal of the European Communities 27. 9. 82 
specialists needed to keep schemes going deserve 
particular attention; the lack of special attention to 
these features leads to costly failures; 
(b) on a general level, adequate training must be 
organized before projects are launched, to ensure 
better results. However, it must be ensured that the 
effect is permanent. 
11. In conclusion, the Committee endorses the 
Commission's assessment: 
(a) of the value of promoting small-scale proj ects which, 
more than other sorts, allow the close participation 
of the people concerned; 
(b) of the importance of training, and of progress in this 
area to ensure that training is of permanent benefit to 
projects; (c) of information. The Committee shares the 
Commission's appreciation of the value of such 
publications as the ACP-EEC Courrier. 
12. In this context, the Committee stresses the value of 
the activity of the Joint Committee of the ACP-EEC 
Consultative Assembly, which with the help of the ESC 
regularly organizes contact between the trade 
organizations of the EEC and the ACP States. The 
Committee hopes that the representation of the social and 
economic groups of the ACP States will be expanded in 
order to start a real dialogue between equal partners. The 
Committee feels that this will (a) make Europeans better 
aware of their responsibilities towards the ACP States and 
(b) allow economic and social groups of the latter to 
discharge better their responsibilities towards the 
development of their countries, and thus enable them to 
extend their role in economic decision-making in their 
countries. 
Done at Brussels, 30 June 1982. 
The Chairman 
of the 
Economic and Social Committee 
Tomas ROSEINGRAVE 
Opinion on the regions of Europe - first periodic report on the social and economic situation 
of the regions of the Community 
The text referred to the Committee has not yet been published in the Official Journal of the 
European Communities. 
A. LEGAL BASIS FOR THE OPINION 
On 30 September 1981 the Commission referred 'new regional policy guidelines and priorities' 
to the Economic and Social Committee in accordance with Article 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 199th 
plenary session held in Brussels on 30 June and 1 July 1982. 
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 Article 198 
thereof, 
Having regard to the request made by the Commission of 
the'European Communities on 30 September 1981 for an 
opinion on 'new regional policy guidelines and 
priorities', Having regard to the decision of its Bureau, authorizing 
the Section for Regional Development to prepare an 
opinion on the subject, 
Having regard to the subsequent decision of the Bureau 
under Article 20, subparagraph 3, on 27 October 1981, 
to call upon the Section to give further consideration to 
the abovementioned matter by drawing up an opinion on 
'the periodic report on the economic and social situation 
of the regions', 
27. 9. 82 Official Journal of the European Communities No C 252/21 
Having regard to the opinion of the Section for Regional 
Development adopted on 11 June 1982, 
Having regard to the written report presented by the 
rapporteur, Mr Loebl, 
Having regard to the discussions at the 199th plenary 
session of 30 June and 1 July 1982, 
HAS ADOPTED THE FOLLOWING OPINION 
by a large majority, with 4 against and 4 abstentions: 
1. Introduction 
1.1. The periodic reports on the economic and social 
situation in the regions of the European Community were 
intended by the Council to be the basis on which 
European regional policies were to be formulated and 
coordinated with national regional policies. 
1.1.2. The first periodic report has indicated an 
increase in the divergence of economic performance 
between the more prosperous and the less-favoured 
regions. At the same time, the relatively limited resources 
are pointing towards a concentration on those countries 
which contain the regions with the most serious 
problems. 
1.1.3. This policy has been reflected in the proposed 
changes in the regulation of the European Regional 
Development Fund (ERDF), according to which regions 
will be included or excluded from the quota section of the 
Fund in accordance with new criteria to be based on the 
findings of the periodic reports. Inclusion or exclusion 
may have even wider consequences. 
1.2. The Committee agrees that the periodic report 
must provide an evaluation of the situation in the regions 
which will, in the first place, point towards appropriate 
European regional development policies. 
1.3. The first report concentrated on identifying the 
regions with the most serious problems and it attempted 
to grade such regions in terms of the severity of these 
problems. This had never been attempted before and 
therefore represents a commendable effort. Although the 
report has considerable limitations, well appreciated both 
by the Commission and by the Regional Policy 
Committee, it nonetheless allows identification of the 
major problem regions, and can thus be said to have 
succeeded in its objective. 
