EFA has been in support of a proposal to facilitate cross-border activities of nonprofit associations in the EU. Now that an EU Commission initiative has in fact been tabled, the European Parliament, as well as the EU Council, will have to study the proposal and introduce amendments as they see fit. This round of decision-making provides an opportunity for non-institutional organizations, such as EFA, to offer input to the decision-makers as to which amendments would be needed to either protect or further strengthen the civil society sector. As such, EFA has joined a consortium of civil society organizations that align on specific matters, in order to strengthen the voice of its members in Brussels.

In the last edition of Fundraising Europe, I wrote that the European Commission adopted a proposal for a Directive on European cross-border associations, which aims to facilitate intra-EU cross border activities for NPOs, by removing some of the legislative and administrative burden. The Commission’s proposal introduces an additional legal form of a European cross-border association (ECBA) in Member States’ national legal systems, “which is specifically designed for cross-border purposes and will reduce legal and administrative burden when it comes to the recognition and establishment of nonprofit associations engaging in activities in another Member State”.

Points to address

Whilst the consortium supports the creation of an ECBA, it needs to be addressed that the ECBA proposal does not effectively cover foundations and does not provide for the creation of a European cross-border foundation. Therefore, in the future, a specific legislative initiative, similar to the ECBA, should also be proposed for foundations. The consortium also argues that guarantees against arbitrary restrictions based on ‘public interest’ should be strengthened.

Another problem has been identified in that the Directive seems to be exclusive towards non-Europeans. The consortium argues that for the ECBA Directive proposal to be effective, it must ensure that non-EU based people or associations (and other non-profit legal entities) can be members of an ECBA and hold leadership positions. The same exclusivity also seems to make it prohibitive for associations that include non-EU members to be converted to an ECBA.

Lastly, while taxation is not covered by the Directive proposal, the consortium expects that at the national tax law level, Member States could consider that foreign-based ECBAs will be considered comparable to local/resident ECBAs and hence donors giving to an ECBA registered abroad would receive the same tax incentive as if they were giving to a local ECBA.

EFA will continue to monitor the proposal as it makes its way through the stages of EU decision-making.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Picture by Antoine Schibler on Unsplash

On 5 September 2023, the European Commission adopted a proposal for a Directive on European cross-border associations, which aims to facilitate intra-EU cross-border activities for NPOs by removing some of the legislative and administrative burden. EFA has been in support of the European Parliament’s legislative initiative procedure of a similar name, calling for legislative action by the European Commission in this regard. As such, EFA is pleased to see that the EU Commission has now tabled this proposal.

The history of the proposal

In 2020, led by Rapporteur MEP Sergey Lagodinsky, the European Affairs Committee tabled a report calling on the Commission to put forward a directive on common measures for NPOs and also a Regulation establishing a statute for European cross-border associations and nonprofit organisations. The proposal recognised that NPOs in particular faced multiple legal and administrative challenges when attempting to operate across borders. It argued that minimum EU standards and being able to acquire a legal personality would help NPOs overcome these barriers.

In February 2022, the European Parliament adopted this proposal with an overwhelming majority. On 5 September 2023, the Commission followed through with their proposal for a Directive. Currently, national legal provisions for NPOs are patchy, and insufficient to build a real pan-European civil society. NPOs do not receive uniform acknowledgment of their legal personality and capacity, and often need to register for a second time or even form a new legal entity in that Member State. An estimated 310,000 nonprofit associations are currently affected by those obstacles.

What’s proposed

The Commission’s proposal introduces an additional legal form of a European cross-border association (ECBA) in Member States’ national legal systems, “which is specifically designed for cross-border purposes and will reduce legal and administrative burden when it comes to the recognition and establishment of non-profit associations engaging in activities in another Member State”. Once established in one Member State, an ECBA will be recognised automatically and will be able to engage in activities in all Member States, including economic activities, thereby allowing non-profit associations to flourish across the EU with minimal barriers to their operations.

