. MOREOVER , MOST OF THE DETAILED RULES FOR THE APPLICATION OF THE SYSTEM IN QUESTION CORRESPOND TO THE GENERAL RULES WHICH HAVE LONG BEEN APPLIED TO NON-MEMBER COUNTRIES AND WHICH THE COURT ACCEPTED AS BOTH NECESSARY AND APPROPRIATE IN ITS JUDGMENT OF 17 DECEMBER 1970 ( CASE 11/70 INTERNATIONALE HANDELSGESELLSCHAFT MBH V EINFUHR- UND VORRATSSTELLE FUR GETREIDE UND FUTTERMITTEL ( 1970 ) ECR 1125 ).
19 THE APPLICANT ALSO ALLEGES THAT THE DAMAGE IT HAS SUFFERED AS A RESULT OF THE ESTABLISHMENT OF A SYSTEM OF STM LICENCES REQUIRING THE LODGING OF A SECURITY IS IRREPARABLE . THE SYSTEM PENALIZES SPANISH EXPORTS HEAVILY BY BURDENING THEM WITH A CONSIDERABLE NUMBER OF FORMALITIES AND ADDITIONAL EXPENSES AND HAS CAUSED A SIGNIFICANT FALL IN THE LEVEL OF EXPORTS . CONSEQUENTLY , SPANISH EXPORTERS ARE LOSING THEIR MARKET SHARES AND THEIR OUTLETS IN THE COMMUNITY . IF THAT SITUATION WERE TO CONTINUE FOR THE DURATION OF THE MAIN PROCEEDINGS BEFORE THE COURT THERE WOULD BE A RISK THAT MARKETS WOULD BE LOST IRRETRIEVABLY .
20 IN ORDER TO SHOW THE REALITY AND SCALE OF THE FALL IN SPANISH EXPORTS OF VITICULTURAL PRODUCTS TO THE COMMUNITY OF TEN , THE APPLICANT REFERS TO TWO TABLES OF STATISTICS CONTAINED IN ANNEX II TO ITS APPLICATION FOR INTERIM MEASURES . THE TABLES ARE IDENTICAL TO THOSE PRODUCED BY THE KINGDOM OF SPAIN IN CASE 119/86 R . THE FIRST TABLE COMPARES THE EXPORTS OF DIFFERENT TYPES OF SPANISH WINES ACTUALLY EFFECTED DURING THE TWO MONTHS FOLLOWING THE ENTRY INTO FORCE OF THE STM , NAMELY MARCH AND APRIL 1986 , WITH THE MONTHLY AVERAGE OF EXPORTS EFFECTED IN 1985 . THE SECOND TABLE SHOWS THE INDICATIVE EXPORT CEILINGS PER CATEGORY OF WINE OVER SIX MONTHS , THE QUANTITY WHICH MAY BE EXPORTED EACH MONTH WITHIN THOSE LIMITS AND THE EXPORTS WHICH WERE ACTUALLY EFFECTED DURING THE MONTHS OF MARCH AND APRIL 1986 . IN THAT CONNECTION THE APPLICANT SUBMITS THAT IN RELATION TO EACH TYPE OF WINE THE LEVEL OF ACTUAL EXPORTS WAS AT BEST NO MORE THAN THREE QUARTERS OF THE QUANTITY WHICH COULD BE EXPORTED WITHIN THE LIMITS OF THE INDICATIVE CEILING .
21 THE APPLICANT IS OF THE OPINION THAT THE FIRST TABLE PRODUCED BY IT CLEARLY SHOWS THAT FOR ALL TYPES OF WINE , WITH THE EXCEPTION OF WHITE QUALITY WINES , THE LEVEL OF ACTUAL EXPORTS IN MARCH AND APRIL 1986 WAS CONSIDERABLY LOWER THAN THE MONTHLY AVERAGE FOR 1985 . THAT FALL WAS PARTICULARLY APPRECIABLE IN RELATION TO WHITE TABLE WINES AND ROSE AND RED TABLE WINES , FOR WHICH THE LEVEL OF EXPORTS IN MARCH AND APRIL VARIED BETWEEN A MERE 15 AND 26% OF THE MONTHLY AVERAGE FOR 1985 AND WAS THE DIRECT CONSEQUENCE OF THE ESTABLISHMENT OF THE SYSTEM OF STM LICENCES REQUIRING THE LODGING OF A SECURITY .
22 THE DEFENDANTS DISPUTE THAT EXPORTS OF SPANISH VITICULTURAL PRODUCTS FELL AS A RESULT OF THE ENTRY INTO FORCE ON 1 MARCH 1986 OF THE STM AND