1.3.1. In the opinion of the Committee, however, 
future periodic reports must go further. In particular, they must provide information which will lead to 
conclusions as to where - within regions with the 
greatest difficulties - Community intervention is 
required. Furthermore, future reports should facilitate 
the appraisal of development programmes for national 
and Community action. 
1.4. A meaningful and consistent analysis of the 
economic and social situation in the regions of a single 
member country is difficult enough, particularly in a 
period of rapid change. Such an analysis covering the 
whole Community is an extraordinarily difficult matter, 
given the wide variety of definitions of regions, historic 
backgrounds, economic and socio-cultural 
circumstances, social policies and methods of defining, 
collecting and computing information. 
1.4.1. It must be accepted from the outset, therefore, 
that periodic reports cannot be expected to be ideal in 
form or content. The Committee believes, however, that 
successive reports should be improved in the light of 
experience gained and by acceptance of the results of 
research which is going on in most Member countries. It is 
the object of this opinion to make proposals for such 
improvements. 
1.5. In arriving at its opinion, the Committee has 
borne in mind two factors in particular: 
— that increasingly difficult regional problems will have 
to be solved under conditions of overall budgetary 
stringency, 
— that there is a general acceptance of the fact that the 
regions will have to depend more on indigenous 
development than in the past. 
1.6. Advice has been taken from experts and public 
agencies in several Member countries. These are listed in 
the report. There are no unanimous views on a number of 
aspects of the measurement of the economic performance 
of the regions. Nevertheless, the Committee has noted 
that there exists a considerable consensus of opinion on 
the more urgently-needed changes and improvements. 
These will require new definitions and changes in the 
collecting and computing of information, as well as some 
harmonization of these activities within the Community. 
Without these, the Committee does not believe it possible 
for regional policies to be properly conceived or 
managed, either at the Community, or, indeed, at the 
national level. In addition, the Committee makes 
proposals for a better presentation of the data. 
1.7. The main objective of periodic reports is to 
examine the situation in the regions in order to help 
economic convergence, particularly as regards 
employment policy. Such policies, however, have to be 
implemented now and in the foreseeable future against a 
background of overall budgetary stringency, both at the 
national and at the Community levels. The Commission 
and the Member governments have, therefore, a common 
interest in the greater clarity and accuracy of future 
No C 252/22 " Official Journal of the European Communities 27. 9. 82 
periodic reports if policies are to be more appropriate and 
resources to be concentrated where they are most needed. 
This common interest should ensure the collaboration of 
Member governments with the Commission in 
implementing the not inconsiderable changes proposed in 
this opinion. 
1.8. The Committee's comments and proposals in this 
opinion only concern those aspects of the first periodic 
report which require the most pressing consideration. 
There rnay be others, which will be dealt with in parts of 
future opinions. 
2. Definition of regions 
2.1. The significance of the data on all the indicators 
used in describing the economic and social situation in 
particular regions - and the conclusions which may be 
drawn from the analysis of such data - depend markedly 
on the delineation of such regions. The Committee 
believes that an improvement in the definitions must be 
the first priority. 
2.2. The Committee does not propose to make an 
appraisal of the definitions used in the first periodic 
report. These Level II definitions corresponded to those 
used by Member governments at the time. The 
Commission was aware that the use of Level II regions 
would, at best, provide rough information only, which in 
some instances produced such glaring distortions that the 
lack of significance had to be pointed out. It was an 
advantage of using these definitions that, the data was 
generally available, something that could not have been 
assumed for any other definitions. 
2.3. One of the consequences of the differences in 
national definition of Level II regions was that there were 
great differences in the size of regions - and in their 
population - as between Member countries. Excluding 
Ireland and Luxembourg, each of which was treated as a 
single region, and Denmark with three regions, the 
number of Level II regions varied from 11 (in the UK) to 
30 (in the Federal Republic of Germany). The Committee 
has much sympathy with those parts of large, relatively 
stronger Level II regions which have serious problems but 
which were 'lost' within such regions. While 
understanding that Level II will still be the basis for 
analysis, the Committee is not surprised that the 
Commission has indicated that it will take into account 
Level HI information, although it finds it difficult to see 
how this-can be done in a uniform manner. 