Whilst the European Parliament had asked for Regulation as well, which is arguably a better tool for harmonization, the Commission chose to propose a Directive instead, which offers more flexibility for implementation by the Member States. The likely reason for this will be the difficulty to harmonize what has been described as a patchwork of 24 legal systems.

What’s next

Since this proposal was born in the European Parliament, it is likely to receive continued support from this institution, which will ultimately enter into negotiations with the EU council. The question is which amendments to the Commission proposal the Parliament might table and whether these will be good for NPOs. It is important for civil society to monitor these developments closely, and to inform decision makers when and where necessary regarding the potential impact their proposals and amendments might have on NPOs’ operations, thereby shepherding the proposal to a positive outcome.

For more on this: read our news story here. 

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Picture by Jonas Horsch on Pexels

The second half of 2023 is looking to be a hectic period for the EU to say the least. With several major crises already disrupting the Brussels decision-making scene, and the Spanish EU Presidency in disarray due to internal political struggles, the upcoming EU Parliamentary elections are expected to further paralyse the regular policy agenda, causing inertia in the files that are relevant for the fundraising community.

Slow moving files

Over the past year(s) we have been following a number of items on the Brussels policy agenda, on behalf of EFA, that directly or indirectly affect fundraisers and NPOs, such as the e-Privacy regulation, and potential new rules on unaddressed advertising. It can be incredibly challenging for NPOs to determine which EU rules apply to them and how to properly comply. Legal certainty in key areas such as donor outreach and data maintenance is therefore crucial. However, due to their sensitive nature, these files are already notoriously slow-moving and subject to much lobbying, which causes legal uncertainty for all stakeholders involved. Recent crises such as the ongoing situation in Ukraine and the European Parliament’s very own scandal “Qatargate” have slowed things down even further.

EU presidency challenges

As if that is not challenging enough, the Spanish EU Presidency is in disarray due to their own election woes back home. The EU Council is the collective of 27 Member States, and is responsible for setting the EU policy agenda. Every six months, another EU Member State takes the Presidency of the Council and therefore strongly influences said agenda. But since Spain is currently in a governmental crisis of its own, it is unable to carry out the EU Presidency in a unified manner, which causes many policy items to be put on hold – likely until January when the Belgians take over the EU Council Presidency. To top it all off, next June, a new EU Parliament will be elected. This means that after the summer, MEPs seeking to be re-elected will start focusing on their re-election campaigns which, again, hampers the progress of current policy negotiations.

An opportunity for the fundraising community

So, does this mean that we will just have to sit back and wait for things to start moving again? No. I would argue that this period can uniquely be used as an opportunity to make the needs of the fundraising community known. Members of the European Parliament tend to be more susceptible to external input when seeking to be re-elected, and promises might be made a little easier. Organizations that have an interest in influencing EU decision-making would do well to think about running their own campaigns during these election times. Well targeted campaigns can result in commitments made by decision-makers now, that can help the sector in its negotiations later, once the election dust has settled. EFA remains at your disposal.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Picture by anisenior on Pixabay

The Swedish EU Presidency is approaching its final month of chairing the EU Council. With several crises, such as the security crisis in Ukraine, overshadowing the Brussels policy agenda, important files for EFA members remain in limbo as working parties at EU level were unable to make meaningful progress. As Sweden will soon be handing the reins to Spain – where do we stand?

