CELEX: 51991PC0529
Language: en
Date: 1992-03-06
Title: Proposal for a COUNCIL DIRECTIVE on the approximation of the laws, regulations and administrative provisions of the Member States relating to labelling of the materials used in the main components of footwear for sale to the final consumer

COMMISSION OF THE EUROPEAN COMMUNITIES
                                     COM(91) 529 final - SYN 378
                                      Brussels, 6 March 1992
                        Proposal for a
                      COUNCIL DIRECTIVE
    on the approximation of the laws, regulations and
      administrative provisions of the Member States
        relating to labelling of the materials used
           in the main components of footwear for
                 sale to the final consumer
                (presented by the Commission)
 ---pagebreak---                                    À
Explanatory memorandum
1. Background
The problem of footwear labelling goes back more than a decade. In some
Member States, regulations were initially introduced on a private basis.
This   was    followed by   the  introduction  of   legislation   in other
Member States.
Between 1986 and 1990 the Commission examined draft Spanish and French
decrees in this sector in the light of Article 30 et sea, of the Treaty.
After expressing various comments, which were taken into consideration, the
Commission accepted that these measures were lawful. However, although
they were legally acceptable, the measures caused problems in intra-EC
trade as they were not coordinated and contained manifest differences. Each
product has to be specially marked according to the Member State of
destination, resulting in particular in additional costs and barriers on
moving from one market to another within the Community. This situation has
been severely criticized in numerous complaints from the trade groups
concerned and by some Member States. There is a real risk that other
Member States wi I I take the same approach and that manufacturers will be
obliged to label products according to their destination within the
Commun i t y.
2. The need for Community action
Decisions taken under Article 30 ensures some degree of liberalization but
cannot be used to introduce harmonization. It has not been possible to
avoid having different Spanish and the French legislation. The ways of
ensuring full and effective free movement in this area are in particular
mutual recognition, voluntary harmonization or recourse to Article 100a.
As far as mutual recognition is concerned, the differences between the
Spanish and the French legislation and the absence of provisions in a
number of other Member States mean that it would be limited in scope.
The industry concerned was asked to start work on voluntary harmonization
but this ran into the major objection that such an approach would not
ensure that the system adopted applied to imports originating in third
countries (these accounting for nearly 35% of consumption). This would
distort competition and would not go very far towards providing consumers
with information. Furthermore, it would not be possible for harmonization
of this kind to replace national regulations.
 ---pagebreak---                                    -Ab<±
The most effective way of overcoming the disadvantages of the different
national laws has therefore been found to be a harmonization directive.
Consultations have shown that all of the Member States and the industry
concerned also support this approach and wish to have a binding system as
they believe this is the most appropriate way of overcoming the present
difficulties.
This proposal has in general been favourably received by all of the experts
representing the groups consulted. It has the advantage of having the
technical contribution of the industries concerned and the proposals put
forward during the three consultation meetings with experts from the
Member States   and  the   consultation  procedure   with   the Consumers'
Consultative Committee.
3. Scope of the proposed measures
As the main purpose of labelling is to inform and the aim is to achieve
harmonization within the Community, this draft directive lays down the
means to be used for footwear labelling. It defines the various parts of
footwear to which labelling will refer and the constitutive materials of
each of these parts which have to be taken into consideration.
The plan is for the information given on the product to be in the form of
pictograms so that consumers will be presented with the information in the
same way throughout the Community. This will facilitate understanding and
the operation of labelling of the products as such. If necessary, it is
planned that a text explaining the pictograms in the language spoken at the
point of sale should be put up to facilitate understanding of the
pictograms.
With the aim being to increase the information provided, it has been
necessary to strike a reasonable balance between the tendency to demand as
much information as possible and the need for that information to be
intelligible in a sufficiently direct manner.
4. Implementation
It is estimated that, following the adoption of the draft directive by the
Council, It will take at least one year for the action required for its
application to be taken by the Member States. This means that the measures
can be expected to be implemented at the earliest on t July 1993.
 ---pagebreak---                                      Proposal for a
                                   COUNCIL DIRECTIVE
                 on the approximation of the laws, regulations and
                   administrative provisions of the Member States
                     relating to labelling of the materials used
                        in the main components of footwear for
                               sale to the final consumer
The Council of the European Communities,
Having regard to the Treaty establishing the European Economic Community
and in particular Article 100a thereof,
Having regard to the proposal from the Commission.
