Category: Archive – 2009

GRTU has today written to the relevant authorities and to MEP Prof Edward Scicluna as substitute member within the Committee on the Environment, Public Health and Food Safety regarding concerns that have arisen on the retailers responsibility on food information to consumers.

GRTU has presented them with a paper where we explained that the commerce sector considers the review of the food labelling legislation as an excellent opportunity to clearly define the obligations that derive from it as well as the responsibility of each operator in the food chain. 

GRTU welcomes the Commission's attempt to clarify the responsibilities regarding food information provided to consumers for the different food business operators. We do however believe that the wording originally proposed leaves room for interpretation. We therefore hope that the suggestions outlined below will clarify the responsibilities regarding the different food operators, ensuring that businesses are not held liable for problems outside their sphere of responsibility or outside their control.

Overview of the situation

The responsible person for the food information, both its accuracy and presence, is the operator who places it for the first time on the Community market: EU manufacturer, or importer, or retailer for its own branded products. An imprecise description as regards the operators' responsibility would lead to the discrepancy in applying the Regulation.

It would also mean a confirmation of the current state of play, where due to the lack of precise statements in food legislation, some national authorities tend to hold the retailer liable for the labelling of manufacturer-branded products and the information that accompanies them.

This practice:

Reduces consumer protection: Holding retailers responsible for carrying out checks that should have taken place earlier in the supply chain could lead to a reduction of compliance with the requirements which should serve to protect consumers, as upstream businesses may be less attentive and carry out fewer controls. Yet, it is impossible for staff in stores to know all the relevant legislation.

Increases the administrative burden: Member States may impose on the retailer the responsibility to verify, not only the presence, but also the accuracy of all mandatory statements on the label of manufacturer-branded products or products not imported by the retailers.

This will considerably increase the administrative and economic burden. Retailers will be constrained to make further analyses, the costs of which will be very high, not to mention the fines incurred in case of inaccuracy of a particular and the appeal costs against the real offenders.

Builds barriers to trade: The possibility of a national legislation challenging their responsibility for the compliance with Community requirements applicable to food products made in other EU countries could deterred retailers from selling such products, because they are unable to assess the extent of the risk that they will have to assume, or the size of the penalty that they risk.

GRTU's position

The free movement of safe and wholesome food is an essential aspect of the internal market. The good protection of consumers makes imperative that food products circulating in the EU Market are in conformity with the EU legislation since their first placing on the Community market.

 

 

 

The Regulation should provide a clear and proportionate distribution of obligations that correspond to the role and activities of each operator in the food supply and distribution process. This is the approach adopted in several Community acts. In order to ensure the consistency of EU legislation, the same approach should be taken into account in this proposal. 

Economic operators should be responsible for the compliance with legislation in relation to their respective roles and activities in the supply chain.

Therefore the responsible person for the food information, both its accuracy and presence, is the operator who places it for the first time on the Community market: EU manufacturer, or importer, or retailer for its own branded products.

In order to sort out the difficulty in practice for finding out the operator responsible for first placing on the Community market, his name should always be mentioned on the label.

It is necessary to distinguish clearly between the manufacturer and operators further down the distribution chain. The manufacturer, having detailed knowledge of the design and production process, is best placed to carry out the complete conformity assessment procedure for products. Conformity assessment of the food information and ensuring its correctness should therefore remain the obligation of the manufacturer alone when placing it on the Community market.

Retailers are fully responsible for the labelling particulars of products they import from third countries and sell under their own brands.

Retailers who simply market products without affecting food information will have to react immediately if they have been notified about the non-conformity of the food information with the relevant legislation or when they become aware of it when exercising their respective activities considering the information at their disposal. Then they have to choose the most appropriate action (withdrawal, recall, putting in conformity with this Regulation…) for the given situation.

Furthermore food should also be the subject of controls carried out by national authorities at every prior step of the food chain. Proceeding again to controls of the prior steps does not fall within the capacities / competence of retailers. They are the last business operator in the food chain, simply marketing the foodstuff without altering the information that accompanies it, and should therefore be able to assume it conforms with the EU relevant legislation.

GRTU considers disproportionate to ask the final retailer to assume the responsibility for systematically performing checks that should have taken place earlier in the chain on aspects which are outside the sphere of its own activities.