AMLD

One file that did make it to the finish line (well, almost) is the package on Anti Money Laundering and Terrorist financing. The three core pieces of draft legislation within the AMLD package – the EU “Single Rulebook” regulation; the regulation establishing the European Anti Money Laundering Authority (AMLA); and the actual 6^th Anti-Money Laundering Directive – have been adopted by the European Parliament’s lead committees in March, followed by a mandate by the European Parliament’s plenary to enter into inter-institutional negotiations. Once the Parliament and the Council come to an agreement, the implementation phase can start.

e-Privacy

Far less progress was made on the e-Privacy file, which is of high relevance to EFA and its members as well. One of the core elements of this proposal is the regulation of digital and telephone outreach by organisations to citizens. Those organisations engaging in telephone outreach would be identifiable as such by a new telephone prefix, which in itself might not be a problem. However, telecom carriers might be given the option to offer blanket blocks of said numbers to their customer base. In other words, enabling customers to opt out of being called by numbers carrying this prefix. If such a rule is adopted, in practice that would mean that these prefix blocks would technically and effectively override the explicit consent to be contacted that NPOs have received from their donors and potential donors. This could have major implications. The rules are aimed at direct marketers but will also affect NPOs, as they too rely heavily on direct outreach by telephone and would fall within the scope of the proposed rules. The proposal has been in a deadlock at European Council level and there does not appear to be an appetite to push the matter up on the agenda – leaving potentially affected stakeholders in suspense.

Door drops

Regarding the file on unaddressed printed advertising, a.k.a. door drops, pressure from certain EU Member States on the EU has been mounting. These Member States advocate the introduction of an EU-wide opt-in scheme regarding unaddressed printed advertising. Needless to say that this proposal is making NPOs across Europe nervous, as they rely heavily on door-to-door advertising to raise awareness for their causes and to garner support and donors. Currently, most countries have opt-out schemes in place. Whilst people that do not wish to be approached are likely to take the necessary actions to opt-out of unaddressed advertising, NPOs fear that not many citizens would go out of their way to opt in to receive it, which would make the jobs of fundraisers more difficult and could mean a significant reduction in potential donors. So far, the EU has not taken any steps towards drafting an EU proposal on the matter, but it is important for the sector to actively educate the EU institutions as to the negative implications of such a measure.

Cross border activities of associations

On a more positive note, the European Parliament’s resolution on cross-border activities of associations was well received. The European Commission followed up with a public consultation and is now expected to table a proposal, possibly in the last quarter of 2023. The initiative seeks to ensure full single market freedoms for associations, simplifying their cross-EU activities and promoting their fundamental rights.

EFA will remain to be your eyes and ears in Brussels and we will notify you of any relevant developments at EU level.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

The European Council is the EU institution that defines the general political direction and priorities of the European Union. The Council is led by its Presidency, which is held by one of the 27 EU membership on a 6-month rotating schedule. This way, every European Member State gets a chance to push their national priorities by setting the EU policy agenda. Therefore, knowing the work programme of the current (and future) Presidency is an important part in EFA’s own EU agenda setting. On 1 January Sweden took over the EU Presidency. These are the priorities relevant for EFA.

The fundraising sector has historically been an attractive target for money launderers. EFA is aware of this and has been actively involved in the EU developments regarding Anti Money Laundering and terrorist financing. The Swedish Presidency will seek to continue the fight against international crime by advancing the efforts to tackle money laundering and the financing of terrorism. This will involve advancing the negotiations on establishing a new EU body in this area and on the ‘rulebook’.

Similarly, EFA has been quite active on the upcoming ePrivacy Regulation, which is currently making its way through the EU decision-making procedure. As I have written before in Fundraising Europe, some of the proposed changes in the Regulation can have a substantial impact on the day-to-day business of fundraisers and other NPOs.  The Swedish Presidency will continue negotiations with the European Parliament on the ePrivacy Regulation.

The Swedish Presidency has also indicated that it will continue the work on the proposal for new VAT rules for the digital age. At the end of last year, the European Commission published a legislative proposal regarding VAT in the digital age – the “ViDA initiative – as part of its action plan for fair and simple taxation. This package aims to improve VAT efficiency and to minimise VAT fraud. This is done by modernising VAT reporting obligations and facilitating e-invoicing, extending the scope of the VAT rules for the platform economy and moving towards organizations having one single VAT registration in the EU. Given the cross-border nature of many fundraisers and NPOs, this is an initiative on EFA’s watch list.