In cooperation with the European Parliament,
Having regard to the opinion of the Economic and Social Committee,
Whereas   in certain    Member   States  there   exist  regulations   on  footwear
labelling which are designed to protect and inform the public as well as to
secure the legitimate interests of industry,
Whereas the disparity of such regulations risks creating barriers to trade
within the Community and thereby impeding the establishment of the internal
market.
Whereas  it is expedient, in order to avoid the problems due to different
systems, to specify the exact elements of such a common          labelling system
for footwear,
Whereas Council Resolution of 9th November 1989 (89/C294/01) on the policy
relating   to consumer    protection   calls   for  efforts  to improve   consumer
 information on products,
Whereas   it  is  in the    interest  both   of  consumers  and of   the  footwear
 industry to introduce a system reducing the risk of fraud by indicating the
exact nature of the materials used in the main components of           the item of
footwear,
 ---pagebreak---                                    - 2 fcb
HAS ADOPTED THIS DIRECTIVE :
                                     Article 1
1.  This Directive concerns the labelling of the materials used in the
    main components of footwear articles for sale to the final consumer.
2.  For t he purposes of t h i s 01rec11ve:
    'footwear' shall mean all        articles of apparel with applied soles
    designed to protect or cover the foot,        it does not include disposable
    foot   or  shoe   coverings   of    flimsy  material   (paper,    sheeting  of
    plastics, etc.) without applied soles.
    'Footwear' may range from sandals with uppers consisting simply of
    adjustable laces or ribbons to thigh boots the uppers of which cover
    the leg and thigh.     Among those products included therefore are:
    i)     Flat or high heeted shoes for ordinary indoor or outdoor wear.
    il)    Ankle-boots, half-boots, knee-boots, and thigh boots.
    iii) Sandals of      various   types,    "espadrilles"   (shoes with    canvas
           uppers and soles of plaited vegetable material), tennis shoes,
           Jogging shoes, bathing slippers and other casual footwear.
    iv)    Special   sports   footwear    which   is designed    for   a  sporting
           activity   and   has, or    has provision    for,  the   attachment  of
           spikes, sprigs, stops, clips, bars or          the   like and skating
           boots,   ski   boots  and   cross-country   ski   footwear, wrestling
           boots, boxing boots and cycling shoes. Also included are toy
           footwear and skating boots with Ice or roller skates attached.
 ---pagebreak---                                - 3 -
   v)    Dancing slippers.
   vi)   Footwear obtained  in a single piece, particularly by moulding
         rubber or plastics or carving from a solid piece of wood.
   vii)  Overshoes worn over other   footwear;     in some cases, they are
         heel-less.
   viii) Disposable footwear, with applied soles, generally designed to
         be used only once.
   Ix)   Orthopedic footwear.
3. This Directive does not cover:
   i)    footwear without applied soles, of textile material;
   i i)   worn footwear ;
   iii)  articles of asbetos;
   iv)   parts of footwear not offered for sale to the final consumer;
   v)    protective footwear which is covered by Council Directive 89/686
         EEC of 21 December 1989.
4. For the purposes of clarity and transparancy therefore and subject to
   the provisions outlined in the proceeding paragraphs the description
   of products covered by this Directive has been made by reference to
   Chapter 64 of the Combined Nomenclature C C N ' ) .
 ---pagebreak---                                    - 4-
5.  Information   on   the  composition   of  the footwear   article   shall  be
   conveyed by means of a label as outlined in Article 4.
   i)     The label shall convey information relating to the three parts
          of the footwear article, namely a) upper, b) lining and sock and
          c) outerso le as defined in the annex.
   ii)    The composition of the footwear article shall be indicated in
          line with the provisions of Article 4 on the basis of pictograms
          for specific materials as outlined in the annex.
   iii)   In the case of a) the upper b) the lining and sock classifi-
          cation   is determined by the constituent material or materials
          which have the greatest external surface area, no account being
          taken of accessories or reinforcements such as ankle patches,
          edging, ornamentation, buckles, tabs, eyelet stays or similar
          attachments.
   iv)    In the case of c) the outersole classification is based on the
          volume or mass of the materials contained therein, in line with
          the provisions of Article 4.
6. 'Sale to the final consumer' shall also cover distance selling such as
   mail order, telephone order on the basis of a catalogue and other
   methods   such   as   television   selling, without   prejudice  to   further
   possible methods arising from the advance of new technologies.