The draft "Communication on Animal Welfare labelling and the establishment of a European Network of Reference Centres for the protection and welfare of animals" aims to promote an informed debate and to provide transparent information on animal welfare in husbandry production.

According to the Commission, such a label could make it easier for consumers to identify and choose welfare friendly products and provide an incentive for industry to promote their products accordingly when they voluntarily apply higher welfare standards.

Both the analysis of the outcome of the Eurobarometer surveys 2005 and 2006 (http://ec.europa.eu/food/animal/welfare/survey/index_en.htm) and the feasibility study performed to support the impact assessment report lead to the conclusion that animal welfare labelling, based on sound scientific knowledge and assessed on the basis of harmonised requirements, can enable consumers to make informed purchasing decisions and make it possible for producers to benefit from market opportunities.

Due to the fact that European consumers frequently complain that they lack information on animal welfare, the Community Action Plan on the Protection and Welfare of Animals 2006-2010 (http://ec.europa.eu/food/animal/welfare/actionplan/actionplan_en.htm) suggests the development of standardised animal welfare indicators, in order to provide for a science-based tool to make animal welfare measurable, more enforceable and easier to communicate to people. The EU funded project "Welfare Quality", will serve as a basis for the elaboration of animal based scientific indicators. According to the Commission, this could lead to a system to classify animal welfare that could be useful to support product labelling and provide consumers with transparent and reliable information. In this context, a network of centres for the protection and welfare of animals could constitute a concrete option to provide technical support for the further development of the system.

Analyses of the Options

The option Mandatory labelling of compliance with EU legislative minimum standards has been discarded from further assessment in this Communication since the overwhelming view from consumers, farmers, processors retailers and others was opposed to such a label.

The option "General guidelines for the establishment of animal welfare labelling and quality schemes" is perceived by the main stakeholders to provide low added value as regards consumer information and is therefore also not further assessed in this Communication.

According to the feasibility study, the majority of the stakeholders consulted supported the following conclusions:

The creation of a European mandatory animal welfare label is not a preferred option.

Information on animal welfare should be clear and easy to understand.

Labelling initiatives for animal welfare would be more effective if associated with comprehensive information campaigns to inform consumers in a more general way and increase preference for high quality products.

There is a need for "standardisation" and maintenance of the instruments to assess animal welfare in the EU, to ensure transparency and scientific investments.

The importance of assessing the welfare of animals in a transparent manner to facilitate trade of high quality products.

There should be better coordination of existing resources in the whole area of animal protection to provide for efficient scientific coordination, transparent enforcement and reduction of costs related to implementation.

The application of a certification scheme developed with the contributions of all relevant stakeholders and integrated with other existing schemes will facilitate the process to ensure synergies between animal welfare labelling schemes and other existing certification policies (as the labelling of organic products).

Conclusion

According to the Commission a strategic approach to addressing the needs identified by stakeholders and the Commission in this communication should include at least the following measures:

The development of harmonised requirements for the use of reserved animal welfare terms through the means of an EU legislative initiative referring to farming systems or to outcome based animal welfare standards, and would improve the information to consumers on specific aspects of animal husbandry.

The creation of a Community animal welfare logo based on harmonised European standards and open for voluntary participation. This measure would allow existing animal welfare schemes to be certified based on harmonised requirements at Community level facilitating transparency.

The establishment of a European Network of Reference Centres for the protection and welfare of animals (ENRC) based on a mixed approach; meaning that the ENRC is based on a central coordination institute that cooperates with a network of relevant research institutions in the Member States – all recognised by the Community – which take on responsibilities for specific sub-tasks and participate in working groups. In this way, a relatively small centre with a coordinating function would become a focal point for coordination and harmonisation of Community relevant issues in the field of animal welfare, performing its tasks in close collaboration with a network of relevant research institutions in the Member States, officially recognised and with international partners.

 

GRTU has received an invitation form the Local Councils' Association to collaborate on an EU funded project entitles PHILOXENIA.

The Local Councils' Association is a project partner and the project is lead by the Initiative Territoriale por l'Emploi at l'Enterprenariat de Kerkini-Petritsi-Heraclee and Employabilite Locale.  The other participating countries are Greece, Sardini, Sicily, Cyprus and Slovenia.

The core objective of the project is the setting up of 15 new micro enterprises in the rural localities as defined by the Rural Development Plan. The project's budget envisages financial assistance to the newly set-up micro enterprises.