2.4. While the collection of data from administrative 
units has posed the least practical difficulties up to now, 
the Committee believes that the use of such administrative 
entities is frequently unsatisfactory for the purpose of 
analyzing their economic and social situation in the 
context of regional development policies. The question of 
implementation is another matter, to which reference will be made further on. A more rational delineation is needed 
not only to ensure a proper identification of the regions, 
with the most serious problems from the Community 
point of view, but also for the purposes of more effective 
national regional policies. 
2.4.1. The Committee believes, therefore, that for 
diagnostic purposes, the regional data must be based on 
some functional considerations and it notes with 
satisfaction that the search for such data is very advanced 
in a number of Member countries. There are, 
nevertheless, different approaches to this, some of which 
are outlined in the report. The view of the Committee is 
that national govenments should, in course of time, agree 
to re-designate regions not only to make better economic 
and statistical sense, but also in terms of entities to which 
policies can be more effectively applied. It is appreciated 
nevertheless, that this may take some time to 
accomplish. 
2.4.2. Given this last consideration, the Committee 
has come to the conclusion that it cannot recommend a 
single definition to apply throughout the Community. 
The Committee sees no merit in a single definition merely 
to satisfy statistical tidiness. 
2.4.3. The Committee therefore proposes, for 
analysis and policy purposes two separate definitions of 
functional regions, to be applied where appropriate: 
— the labour market regions, 
— the homogeneous policy regions. 
2.5. Labour market regions 
2.5.1. The use of labour market (or travel to work) 
regions does lead to relatively small geographical entities. 
For some purposes of regional development, for example 
the development of infrastructure, these may appear to be 
too small. Nevertheless, since unemployment is now seen 
to be by far the most serious problem facing the countries 
of the Community, the Committee believes that in those 
areas of the Community where there are relatively dense 
populations, where the pattern of travelling to work is 
identifiable, where there exist metropolitan areas with an 
adequate, if not ideal infrastructure, labour market 
regions define with more relevance those entities in which 
people seek work and where the regional problem is most 
closely defined than any other. Furthermore, since the 
Commission - and many Member governments — now 
see indigenous development to present the most likely 
opportunities for the less-favoured regions, the local 
industrial milieu - and such a milieu is formed in labour 
market regions - must play an important role in this kind 
of development. This will permit the greatest possible 
'personal' multiplier effect - so essential for indigenous 
development, even if such regions may not be the 
27. 9. 82 Official Journal of the European Communities No C 252/23 
optimum size for conventional 'regional' multiplier 
policies. 
2.5.2. It is to be noted that the labour market regions 
often cut across administrative regions, sometimes at 
several levels, but this is merely a confirmation that 
economic developments - and problems - are no 
respecters of historical boundaries. For analysis and 
policy purposes, this must be accepted. There is no 
reason, however, why the implementation of regional 
development policies in labour market regions cannot be 
shared by existing administrative entities. 
2.6. Homogeneous policy regions 
2.6.1. While labour markets form natural compact 
functional regions, the majority of the regions of the 
Community - although not containing more than a 
minority of the population - are of a type where labour 
markets have little or no meaning. These include 
agricultural, mountain, border, cross-border and 
under-developed areas. 
2.6.2. The Committee believes that in these cases, 
Level III - or even Level IV - regions should be 
aggregated into new regions requiring the same kind of 
development policies. (This does not mean that similar 
types of regions require necessarily the same kind of 
development policies.) The Committee notes that 
proposals to this effect are already available for the 
Mezzogiorno, under which the 34 provinces of the eight 
Level II regions have been found to require seven quite 
different development policies, and are to be aggregated 
accordingly. Such aggregations must, of course, take into 
account existing solidarities between the poorer and more 
prosperous parts and linkages which function well. 
2.7. The Committee suggests that the definition of 
new functional regions must be made by the Commission 
on the basis of its analyses in conjunction with the 
Member States. The Committee believes that the 
following considerations are very important in arriving at 
definitions. 