                                    Article 2
1. Member States shall take all necessary measures to ensure that all
   footwear items, whether produced in the EC or imported, placed on the
   market   meet   the   labelling   requirements of   this Directive    without
   prejudice to other relevant Community provisions.
 ---pagebreak---                                    - 5 -
2. Where footwear items not in conformity with the provisions regarding
   the     labelling requirements are placed on the market         the competent
   Member      State  shall  take  appropriate   action   as  specified   in  its
   national provisions.
                                    Article 3
1. Member States shall not prohibit or impede the placement on the market
   of footwear items which comply with the labelling requirements of this
   Directive, by the application of national provisions governing the
   labelling of certain footwear items or of footwear items in general,
   without prejudice to other relevant Community provisions.
                                    Article 4
1. The label shall provide information on the material which constitutes
   at least 85% of the surface area of a) the upper b) the lining and
   sock of the footwear article and at least 85% of the volume or mass of
   c) the outer sole.       If no one material     accounts  for   at  least 85%
   information should be given on the two principal materials              in the
   composition.
2. The information shall be conveyed by means of agreed pictograms as
   defined and illustrated in the Annex together with a poster explaining
   these pictograms       in the national   language(s) or other    languages as
   necessary, or any equivalent means (eg. video, electronic display,
   e t c . . ) also able to convey     the relevant    information.   The poster
   shall      be  displayed  prominently  and   in the   immediate   vicinity  of
   footwear      items at all   points of sale to the final       consumer.   The
   dimensions of the characters contained therein shall not be less than
   2 cm.
3. The label must be on or attached to at least one footwear article in
   each pair e.g. imprinted on or stuck to the sole or the inside of the
   footwear article, tied, embossed etc.
 ---pagebreak---                                      - 6-
4. The  label   must    be   legible,    firmly    secure   and   accessible   and   the
   dimensions of     the pictograms must         be suffi cent I y    large to make it
   possible to clearly understand the information contained therein.
5. The manufacturer or his authorized agent established in the Community
   is responsible for supplying the            label and for the accuracy of the
   information contained       therein.     If neither    the manufacturer      nor his
   authorized   agent    are established        in the Community       this  obligation
   falls on the person responsible for the placement on the market in the
   Community.    The   retailer     remains    reponsible    for   ensuring   that   the
   labelling of footwear sold by him conforms with the provisions of this
   directive.
6. The  name   and    address    of   the   manufacturer,      his   authorized    agent
   established    in   the   Community     or    the  person    responsible    for   the
   placement on the market         in the Community,       if not    indicated on the
   label, should be available to the consumer at the point of sale.
                                      Article 5
   The proceeding article outlines the basic requirements for footwear
   labelling.    Supplementary       information     such   as   textual    information
   indication of leather type or means of attachment of the sole may be
   recommended by Member States in their provisions.              However, they shall
   not  prohibit    or    impede   the   placement     on  the   market    of  footwear
   conforming   to the requirements of           this Directive     in   line with the
   provisions of Article 3.
                                      Article 6
1. Labelling provisions as outlined           in Article 4 will apply equally to
   distance selling such as mail order or telephone order on the basis of
   a catalogue and television selling.             Because of special constraints,
 ---pagebreak---                                    - 7 -
    the relevant    information will be conveyed by means of the following
    methods, without prejudice to further possible methods arising from
    the advance of new technologies:
    a)  Mail order and telephone order on the basis of a catalogue
         Pictograms   in  line with    the   provisions  of   Article  4 wi 11 be
         presented for all footwear       items which appear    in the catalogue.
         An explanatory notice concerning the pictograms will appear once
         in the catalogue.     This notice will be presented prominently and
         close to the footwear articles displayed.
    b)   Television Sel Iing
         Pictograms   in line with the provisions of Article 4 wi I I appear
         with the display on the screen of the footwear article for sale.
                                     Article 7
1.  Member   States   shall   adopt   and   publish  the   laws   regulations   and
    administrative provisions necessary to comply with the provisions of
    this Directive by [31 December 1992].        They shall forthwith inform the
    Commission thereof.
2.  They shall apply the provisions referred to in paragraph 1 from [30
    June 1993].   Stock invoiced or delivered to the retailer before this
    date shall not be subject        to the said provisions until       [1 January
    1995].
3.  When   Member  States   adopt   these   provisions, these    shall   contain  a
    reference to this directive or shall be accompanied by such reference
    at the time of their official publication.           The procedure for such
    reference shall be adopted by Member States.