Weakened by demographic decline, the rural Mediterranean municipalities of the probed Philoxenia are increasingly confronted with a diminution of services and commercial enterprises, or even with a loss of their identity. However, the promotion of mobility and of the information and communication technologies (ICT), the concern for a sustainable development and the search for a better quality of life in view of the urban nuisances permits these rural territories to inverse the tendency above and to find new ways of local development. The architectural, cultural and environmental heritage and space at their disposal are indeed new factors of interactivity.

In this actual environment which is taking shape, the seven project partners propose in the territories implicated the implementation of a common  operational mechanism of reception of activities in Mediterranean rural areas.

For three years, from April 2009 to March 2012, this mechanism foresees the financial, technical and cultural support of 90 persons, 54 female and 36 male, wishing to install themselves in the target zones to create their own micro-projects and also to contribute to the vitality of these rural territories.

GRTU has excepted to participate and has put the nomination of its member forward.

GRTU has written to Hon George Pullicino Minister for resources and Rural Affairs regarding the landfill fees.  Following the meeting with the Hon Minister earlier this month and a meeting for the waste management sector GRTU sent the following comments:

The sector notes that increasing landfill fees from €0.91/tonne to €20.00/tonne is not only detrimental to the waste management operators but also to many industries operating in the private sector inclusive of hotels, restaurants and other commercial entities. The waste management sector is today being paid six months in arrears, so it is no longer acceptable for the sector to be able to offer such credit facilities with such a fee increase.

The waste management sector is the carrier in this situation and they should in no way be made to burden the costs of those generating the waste. Even the waste generators themselves cannot afford such a burden overnight. The Hotels and restaurant and all small and medium sized enterprises are suffering through an economic crises and any exorbitant increase is totally not acceptable to these sectors.

GRTU confirms that it agrees with the sustainability concept but there are times and circumstances when this should be implemented.

GRTU on behalf of all its members explained that it cannot agree to such an increase and that we are prepared to meet and discuss an acceptable solution to this landfill sustainability situation.

GRTU requested to receive a confirmation that there will be no increases of any sort implemented before future discussions are held and realistic agreements are reached.

 

In a Eurobarometer survey published on the 29th of August, it was revealed that four out of five Europeans say that they consider the environmental impact of the products they buy. Environmental consideration was highest in Greece where more than 9 in 10 of those surveyed said the impact of a product on the environment plays an important aspect in their purchasing decisions. In the same survey Europeans were evenly divided about claims by producers on the environmental performance of their products while nearly half thought that a combination of increased taxes on environmentally-damaging products and decreased taxes on environmentally-friendly products would best promote eco-friendly products. There was also strong support for retailers to play a role in promoting environmentally-friendly products and for mandatory carbon labelling.

 

 

 

EU Environment Commissioner Stavros Dimas said that consumers have the power in the sense that the battle against climate change is not only the remit of companies and governments. Consumers also have their part to play. By purchasing environmentally and climate-friendly products, individual customers send the right signal to producers who respond in turn by producing more eco-friendly products.

Some 46% of EU citizens also thought that the best way to promote environmentally-friendly products would be to increase taxes on environmentally-damaging products and decrease taxes on environmentally-friendly products. Britons were most in favour of such a double taxation system while the Maltese much less so (28%) preferring instead reducing taxes on environmentally-friendly products only.

Background: In July 2008 the Commission presented an action plan which includes a series of proposals on sustainable consumption and production that will contribute to improve the environmental performance of products and increase the demand for more sustainable goods and production technologies. It also seeks to encourage EU industry to take advantage of opportunities to innovate. More information on this can be found here: http://ec.europa.eu/environment/eussd/escp_en.htm

Source: MEUSAC Sectoral Committee Update

 

GRTU has today written the Hon Chris Said as responsible for Local Council, the Mayor of Valletta Local Council, the Police Corps and the Commissioner for Land, requesting immediate action on the gatherings occurring in City Gate on behalf of the shop owners of the Valletta city gate shopping arcades in Freedom Square.

Our concern relates to a situation that has been existing for now a considerable amount of time where a large group of youngsters have been gathering in the form of a gang in these arcades. These youngsters used to gather inside the arcade and they abused of the premises in every way.