2.7.1. Labour market regions: these should 
encompass travel to work distances for particular labour 
markets (see report). Some adjustments for achieving 
units which facilitate the colection of statsistical data -
or where labour market data are not yet available -
should be accepted. The important consideration must be 
that significant populations — by Community standards 
— are involved in each case. 
2.7.2. Homogeneous policy regions: Level III or even 
Level IV administrative areas should be aggregated into 
regions where similar kinds of development policies can 
be applied. The important consideration here is that such regions should be significant in extent, if not in 
population, and their aggregation should be made on 
similar, agreed Community principles. 
2.7.3. The Committee's insistence on significant 
populations (in the case of labour markets) and on 
significant size (in the case of homogeneous policy 
regions) aims at avoiding 'black spot' policies, which 
cannot form part of European regional development 
politices, although they may be part of national 
policies. 
2.8. It was one of the criticisms of the use of Level II 
regions that their number differed too greatly between 
Member countries and that quite different orders of 
populations were involved. 
2.8.1. The Committee cannot predict the effect of its 
proposals in this respect. The number of labour market 
regions will be relatively large and so will their 
populations. So far as homogeneous policy regions are 
concerned, however, aggregation in accordance with the 
principles outlined may, in fact, result in a reduction in 
the number compared with Level II regions. 
Nevertheless, an overall increase in the number of 
regions, perhaps a considerable increase, is to be expected 
by comparison with the first periodic report. 
2.8.2. But whatever the number of regions, the 
Committee believes that the real importance in the 
definition of functional regions lies in the greater 
precision in the delineation of entities where problems of 
employment, long-standing industrial decline or 
under-develolpment have to be solved. 
2.9. It is likely that the new definitions will result in 
highlighting in certain regions problems which are not 
regional but sectoral. It will be the task of the 
Commission to agree with Member governments which 
of the regions will be subject to regional aid, even if the 
quota-free section of the ERDF can now be applied to 
regions with sectoral problems. 
2.10. In the light of the proposed changes in 
definitions, the Committee recognizes the need to collect 
statistics which correspond more closely to functional 
regions, for diagnostic and policy purposes. The 
Commission and Member governments should provide 
the necessary means to achieve this objective. 
2.11. The Committee, finally, notes that experts see 
another advantage in the definition of functional regions 
- provided the statistical exercises are authorized by 
Member governments - in that the data on some, if not 
all, indicators could in principle be more accurate. The 
data on GDP, for example, could be more representative 
of the relative prosperity of a region, if the errors in 
No C 252/24 Official Journal of the European Communities 27. 9. 82 
attribution as between those who work and those who 
live in a particular region disappear. 
2.12. Given that the information on the new regions 
cannot be available in time for the next periodic report 
(mid-1983), the question arises, what definitions of 
regions should be used? While the Committee has no 
strong views on this matter, it sees some merit in using the 
same definitions as in the first periodic report. In this way, 
the bases - however unsatisfactory - of the first and 
second periodic reports will at least be comparable and, 
as the Committee hopes, that the new definitions it has 
proposed can be applied in the third report (January 
1986), there would be only one change of base rather than 
two. 
3. GDP as an indicator of economic performance 
3.1. Since GDP together with unemployment, is the 
main indicator used in the first periodic report, the 
Committee feels it necessary to comment. 
3.2. Few of the experts consulted were entirely 
satisfied with this indicator, and some rejected it 
altogether. 
3.3. The Committee is aware of the progress achieved 
in recent years by the Statistical Office of the European 
Communities (SOEC) in association with national 
statistical offices in harmonizing the basis of collection 
and computation of regional GDP. Nevertheless, there 
remain differences - the importance of which the 
Committee is unable to judge - which prevent identical 
results being obtained in different Member countries, 
even using the same date. The opinion has already 
referred to the difficulty of attribution in areas where 
there is significant commuting. In some countries, GDP 
due to services is not measured but attributed simply on a 
population basis. Errors occur, in addition, from the 
impossibility of estimating the GDP stemming from the 
black economy. 