                                     Article 8
This Directive is addressed to the Member States.
 ---pagebreak---                                 - 8 -
                                   ANNEX
1. DEFINITION AND CORRESPONDING PICTOGRAMS CONCERNING THE PARTS OF THE
   FOOTWEAR ARTICLE TO BE IDENTIFIED
a) Upper
   It is the outerface of the structural element
   which is attached to the outersole.
b) Lining and Sock (insole lining)
   It  is the upper and    insole   lining, consti-
   tuting the inside of the footwear article.
c) Outersole
   It  Is the   bottom  surface   of   the footwear
   article which   is subjected to abrasive wear
   and which is attached to the upper part of the
   footwear article.
2. DEFINITION AND CORRESPONDING PICTOGRAMS OF THE MATERIALS
   The pictograms concerning the materials should appear on the label
   beside the pictograms relating to the 3 parts of the footwear article
   as specified in Article 4 and part 1 of the Annex.
 ---pagebreak---                                      - 9 -
a) Leather
   i)  A general term for hide or skin with its
       original      fibrous structure more or         less
        intact, tanned       to be   imputrescible.     The
       hair    or   wool   may   or may   not   have been
       removed.      Leather is also made from a hide
       or skin which has been split into layers
       or    segmented      either    before    or    after
       tanning, but if the tanned hide or skin is
       disintegrated          mechanically       and     or
       chemically      into fibrous particles, small
       pieces     or    powders    and   then,    with   or
       without      the   combination     of   a    binding
       agent, is made into sheets or other forms,
       such    sheets or forms are not leather.          If
       the    leather has a surface coating, this
       surface     layer, however applied, must not
       be thicker than 0.15mm.         Thus all leathers
       are   covered     without    prejudice    to   other
        legal      obligations        e.g.     Washington
       Convent ion.
   ii) Coated Leather: leather where the surface
       coating applied        to the   leather    does not
       exceed one third of the total thickness of
       the product but is in excess of 0.15mm.
b) Natural     Textile      Materials    and     Synthetic
   Textile Materials woven or non-woven
                                                            —-1—1—1—1-=-
   Textile means all products falling under the
                                                              I — | — | J-|
   scope of Dir. 71/307/CEE and any            amendments
                                                             -I—I—I—l-i
   thereof.
                                                            - l — l — I — i JL
 ---pagebreak---                                - 10 -
c) Rubber
   This covers natural or    synthetic rubber, an
   elastic  material   derived   from  latex from
   living plants and/or from synthetic polymers
   and processed by vulcanisation.
d) All other materials
 ---pagebreak---                                  M
                              FINANCIAL STATEMENT
                      SECTION 1: FINANCIAL IMPLICATIONS
1. Title of operation
   Directive on the approximation of the            laws, regulations and
   administrative provisions of the Member States relating to the labelling
   of the materials used in the main parts of footwear for sale to the
   final consumer.
2. Budget heading involved
   B8-530:  Completing the internal market - support
3. Legal basis
   Article 100a of the EEC Treaty
4. Description of operation
   4.1  Specific objectives of operation
        To ensure full and effective free movement        of  the  products
        concerned; to provide consumer information
   4.2  Duration
        One-off action.
   4.3  Target population
        Trade groups and consumers in the Community
5. Classification of expenditure or revenue
   5.1  Compulsory/Non-compulsory:
        Non-compulsory
   5.2  Different iated/Non-differentiated:
        Non-d i fferenti ated
 ---pagebreak---                                      -Jfc
   5.3  Type of revenue involved:
        Not appIi cab Ie
6. Type of expenditure or revenue
   6.1  100% subsidy:
        Not appIicab le
   6.2  Subsidy for Joint financing with other sources in the public and/or
        private sector:
        Not appIicab le
   6.3  Interest subsidy:
        Not app11 cab le
   6.4  Other
        Administrative expenditure      to  permit  implementation  of the
        Directive concerned.
   6.5  Should the operation prove an economic success, is there provision
        for all or part of the Community contribution to be reimbursed?
        No
   6.6  Will the proposed operation cause any change in the level of
        revenue?    If so, what sort of change and what type of revenue is
        involved?