 

Now they have been ousted from inside the arcades and by 17:00 hrs they gather in front of Libyan Arab Airways, and placate the first half of the front of the arcade from Trafalgar shop to Clavis.

GRTU brought to their attention that a gathering of more than 9 people is illegal and therefore such gathering in this area can no longer be permitted. This also because their way of behaving and the general atmosphere they are creating is being of detriment to the general image of the area and is negatively affecting business. The general public passing by is literally afraid to walk into the shops.

To give an idea, these youngsters have been reported by our members of loud and continuous blasphemy. We have to point out that in our country it is criminal offence to blaspheme.

Though the police have often had reports to take action, the action taken was insufficient and ineffective. One cannot accept that the law is being broken so evidently on a daily basis and no authority shoulder the responsibility and more still take definite action to bring the situation to an end.

 

 

 

 

We are on the brink of having politicians ruin businesses again by attempting to set up structures that compete and distort the market again. The Chamber of Commerce was right to be concerned and it issued a statement to that effect last Friday. I am in total agreement on this, although I am not a member of the Chamber of Commerce, and there is no love lost between us, but I am in business.

People cannot have the cake and eat it at the same time. Let's just take an example I am familiar with.  Eurostat says that on average, our medicines prices are 1.9% above the EU average in general. These are the facts. These are the known facts. That fact has been conveniently omitted by both sides of our political spectrum. "Let's do something about prices in Malta" is just a convenient catchphrase used every time the issue of making ends meet in Malta raises its head. It's the medicine importers who are invariably targeted first, and then the food importers follow.

It is a known fact that in the EU no one cares about the price of medicine except those who pay for them, that is, Governments and Insurance companies. Therefore most times prices are agreed between manufacturers and payers.  There exist reimbursement systems over the entire EU except Malta and Cyprus. But people in the EU pay a lot of social security contributions for this. They also have to co-pay for all their medicines in most countries. Then it's either the patient or the pharmacy that is reimbursed. BUT patients under 65 or over 18 have, in most cases, to pay a prescription fee  or a co-payment that is either a percentage of the medicines cost or else a straight fee. In the UK it's around STG 6.50 for example, even if your medicine costs STG 1.50. If people want this in Malta, I am sure –that the Chamber of Commerce and the GRTU can find ways to oblige, but invariably the Maltese will pay more than they are doing just now. I can guarantee this.

I have heard that both the Prime Minister and the Leader of the Opposition are in broad agreement that, if necessary, Government should start importing products itself, even medicines, and selling them in competition with the private operator. Or else introduce a system of price controls. This is austere Marxist-Leninist ideology at its very best. Its unbelievable that these people, who spend most of their time in the hallways of Brussels, don't bother to read the EU treaty and the various directives. It is ILLEGAL to impose price controls on anything in the EU in principle. As regards medicines, unless you are paying for it all, you can't impose controls on the prices of medicines. Government already is supposed to be buying at the cheapest price possible, as it issues tenders for medicines. That's about the best it can do. It certainly cannot go to importers or pharmacies and demand price reductions. It will be war with a capital W.

The reality is that Government dishes out most medicines in Malta for free. The most expensive ones are not bought in pharmacies, but are given away for free. So what in God's name are people bleating about? Who are these constant complainers who do so behind everyone's back? Where are the facts to back up the Government and Opposition's so called surveys on prices in Malta?

To give these medicines out, the Government has created a huge monolith employing hundreds of people, to purchase medicines by tender. Millions of Euros are wasted in bureaucracy and archaic work practices and even when presented with viable alternatives, the politician gives in to the supposed "experts" in the Civil Service thus making it as difficult to move forward as sending a man on the moon.  When it comes to paying for what it buys, then it's a matter of delays and obfuscation. Anyone tendering has to abide by a clause that payment will be made 150 days after goods are delivered. This is clearly in breach of the EU late Payments Directive, and the supposed EU representative in Malta is either blind, or deaf, or simply not bothered, and has not brought this to the attention of the EU. This is the example Government is setting in Malta.  Now we learn that it's not even allowing businesses to factor invoices due from Government departments. How ridiculous is that?

The other ludicrous lie that politicians wheel out regularly is that there are cartels in Malta. Cartels when people and businesses are at each other's throats all the time in this microcosm of a state? What utter hogwash. The only cartels formed are those done with Government sanction. A glaring example comes to mind. There is only one company that is allowed to carry out public registry searches and this by direct Government sanction. There are other examples.