3.4. The errors in GDP are not uniformly spread 
throughout any Member country and errors in particular 
regions are unknown. For example, in agricultural areas 
and in areas where public services dominate, GDP is 
generally under-estimated. In areas where there are 
mainly private services and manufacture, GDP is usually 
over-estimated, particularly in manufacturing sectors where taxes on consumsption are significant, for example 
in oil refining and tobacco. Experts have advised the 
Committee that accuracies of better than ± 15 % are 
unlikely within any one Member country and if errors 
between countries are conservatively assumed to add a 
further ± 5 %, we would expect possible errors to be at 
least ± 20 %. These shortcomings must be borne in 
mind in any analysis of relative regional difficulties. 
3.5. Many different suggestions were made for 
replacing GDP as a key indicator (see report). Given the 
limited judgments which the Committee is capable of 
making, it does not appear that the theoretical work on 
most of these is sufficiently advanced for their adoption. 
When this is not the case, there are practical reasons 
which prevent their use. One advantage of the GDP 
indicator in the regional development context is that it 
makes it possible to exclude transfer payments. While 
such payments improve the standard of living of the 
people in the assisted regions, they may hide the regional 
problem to the extent that such payments are significant. 
Alternatively, a reduction in transfer payments may hide 
a small but significant improvement in the regional 
GDP. 
3.6. While accepting therefore the continued use of 
GDP as a key indicator, the Committee nonetheless looks 
to the statistical offices of Member countries to improve 
the quality of the GDP information, and to the Statistical 
Office of the European Communities to achieve even 
greater harmonization in the collection and computation 
of national GDPs. The Committee notes that the SOEC 
has called a meeting later this year at which all. the 
national statistical offices will take part. The Committee 
hopes that its concerns will be noted and suggests that the 
Commission publish a review of the methods of GDP 
collection in Member countries in a form suitable for 
non-specialists. 
3.7. The Committee draws attention to a problem 
arising from the use of the GDP indicator in the context of 
regional development policies, or, more specifically, of 
employment in the less-favoured regions: those activities 
leading to a relatively high GDP per unit of population 
tend, in many cases, to be capital-intensive (with the 
exception of service industries in metropolitan regions), 
while those leading to a relatively lower GDP tend to be 
labour-intensive. While all industries must be, or become, 
more competitive to survive the competition from outside 
the Community, the less-favoured regions require 
labour-intensive industries, that is, industries with a 
relatively low GDP. This must be borne in mind when 
looking at GDP in a problem region. This problem may 
also be put another way: as a result of the introduction of 
new technologies, a region may well show a rapid 
increase in GDP, but with unemployment rates initially 
rising at the same time. This poses the problem of the 
less-favoured industrial regions in its starkest form. 
27. 9. 82 Official Journal of the European Communities No C 252/25 
4. Unemployment 
4.1. Since unemployment is seen as the most serious 
problem in the less-favoured regions of the Community, 
the measurement of this indicator is of the greatest 
importance. 
4.2. It is, however, a much more difficult indicator to 
establish than appears at first glance. The differences 
between the social policies of Member governments lead 
to different definitions of unemployment. Furthermore, 
some countries have compulsory military service, while 
others have not. The Committee has to accept the 
assurances given by the SOEC that the differences have 
been compensated for as far as possible in establishing 
Community tables. 
4.3. Another complicating factor is to be found in the 
differences in activity rates. This variation affects the 
comparability of unemployment between different 
regions. In the less-favoured regions, and in particular in 
under-developed regions, activity rates are generally 
lower; this applies particularly to females. Female activity 
rates also vary in highly developed regions for social 
reasons: in the Netherlands, for example, it is particularly 
low. While the first periodic report has produced data on 
activity rates, it has not weighted unemployment figures 
to take account of low activity rates. As an aside, the 
Committee has noted that very high activity rates in 
certain areas may also indicate serious economic 
difficulties e.g. low wages and low GDP. 
4.4. The Committee also suggests that an attempt 
should be made to distinguish between the 
unemployment caused by demand deficiency and by an 
excess of labour supply. This distinction has significant 
implications for regional development policies. 
Furthermore, the Committee would like to see a 
refinement in the information on occupational structure 
and, in particular, on the percentage of employees in 
declining and growth industries (see also 6 below). 