        Not applicab le
7. Financial impact on appropriations for operations {part B of the budget)
   BOJ 29 000
   7.1 Method of calculating   total cost of operation:
        20% of the working time of an auxiliary secretary for one year +
        share:                                           BOJ 12 200
       Meeting of experts:    15 x BOJ 700 -             BOJ 10 500
        Consultant for technical assistance {one month) BOJ 6 300
   7.2  Proportion of mini-budget in total cost of operation.
        Explain method of calculation.
        BOJ 29 000 representing the total cost of the operation
   7.3  Indicative schedule of commitment and payment appropriations:
        CA: ECU 29 000
        PA: ECU 29 000
 ---pagebreak---                                     43 -
8. What anti-fraud measures are planned in the proposal for the operation?
   Anti-fraud measures not required in view of the internal nature of the
   expenditure.
       SECTION 2 : ADMINISTRATIVE EXPENDITURE (part A of the budget)
1. Will the proposed operation involve an       increase  in the number of
   Commission staff? If so, how many?
   No increase in staff
2. Indicate the amount of staff and administrative expenditure involved in
   the proposed operation. Explain the method of calculation.
   ECU 29 000
        20% auxiliary secretary for one year + share of a person already
        present in the departments
        See point 7
            SECTION 3:  ELEMENTS OF COST-EFFECTIVENESS ANALYSIS
1. Objectives and coherence with financial programming
   1.1  Specific objective(s) of proposed operation. If possible this
        should be quantified and must be shown for each of the years
        concerned in the case of a multiannua I operation:
        (a)     See Section 1, 4.1: to ensure full and effective free
                movement of footwear within the Community
        (b)     Permanent operation principally at the expense of the
                Member States
   1.2  Is the operation incorporated in the financial programming of the
        DG for the years concerned?:
        Yes
   1.3  To which broader objective defined         in the DG's    financial
        programming does the objective of          the proposed   operation
        correspond?
 ---pagebreak---                                     -**4 -
        Objective: completing the internal market
        Sub-objective: abolition of technical barriers
        Objective: harmonization of laws
2. Grounds for the operation
2.1     Reasons for choosing this operation rather than an alternative
        which would achieve the same objectives. The justification must
        be based on three criteria*.
        Two alternatives were considered:
                mutual recognition: this would have been of limited scope
                 in view of the differences between the Spanish and the
                French legislation in force and the absence of provisions
                 in the other Member States
                voluntary harmonization: this approach would be unable to
                ensure that the agreed system applied to imports
                originating in third countries (which account for 35% of
                consumption). A harmonization directive has therefore been
                found to be the most effective means.
        (a)     Cost:
                Modest
        (b)     Spin-off effect (impact beyond the specific
                objective(s)):
                Avoidance of complaints from economic operators
        (c)     Multiplier effect (ability to mobilize other sources of
                finance):
                Not appi icable
3. Monitoring and evaluation of the operation
   3.1  Performance indicators selected:
        Transposition into national laws
    3.2 Details and frequency of planned evaluation:
        Bi-annual examination of the situation with       industry and the
        Member States
   3.3 Main factors of uncertainty which could affect the specific results
        of the operation:
 ---pagebreak---                                J5
                        FOOTWEAR LABELLING
                      Impact Assessment Form
                        Title of Proposal:
  Draft Council Directive on the approximation of the Laws,
           Regulations and Administrative Provisions
       of the Member States relating to the Labelling of
     the Materials used in the Main Components of Footwear
                 for Sale to the Final Consumer
                    Reference Number: 21219.2
1. The Proposal
-   National legislation on Footwear Labelling exists in
    Spain and France. The French decree which was Imple-
   mented on 1 June 1990 caused significant disquiet in the
    EC footwear Industry because of the adverse effects which
    it could have on intra-EC trade. At the beginning of
    1990 therefore the European Confederation of the Footwear
    Industry requested the EC Commission to begin discussions
    leading to the introduction of a harmonized labelling
    system for footwear sold in the EC on the basis of agreed
    symbols. This idea was then presented to the Member
    States who Indicated their support for the initiative.
    The main alms of the initiatives are to provide the con-
    sumer with essential information while aiding the free
   circulation of footwear in EC by replacing divisive na-
    tional regulations with harmonized Community provisions.
2. The Impact on business
I)    The proposal will directly affect footwear manufac-
      turers, importers, distributors and retailers.
ii)   The Industry is composed almost entirely of SMEs.
      Fragmentation and labour     intensity  are the sector's
      most significant traits.
      There are over 15,000 footwear businesses in the Commu-
      nity, with an average of 24 employees/firm.