Lastly, the EU has been moving forward on a proposal for a regulation on the transparency and targeting of political advertising. Because definitions in this proposal are considered to be a bit vague and “muddy” there is a risk that new rules might affect the work of NPOs as well. The Swedish Presidency has indicated that it will work to advance the EU’s work regarding the negotiations on the Regulation on the transparency and targeting of political advertising. EFA will monitor this file closely in order to signal any potential unintended consequences for fundraisers in their campaigning and outreach work.

EFA will keep you informed on any relevant developments regarding these files. On 1 July 2023, Spain will take over the EU Presidency from Sweden, at which time we will re-evaluate the police agenda.

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

On more than one occasion, I have written in Fundraising Europe about the new e-Privacy Regulation, currently in the negotiation procedure inside the EU institutions. As negotiations in Brussels on the new e-Privacy Regulation near conclusion, a crucial element that may adversely affect the daily work of the fundraising community has still not been resolved.

As outlined in previous articles, the e-Privacy Regulation primarily aims to protect EU citizens from data abuse and privacy violations by large tech companies. Whilst such protection is, in principle, something EFA can support, there is a real danger for the fundraising community to become collateral damage in the EU’s battle against big tech.

Specifically, the EU proposes a prefix to be given to all organisations engaging in direct marketing, which includes telephone outreach campaigns. Whist this does not necessarily pose a problem, there is a complicating factor as the Institutions are also looking to give Telecom operators the option to offer blanket-blocks of said prefixes to their customers, making it impossible for these numbers to call them. This would essentially mean that donors or potential donors who have given their explicit consent to be contacted, could effectively no longer be contacted if they opt to make use of the blanket block of numbers carrying the prefix. In other words, the technical act of blocking these numbers, overrules the legal consent given by the donor.

There have been attempts to exempt fundraisers and other NGOs from this potential new rule but, judging by the latest negotiation documents  – as seen by EFA – recital 32 still states:

“The concept of to direct marketing communications should not only cover the directly and individually addressed or received advertising of products and services for commercial purposes, but also include direct marketing communications that are sent by political parties or non-profit organisations to natural persons via publicly available electronic communications services in order to promote their parties.”

This would mean that EFA and its members would fall within the full scope of the proposal for an e-Privacy Regulation. EFA will formulate a message to share with the European Parliament. We would encourage you to reach out to your Member(s) of the European Parliament to warn them against the dangers of such a measure.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Main image by Towfiqu barbhuiya on Unsplash

Each year, the European Commission adopts its annual work programme, listing the main actions it will take in the coming year. The programme informs the public and other institutions about new initiatives the Commission will present, as well as pending proposals to be given priority, those to be potentially withdrawn, and existing EU legislation that will be reviewed.

On 18 October, the Commission presented its work programme for 2023 – a task not to be underestimated in the face of the Russian aggression and rising energy prices plaguing the already fragile post-COVID landscape. We see these realities translated into a bold programme and digital transformation plays a key role in this with the Commission vowing to place citizens at the heart of decision-making.

In its 43 new policy initiatives, the Commission has based itself on the six pillars it set out at the beginning of its mandate: A European green deal; A Europe ready for the digital age; An economy that works for the people; A stronger Europe in the world; Promoting our European way of life; and A new push for European democracy. In addition, the findings of the Conference on the Future of Europe have played a role in the design of this programme. In particular, it was decided here that citizens should be more closely involved in policy-making.

Commission President Ursula von der Leyen said at a press conference that Europe is facing a confluence of crises due to the “barbaric invasion of Russia in Ukraine”. The citizens’ agenda will therefore be paramount. Protecting citizens typically goes hand in hand with an increased focus on privacy and data protection. Indeed, the E-Privacy Regulation remains a “Priority Pending Proposal” in the Commission Work Programme.