4.5. In a period of rapid change, what matters as 
much as the unemployment rate is the level of vacancies. 
If this increases without any drop in the unemployment 
rate for example, it indicates an imbalance in the labour 
market and points to the urgency for local retraining 
schemes. The Committee was impressed by the use of a 
'labour reserve coefficent' and recommends that the use of 
this coefficient (see report), together with the 
unemployment figures, should be investigated by the 
Commission, as it may give a better guide to regional 
development policies than the unemployment figures 
alone. 
4.6. Unemployment and GDP taken together may in 
some instances lead to a mistaken diagnosis. It has been 
suggested that a control parameter be used based on the 
net migration rate (details in the report). Since this method has revealed several instances of mistaken 
diagnosis, the Committee recommends that the 
Commission examine its more general application. 
4.7. While in a rapidly changing situation it is vital 
that all data for periodic reports are as recent as possible, 
the Committee has been persuaded that some indicators, 
for example GDP, will always be one or two years out of 
date. Unemployment figures, by contrast, are collected 
on a monthly basis in most countries and figures used by 
future periodic reports should not therefore be more than 
three to six months old (see also 6.2). 
4.8. The Committee agrees to the use of longer-term 
unemployment figures, together with GDP, as the main 
indicator assisting the identification of problem areas. 
5. Other indicators 
5.1. Apart from GDP and unemployment, this 
opinion deals with some other indicators (see 6 to 9 
below). 
5.2. In addition, useful suggestions have been made 
by the experts consulted and these will be found in the 
report. 
5.3. Apart from GDP and unemployment, the first 
periodic report took account of certain other indicators in 
arriving at relative regional difficulties. It would go too 
far to comment on all of them, but the Committee would 
like the Commission to examine whether some of the 
indicators proposed in this opinion and in the report 
might not usefully be employed in the preparation of the 
next periodic report. 
6. Dynamic approach to indicators 
6.1. In the first periodic report, reliance was placed 
with the exception of the demographic indicators (and 
with a diagram showing the evolution of GDP from 1970 
to 1977) on two key dates: 1970 and 1977/78. It would, 
of course, have been interesting to see the effect of the 
establishment of the ERDF in 1974. 
6.2. Apart from this, the advice which the Committee 
has had from almost all the experts consulted is that 
dynamic data are required if future reports are to be 
significant in formulating European regional policies. 
This would have been important in times of stability or 
growth. In the present rapidly changing situation in the 
Community, the Committee considers it absolutely 
essential. 
6.3. The key indicators should be recorded (in 
graplhical form, see also 10) for a historic period of five 
No C 252/26 Official Journal of the European Communities 27. 9. 82 
years at least, and a projection of data for a further period 
of five years must be attempted, at least for the labour 
market. This must take into consideration the labour 
balance arising from demographic information, 
migration, job creation and job losses, among other 
things. It will require studies, on a regional basis, of 
declining and growth industries. Some effort must be 
made to predict GDP as well, particularly bearing in mind 
that historic GDP and unemployment figures may be one 
or two years apart (see 4.7 above). Regions of small 
population density and very low activity will present 
special difficulties. Dynamic information will be 
particularly suitable for graphical representation (see 
also 10). 
7. Qualitative information 
7.1. While a previous report on the regions associated 
with the name of Commissioner Thomson was, in the 
Committee's view, too qualitative in approach, the first 
periodic report goes too far in the opposite direction. 
Statistical information on the macro-economic indicators 
alone cannot describe the problems and the opportunities 
of particular regions. Such information does not indicate, 
either, why things are as they are. 
7.2. The first peiodic report gave no information on 
educational facilities available, on climate, fertility of 
soil, opportunities for tourist development, the 
socio-cultural climate for enterprise, etc. Nor did the first 
report describe the adequacy of infrastructure, a matter 
already commented on by the Regional Policy Committee 
in a statement attached to the first report. Yet these 
factors are of great importance when formulating policies 
and, in a simplified form, they must form part of any 
meaningful analysis of relative regional difficulties. These 
factors may be quantified to some extent by using, say, 
four grades of adequacy (or inadequacy). 