 ---pagebreak---                               -At
 ill) Italy is by far the largest producer, with an average
       annual % share of total EC production of 40%. Other
        large producers are Spain (15%), France (15%), followed
       by the UK (12%), Portugal (8%) and Germany (7%). Pro-
       duction in the other EC countries Is marginal.
3. What will business have to do to comply with the proposal?
    The directive provides for the obligatory labelling of ail
    footwear for sale to the final consumer. Thus, it is the
    responsibility of the footwear manufacturer, his author-
    ized agent and the retailer to ensure that all footwear
    offered for sale displays the required information in a
    correct    form   in line with the provisions of this
    directive. In practice the manufacturer will supply the
    label and take responsibility for the accuracy of its
    information while It Is up to the retailer to ensure that
    the label is present at the time of purchase.
4. What economic effects is the proposal likely to have?
i)     Approximately 346,000 people were employed in the EC
       footwear industry in 1990. Italy has by far the largest
       employment figure with 114,000 followed by the UK,
       Portugal, France, Spain and Germany with 54,000, 49,000,
       38,000, 38,000 and 33,000 respectively. During the
       1980s employment in the industry fell at a rate of over
       3% p.a. and this downward trend is continuing.
ii)    This proposal Is unlikely to have any direct effect on
       employment or investment in the Industry. However, giv-
       en the objectives of a) informing the consumer of the
       composition of the item of footwear, and b) aiding the
       free circulation of footwear throughout the community it
       is to be hoped that Implementation of the proposal will
       have a positive effect on the industry. A unified har-
       monized system will replace different national practises
       and additional costs which would have to be borne by the-
       industry in preparing different labels for various EC
       markets will be avoided. Furthermore, heightened con-
       sumer awareness of the composition of footwear articles
       may increase their appreciation of and confidence in the
       product and encourage further purchases.
5. What about the specific situation of SMEs?
-    In view of the fact that the industry is composed almost
    entirely of small and medium sized enterprises the propos-
    al was prepared with the interests and specific situation
    of SMEs continuously borne in mind.
 ---pagebreak---                                -/*-
6. Consultation
   Regular consultations with the European Footwear Federa-
   tion took place during the evolution of the project com-
   bined with meetings with representatives from the Member
   States on four seperate occasions. A formal consultation
   of the information and education section of the Consumer
   Consultative Council (CCC) took place on 11 April 1991 and
   the opinion of the complete Committee was presented during
   their session of 16 October 1991. The views of individual
   organisations were also received in the form of written
   comments. The relevant views of other concerned bodies
   were conveyed through the Interservice consultation of
   other Commission Departments such as the Consumer Policy
   Service,   and   the Directorate     General   for  Enterprise
   Policy, Distributive Trades, Tourism and Cooperatives.
-  The views of all the concerned parties have been taken
   Into account in preparing this proposal. The main points
   of debate centered on the amount of Information to be giv-
   en on the label. The different views of various Member
   States have been discussed and considered during the
   meetings held over the past 18 months while the greatest
   divergence of opinion on the project exists between the
   CCC and the European Footwear Federation.
   The CCC would like information to be given on the upper,
   lining,   innersole,    midsole   and   sole  along   with   an
   indication of the means of attachment of the sole i.e.
   stitched, stuck etc. Furthermore, they believe that the
   consumer should be informed of the characteristics of the
   materials   used   e.g.   waterproof    and  that   the   exact
   dimensions of the proposed label should be laid down in
   the directive.
   On the other hand industry stresses the necessity for
   simplicity and clarity       in the directive's provisions.
   They propose just one overall category for leather, a
   category   for natural     textile products and one       final
   category covering     rubber   and synthetic materials.      In
   their view just three parts of the footwear article should
   be identified viz a) the upper, b) the sock and vamp
   lining, and c) the sole in order not to detract from the
   appearence of the shoes which are, of course, fashion
   objects. For its part the leather industry, represented
   by Cotance, has continously stressed the importance of
   differentiating between "leather" and "coated leather" in
   order to ensure conformity with existing internationally
   agreed definitions.
   The proposed directive is intended to strike a reasonable
   balance between the various viewpoints and have the twin
   merits of providing the consumer with essential informa-
   tion without becoming too cumbersome or burdensome on the
   SMEs in the sector.
 ---pagebreak---                                                                      ISSN 0254-1475
                                                              COM (91) 529 final
                                                      DOCUMENTS
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