Whilst these are positive developments in principle and the continued protection of EU citizens is important, it is of equal importance for civil society to be involved to ensure that protection does not turn into over-regulation. This also means the Commission will continue to find itself caught in a balancing act between offering adequate protection to citizens and not placing unnecessary administrative and regulatory burdens on NGOs and other organisations serving these citizens.

The European Commission will now discuss a list of joint priority legislative proposals with the European Parliament and the Council. The latter will itself come up with a 6-month work programme by the end of this year, under the leadership of the Swedish Presidency, setting out the collective’s priorities to EU Member States from January to June 2023. After that, Spain takes over.

EFA will continue to monitor any relevant developments and remains at the disposal of the European Commission to exchange views on behalf of fundraisers, charities and other NPOs.

The official documentation on the European Commission’s work programme can be found here.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Picture by Pixels2013 on Pixabay

In a move that might set a precedent for other European countries, Switzerland recently confirmed the freedom of advertising at the mailbox. A motion by the Nation Council to restrict unaddressed letterbox advertising by means of an opt-in regime was turned down by the responsible Council of States Commission by an overwhelming majority of 8 votes to 1 with one abstention. Whilst Switzerland is not a member of the EU, the decision might influence ongoing discussions on the topic at EU level, as well as within individual Member States.

The discussion is not new. In fact, I first wrote about the subject for Fundraising Europe a little over two years ago, when several EU Member States (Netherlands, Belgium, France, Denmark and Germany) proposed to change the current opt-out approach for receiving unaddressed printed advertising to an opt-in approach. However, many nonprofits rely on these ‘door drops’ to build awareness within the local community and beyond and encourage supporters to donate, raising concerns about the impact of restrictions to this fundraising channel.

Door drops and the opt-out system are a part of the EU’s 2005 Unfair Commercial Practices Directive. If the EU were to adopt an opt-in approach, nonprofits would no longer be able to send unaddressed mailings to any households, unless they proactively permit them to do so. Few people are likely to do so, which would have a significant negative impact on fundraising organisations and their opportunity to rebuild income levels at a time where many are facing critical funding shortfalls.

At the time, The European Fundraising Association had signed a joint letter (along with Intergraf, FEDMA, the European Letterbox Marketing Association and others), calling on the European Commission to address this issue with the Member States concerned. The letter asks for clarification that any restrictions on this form of advertising need to take into account the principle of proportionality and must be compliant with EU law.

In May 2022, I reported that the Danish government was considering legislation that would introduce a regime banning unaddressed printed advertising. Denmark has made similar attempts to curb unaddressed printed advertising in 2012, 2016, and 2020. The European Commission clarified at that time that “Directive 2005/29/EC bans unsolicited advertising by remote media if it is persistent and unwanted. Assessments of the compatibility of national rules with this directive depend on their exact wording, but an opt-in scheme seems to go further than this ban.

Whilst attempts to introduce opt-in regimes have thus far been largely unsuccessful, there remains an appetite in some European countries for curbing the way organisations can reach out to citizens. EFA sees the Swiss decision as a step in the right direction and hopes that this will be reflected in EU Member States as well. EFA and its partners will continue to monitor the situation closely.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Main photo by AC works Co Ltd on Pixabay

Every six months, one of the 27 EU Member States takes over the Presidency of the Council of the European Union. The reason why this is often referred to as the “EU Presidency”, rather than just the Council Presidency, is the fact that the agenda set by the Presidency sets the course for all EU decision-making for that six-month period.

These days EU Presidencies are organised in “Trios” which means that three consecutive EU Presidencies agree on an overarching programme ahead of their combined 18-month term. In other words, whatever course they decide to take will have a significant impact on the legislation coming out of Brussels during that time. The Czech Republic is the second Presidency in this trio, preceded by France and followed by Sweden.