7.3. It has occurred to the Committee that this part of 
future reports might perhaps be written by the authority 
or authorities responsible for the newly defined regions, 
subject to guidelines from the Commission. These 
authorities are likely to have a better detailed knowledge 
of their region than almost anyone else. It would also have 
the important psychological merit that it would give these 
authorities an opportunity for direct contact with the 
Commission, a contact which the Committee has 
advocated strongly in the past (x). 
8. Input of resources 
8.1. There is one indicator which has been left out 
from the first periodic report which appears crucial to the 
(!) OJ No C 53, 3. 3. 1980, p. 61. Committee: the direct investment in regional policy 
instruments both by the Community and by the national 
governments. The Committee suggests that this 
information should be provided for a period going back 
to the start of the ERDF in 1974. 
8.2. The information proposed by the Committee 
would answer the question of whether investment in 
regional development is increasing or, at least, not 
declining, when Community and national aids are 
added. 
8.3. Reporting on the results of past policies without 
giving details of the funds employed does not, in the 
Committee's view, lead to any significant conclusions. 
The Committee does not see why a report on the regions 
should be expected to be complete without such 
information. 
9. The Community average and dynamic trends 
9.1. The first periodic report established the concept 
of a Community average for the main indicators, suitably 
combined. This has assumed great importance, if only 
because an arbitrary level below this average will, 
according to the proposed revision of the ERDF 
Regulation, determine eligibility of regions for finance 
under the quota section of the ERDF. 
9.2. The Committee can see some usefulness in the 
concept of the Community average as a technical 
measure, but it fears that it is too simplistic for regional 
policy purposes. 
9.3. The Committee has expressed itself in favour of a 
dynamic approach to indicators. While this will produce 
a more reliable picture of the situation in the regions, it is 
difficult to see how the concept of the average can be 
accommodated for within this approach. 
9.4. It would be useful, for example, to be able to take 
account of the fact that the changes shown by the dynamic 
information may not be the same for all the indicators. 
Furthermore, it should be possible to provide different 
weighting for different policy options. The Committee 
fears that this may not be compatible with the 
Community average computation and, therefore, may 
prevent a more flexible Community regional policy. 
9.5. Since some of the more prosperous regions have 
recently declined relatively more than many of the poorer 
regions, the concept of the average could also lead to false 
conclusions of increasing convergence, although the 
conditions in the poorer regions have become more 
serious in absolute terms. 
27. 9. 82 Official Journal of the European Communities No C 252/27 
9.6. The Committee believes, therefore, that the 
Community average alone should not determine 
inclusion or exclusion in the quota section of the ERDF. 
Additional criteria must be developed. Useful 
information can be obtained, for example, from rates of 
change of dynamic information, regional structure and 
percentage changes in growth and income (in relation to 
equivalent national percentage changes) (see report for 
discussion on the latter). 
10. Presentation of data 
10.1. In the first report, it was difficult to establish a 
picture of the situation in a particular region except after a 
search through many chapters of descriptive text, tables, 
maps, diagrams and annexes. 10.2. The increase in the number of regions for 
analytical purposes resulting from our proposals will 
require a reconsideration of the presentation in any case. 
The Committee believes that all the data relating to a 
particular region should be recorded on two sides of a 
single sheet. This will involve a great deal of compression 
and the use of graphical rather than descriptive 
information. Before this can be done it has to be decided 
which items of information to include. The Committee 
believes that a 'taxonomy' of a region can and should be 
developed which can be expressed in the space 
suggested. 
10.3. The increase in the number of regions will make 
future reports more formidable undertakings, whatever 
form of presentation will be adopted, but this strengthens 
the Committee's view on presentation. 
Done at Brussels, 30 June 1982. 
The Chairman 
of the 
Economic and Social Committee 
Tomas ROSEINGRAVE 
APPENDIX 
to the opinion of the Economic and Social Committee 
Defeated amendments 
The following amendments, tabled in accordance with the Rules of Procedure, were rejected during 
plenary session discussions: 
Page 4, first indent 
Add the following after 'overall budgetary stringency': 
'about which the Committee has frequently expressed its reservations;' 
Reason 
The recession is no excuse for cutting expenditure on regional policy which is expressly designed to remedy 
the effects of recession. 