The nub of the matter is that we try and impose large mass market formulas in Malta when in fact, these don't work at all. It may have escaped people's noses that our population is less than a small town in the UK or Italy. There is no appreciable mass market here in Malta which makes it easier to negotiate lower prices. There are many importers who have to plead with their principals to sell them a pallet when these people usually sell in trailer loads or container loads.

We also had some sea surrounding us the last time I looked. This means freight charges and expenses that are bigger because the market is small and there is no mass volume, so freight is expensive compared to bigger markets in the EU. At the port and anywhere else to get the goods delivered, the cost of transport is high.  Diesel costs money. Electricity costs more and more nowadays to keep things refrigerated and warehouses cool, especially food. Not many foodstuffs or medicines for the matter, can tolerate temperatures above 25 degrees Celsius. We have to have these standards, and that's how it should be. People expect that prices remain the same, although quality, quantity and choice have vastly improved. Well, it's just not going to happen. There is a limit as to how much people are prepared to invest in order to abide to today's standards, without raising prices.

Instead of lambasting the importer, get on your knees, raise your hands to heaven and thank him that he has managed to still provide you with a choice and range of prices. He does the impossible to do this; the costs of doing so are high in comparison to potential sales in Malta!

Yet, there is cut throat competition in Malta, but the baseline remains the same. It is the baseline of not having the weight of a mass market with volumes behind you that does not let you negotiate prices. It is also a baseline made up of disproportionately high expenses that encompass freight, certification, energy, storage costs, and distribution costs. The cut throat competition that does exist doesn't allow for high profit margins either.

Oh, and by the way, we still manage to employ your son, daughter, wife, husband, aunt, uncle, and God knows who else. We also keep at least half the mouths in the civil service, the people who are at the beach at the moment enjoying their half days whilst we toil in this heat, with food on their table and clothing on their backs with the wealth we generate and the taxes and VAT we pay. We get very little back in the form of service or increased productivity. I don't mean to generalise, but the Government employees who toil at all hours deserve a medal, and there are quite a few. Sadly, the majority don't have these high ideals of service. This is where politicians, all politicians have failed us. We trusted them on this one.

For all of those who believe in some ersatz communism tinged with pseudo-socialism, and want to introduce price controls, "difensuri tax-xerrejja", bulk buying and other forms of control, I say  get a life and leave us alone.  Take a trip to Sicily and fill up your cars!  Who is holding you back?

By all means strengthen the Office of Fair Competition. This is important because we need to foster more competition and more entrepreneurial spirit amongst the Maltese. By all means, make sure that the OFC comes down hard on cartels like a ton of bricks, not that they exist, mind. I'll bet my bottom dollar that most people don't even know what a cartel means and how it is created. They think that the pasta importers get together and agree on a price for every brand or some kind of infantile conspiracy theory you read about only in novels.

Recently Lidl opened its doors here with lower prices for what are mostly secondary brands. This bought a whole new arena in play. Lidl has failed to capture the majority of the market, however. The only reason why the rest of the Supermarkets are still in business is that Lidl don't always have your favourite brand. It's the poor supermarket owner who stocks all your favourite brands, has a delicatessen, and gives you oodles of choice, who has.

In a nutshell the consumer in Malta thinks it's their right to buy things at ridiculous prices, and expects products to be much cheaper than abroad. The only problem is that we are not a cheap economy. It costs more money for a business to operate in Malta than the UK. However a coffee is cheaper in Malta than the UK. It's cheaper to eat out as well. Clothes are not as cheap. But other things are. And the choice concentrated in Malta's shops is better than it has to be, considering everything.

If the Government wants to do something, then provide a  better access to finance mechanism than we have at the moment, reduce expenses, tackle your own shortcomings, implement Better Regulation well, and behave like a Government should, set an example and pay your bills on time. Foster entrepreneurship by making funds available for people to start businesses. Set up a structure that will guarantee these loans to first time businesses. Introduce a culture of value for money and productivity in Government departments itself, by involving the private sector in benchmarking exercises for the public sector. Reward people with promotions only based on merit and not on seniority.  And control the Unions. They are more to blame than anyone else, because they make it a point to defend archaic work practices.