The past years and months have seen a big push by the EU towards strengthening the rights and freedoms of citizens. Whilst this is of course a positive development in principle, we have also seen that an overzealous approach towards privacy protection can have negative implications for fundraisers and other not-for-profit organisations (NPOs). In the Programme of the Czech Presidency of the Council of the European Union, the Czechs announced that they will build on the work of their French predecessors, keeping a strong focus on the protection of (digital) rights of citizens. Whilst supporting the general principle, it is important for EFA and its members to remain vigilant and to educate decision-makers regarding any undue negative implications legislative proposals might have on the sector.

Whilst there is not much EU legislation drafted specifically for the fundraising sector, we have been following and reporting on a number of EU legislative proposals that can have a direct or indirect impact on how fundraisers and NPOs carry out their day-to-day business. Most of these proposals are designed to protect citizens’ rights, and more specifically their privacy. Whilst these proposals are drafted in essence to curb large online players, EU legislators often underestimate the collateral damage on the NPO sector.

We all know the General Data Protection Regulation by now, and the limitations it imposed on the work of NPOs, as well as a significant increase in administrative and regulatory burden. More recently, an ongoing revision of European e-Privacy legislation could kill all telephone and online outreach to existing and potential donors. But it is not just online limitations, for some time now the EU has been mulling the introduction of an opt-in regime for unaddressed mailings, which would make it virtually impossible to deliver leaflets or any other materials door-to-door in order to attract donors.

In their Presidency Programme, the Czechs outline that they will keep on this same course and take over the agreement of the European Declaration on Digital Rights and Principles, which was presented during the French Presidency. EFA will keep monitoring our relevant legislative files closely, together with our coalition partners, and we will set out to educate decision-makers regarding the potential implications of these proposals on the sector. This way we hope to contribute to a balanced approach that considers all stakeholders involved.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

Main photo by Martin Krchnacek on Unsplash

In previous editions of Fundraising Europe, I have written about upcoming changes in EU Privacy legislation that could negatively impact nonprofit organisations and fundraisers. One of these is the ePrivacy Regulation, which will replace the existing ePrivacy Directive and is currently under negotiation.

The ePrivacy Directive is a piece of EU legislation closely connected to the GDPR but zoning in even more on what data may be harvested. And the new ePrivacy Regulation focuses specifically on outreach by telephone. The proposed Article 16, which covers unsolicited and direct marketing communications, states that any ‘natural or legal person’ using electronic communications services for the purposes of placing direct marketing calls shall either present a calling line identification (caller ID) on which they can be contacted or present a specific code or prefix identifying the fact that the call is a marketing call. The proposal furthermore outlines that the same applies to calls made by nonprofit organisations to support their purposes.

However, an added danger lies in the recent negotiations between the European Parliament and the Council, with a new proposal to replace the option of a calling line or a prefix with a mandatory prefix. Whilst NGOs and charities are in favour of the identification of their calling lines, a mandatory prefix would generate the false impression that their calls are for commercial or marketing activities instead of fundraising for activities in the general interest.

The work of nonprofit organisations, such as charities and NGOs, is essential for the EU. Their assistance during the COVID-19 crisis proved a crucial key to helping overcome economic and social problems. They support vulnerable people; they help protect the environment and safeguard human rights. Many of them are now at the forefront, raising funds and helping the people of Ukraine.

Particularly at a time when other forms of fundraising continue to be under pressure, blindly grouping NGOs and charities in with direct marketing organisations, whilst sticking them with a mandatory prefix could severely impact their important work. In a letter to the decision-makers, EFA has therefore called on the EU institutions involved in the negotiations to take this adverse impact into account and to stick to the text that was proposed by the European Commission, and agreed by the European Parliament.

EFA will continue to closely monitor the developments regarding this file.

Patrick Gibbels, Gibbels Public Affairs

About Patrick Gibbels

Patrick is EFA’s public affairs columnist in Brussels.

He is the director of Gibbels Public Affairs.

Follow Patrick @GPA_Brussels.

Read more from Patrick in our View from Brussels column here.

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