Voting 
For: 11, Against: 29, Abstentions: 25. 
Page 6, point 2.4 
Add the following to the end of the last paragraph: 
'At the same time it is acknowledged that the existing regional and sub-regional administrative bodies 
have an essential role to play in data-collection and the implementation of regional policy.' 
Reason 
The amendment is self-explanatory. 
No C 252/28 Official Journal of the European Communities 27. 9. 82 
Voting 
For: 22, Against: 23, Abstentions: 21. 
Page 9, point 2.7 
Delete first sentence and substitute: 
'The Section believes that the regrouping by the Commission into functional regions of the results of its 
analysis should take into account the following considerations'. 
Reason 
It is preferable not to be too specific on the Community decision-making process. 
Voting 
For: 8, Against: 60, Abstentions: 10. 
Page 12, point 2.12 
Rewrite first line as follows: 
'. . . information on and the re-defining of the regions cannot . . .'. 
Insert after second sentence: 
'Notwithstanding the Committee's reservations in paragraph 2.3 above, nevertheless Level II 
information should wherever possible be supplemented and updated by the collection and aggregation 
of Level III information, the use of which should enable the preliminary analysis of the state and 
condition of Level II regions to be reworked and adjustments made as necessary'. 
Reason 
The quickest and safest way to improve the information for the second report, is to superimpose Level HI 
and IV statistics as and when available so that, with the benefit of this overlay, one can see, at a glance, 
which part of the Level II regions are above the Community average and which below. 
Voting 
For: 10, Against: 63, Abstentions: 16. 
Page 14, point 3.4 
Delete last two sentences and substitute: 
'Experts warn of significant percentage errors in each Member State which will be further compounded 
on Community collation and this shortcoming must be borne in mind in the analysis of relative regional 
difficulties'. 
Reason 
The amended text would be shorter and not as openly aggressive towards the periodic report. 
Voting 
For: 7, Against: 62, Abstentions: 11. 
Official Journal of the European Communities No C 252/29 
Page 21, points 9.1 and 9.2 
Insert at the end of 9.1 and in place of 9.2 the following text: 
'In this respect the Committee calls attention to its opinion of 29 April 1982 (point 8.3*) on the amending 
Regulation for the ERDF in which it stressed "the need constantly to update the statistical data which 
alone can justify the admission or exclusion, not of a Member State, but of a given region". 
9.2. The Section appreciates therefore, the significance of the "Community average" in relation to 
decisions on eligibility for ERDF finance. It fears, however, that it is too simplistic for regional policy 
purposes'. 
Reason 
Consistency with the opinion on ERDF revision. 
Voting 
For: 8, and a large majority against. 
Opinion on the proposal for a Council Directive amending for the fifth time Directive 
76/768/EEC on the approximation of the laws of the Member States relating to cosmetic 
products 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 36 of 12 February 1982, page 10. 
A. LEGAL BASIS FOR THE OPINION 
On 29 January 1982 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. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 199th 
plenary session held in Brussels on 30 June and 1 July 1982. 
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 Article 100 
thereof, 
Having regard to the request made by the Council of the 
European Communities on 29 January 1982 for an 
opinion on the proposal for a Council Directive amending 
for the fifth time Directive 76/768/EEC on the 
approximation of the laws of the Member States relating 
to cosmetic products, 
Having regard to the decision taken by its Bureau on 26 
January 1982 instructing the Section for Industry, 
Commerce, Crafts and Services to draw up an opinion 
and a report on the matter, Having regard to the opinion adopted by the Section for 
Industry, Commerce, Crafts and Services at its meeting 
on 2 June 1982, 
Having regard to the report submitted by the rapporteur, 
Mr Ramaekers, 
Having regard to the discussions at its 199th plenary 
session held on 30 June and 1 July 1982, 
HAS ADOPTED THE FOLLOWING OPINION 
with no dissenting votes, but with 6 abstentions: 
The Committee approves the proposal subject to the 
comments set out below.