As for the politicians, targeting us is a very cheap shot indeed. You attack us one day, and come to us for donations the next. And this applies to ALL parties! Shame on you!  The only time you had the chance to do something meaningful about prices is when you could have reduced the price of cars in Malta to reasonable EU levels. Instead, you have filled Malta with second hand cars from the UK. How short sighted!

And yet, these people want to compete with the private sector by using our tax money to set up and run importation enterprises that will end up being inefficient and will have to sell at a loss. They think that by doing this, they will force everyone to depress prices. They want to do it by using our tax money against us. Isn't this a form of subsidization? Is the EU listening?

Mario Debono

 

The aim of the proposal is to give legal effect to the revised Framework Agreement on parental leave, concluded by the European cross-industry social partners (BUSINESSEUROPE, UEAPME, CEEP and ETUC) on 18 June 2009. The revised Agreement extends male and female workers' individual right to parental leave from three months to four months and introduces several improvements and clarifications relating to the exercise of that right. Workers will be protected against discrimination on the grounds of applying for or taking parental leave. The return to work after the leave period will be facilitated, in particular by granting the workers the right to request flexible working. The Agreement and this proposal will contribute to better reconciliation of work, private and family life and to promoting gender equality on the labour market.

In its Resolution of 3rd September 2008, the European Parliament took the view that the Framework Agreement on parental leave could be improved by providing incentives for fathers to take parental leave, improving the employment rights of workers who take parental leave, making the leave arrangements more flexible and increasing the duration and pay during such leave.

On 3rd October 2008 the Commission presented two proposals both in relation to maternity leave and situation of self-employed women and assisting spouses. This ‘reconciliation package' was accompanied by a stocktaking report on the provision of childcare and by a policy Communication in which the Commission announced that it would take the necessary action, if the social partners so requested, to give legal force to a new agreement in the form of a proposal for a directive.

Existing provisions on issues relating to the proposal, provides for an individual right to parental leave of at least three months for male and female workers on the birth or adoption of a child. That right should, in principle, be granted on a non-transferable basis; however, many Member States have allowed parental-leave entitlements to be transferred from one parent to the other, which in practice has meant that mothers have taken longer parental leave than fathers.

The Directive also provides for the protection from dismissal of workers taking parental leave, for a right to return to the same/ equivalent job and for maintenance of employment rights during parental leave. It lays down the conditions governing parental leave and the detailed rules for applying it which the Member States and/or the social partners may determine at national level. Lastly, the Directive provides for the right for workers to take time off work for urgent family reasons in the event of sickness or accident that makes the worker's immediate presence indispensable.

Summary

longer leave – each parent would be able to take 4 months off per child (previously 3 months). The extra month could not be transferred from one parent to the other no discrimination

temporary changes to working hours – employees returning from parental leave would have the right to request changes to their work schedules for a limited period. In considering such requests, employers would be obliged to balance the needs of the employee as well as the company.

parents of adopted children / children with disability or long-term illness – governments and employers/unions would be obliged to assess the specific needs of such parents.

 

 

Objectives & Scope

The European Commission has proposed a European Regulation for the placing on the market and use of biocidal products,  replacing the Directive that was transposed into the Biocides Regulation. Once in force (scheduled for January 2013), the Regulation would equally act in all 27 Member States . The proposal is a reaction that the current regulatory regime for biocidal products is not working. The proposal keeps the concept of assessing active substances at EU level for inclusion in a positive list and then authorising biocidal products for the market. It also aims to improve and update certain elements of the system.

Among the key changes proposed are:

Extending the regulatory regime to cover treated materials containing biocides.

Adopting a centralised Community product authorisation scheme for some products.

Requiring mandatory data-sharing of vertebrate animal test data.

Reducing the burden of data requirements.

Harmonising the fee structure across Member States.

The proposed Regulation is scheduled to enter into force subject to making reasonable progress through the co-decision process involving the European Council and the European Parliament over the next 12 to 18 months.

In making its proposal, the European Commission has recognized there are significant problems with the existing BPD that have resulted in very slow progress in reviewing active substances. Furthermore, the high cost of supporting active substances through the review process has resulted in many existing biocidal products being withdrawn from the market for economic reasons. The proposed Regulation includes some welcome initiatives to address the problems with the BPD, such as the option of product authorisation at Community level instead of in each Member State.

Any comments are to reach the GRTU by writing or via e-mail on by not later than 8^th September 2009