Legal analysis RDE ruling (2)
Dear Madam, Sir,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:
1. Background note of the Legal Service of 22 January 2019 (document reference Ares (2019)2632727)
2. Note of the Legal Service of 19 February 2019 to the Directors General of DG GROW (document reference Ares (2019) 1023442)
3. Revised background note of the Legal Service of 20 February 2019 (document reference Ares (2019) 3139320).
4. Commission Decision C(2019)1640 final, including draft version(s)
These are the same documents I requested on 5 March 2019 (GestDem 2019/1258.). In response, the Commission refused access to these documents referring to Article 4(2), second indent, of Regulation 1049/2001 - 'protection of court proceedings'.
The court case related to the above-mentioned document has come to a close with the 18 February 2022 decision, paving the way to full disclosure of the said documents.
Sincerely
Peter Teffer
postal address:
Peter Teffer
Ekko Voorkamer
Bemuurde Weerd WZ 3
3513 BH Utrecht
The Netherlands
Yours faithfully,
Peter
Dear Sir,
Thank you for your e-mail of 22 MARCH 2022. We hereby acknowledge receipt of your application for access to documents, which was registered on 24 MARCH 2022 under reference number GESTDEM 2022/1730.
In accordance with Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents, your application will be handled within 15 working days. The time limit will expire on 19 APRIL 2022 . In case this time limit needs to be extended, you will be informed in due course.
You have lodged your application via a private third-party website, which has no link with any institution of the European Union. Therefore, the European Commission cannot be held accountable for any technical issues or problems linked to the use of this system.
Please note that the private third party running the website is responsible and accountable for the processing of your personal data via that website, and not the Commission. For further information on your rights, please refer to the third party’s privacy policy.
We understand that the third party running the AsktheEU.org website usually publishes the content of applicants’ correspondence with the Commission on that website. This includes the personal data that you may have communicated to the Commission (e.g. your private postal address).
Similarly, the third party publishes on that website any reply that the Commission will send to the email address of the applicants generated by the AsktheEU.org website.
If you do not wish that your correspondence with the Commission is published on a private third-party website such as AsktheEU.org, you can provide us with an alternative, private e-mail address for further correspondence. In that case, the Commission will send all future electronic correspondence addressed to you only to that private address, and it will use only that private address to reply to your request. You should still remain responsible to inform the private third-party website about this change of how you wish to communicate with, and receive a reply from, the Commission.
For information on how we process your personal data visit our page Privacy statement – access to documents.
Yours faithfully,
DG GROW – Access to documents team
European Commission
Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs
DG GROW/B1 – Planning and Briefings
Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping
[5]Your request to access to documents - Ref. GestDem 2022/1730 -
Ares(2022)3067402 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Mr Teffer,
We refer to your above-referenced request for access to documents under
Regulation (EC) No 1049/2001 regarding public access to European
Parliament, Council and Commission documents (OJ L 145, 31.05.2001, pages
43).
Your request is currently being handled. However, in view of the number
and nature of the requests for access to documents the Legal Service is
dealing with, we will not be in a position to complete the processing of
your request within the time limit of 15 working days, which expires
today, 19 April 2022.
For this reason, this time-limit will be extended by 15 working days, in
accordance with Article 7(3) of Regulation (EC) No 1049/2001, to expire on
11 May 2022.
Thank you for your understanding.
Yours sincerely,
Access to Documents team
[6]cid:image001.png@01D8295E.30135E70
European Commission
Legal Service
Berlaymont
B-1049 Brussels/Belgium
[7][email address]
References
Visible links
1. file:///tmp/cid:filelist.xml@01D853D2.EFFECB40
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...
7. mailto:[email address]
Dear Madam, Sir,
I refer to Ref. GestDem 2022/1730.
Please note that the reason for the delay you have given is not in line with Regulation 1049/2001. Article 7.3 says: "In exceptional cases, for example in the event of an application relating to a very long document or to a very large number of documents, the time-limit provided for in paragraph 1 may be extended by 15 working days, provided that the applicant is notified in advance and that detailed reasons are given."
The number and nature of the requests for access to documents the Legal Service is dealing with, is not a valid reason for a delay. Each individual request may be of a specific nature that requires the exceptional delay to be triggered, but there is no legal basis for a delay because of the total number of requests.
If there are structural delays, the Commission should find ways to increase staff, prioitise work, update software and/or streamline processes - but the Regulation does not allow for extensions of the time limit simply as a consequence of the inability to handle requests within a certain time limit. The Legal Service above all, should know this.
Sincerely,
Peter Teffer
Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping
[5]Your request for Access to Documents - Reference: GestDem 2022/1730 -
Ares(2022)3577716 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Mr Teffer,
We refer to your above-referenced request for access to documents under
Regulation (EC) No 1049/2001 regarding public access to European
Parliament, Council and Commission documents (OJ L 145, 31.05.2001, page
43).
Your request is currently being handled. However, we are still not in a
position to finalise it within the extended deadline which expires today,
11 May 2022. Please be informed that we will do our outmost to come back
to you with a reply as soon as possible.
Apologies for this delay and for any inconvenience this may cause.
Yours sincerely,
Access to Documents team
[6]cid:image001.png@01D84517.6BC003E0
European Commission
Legal Service
Berlaymont
B-1049 Brussels/Belgium
[7][email address]
References
Visible links
1. file:///tmp/cid:filelist.xml@01D86516.BC0E2880
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...
7. mailto:[email address]
Dear Madam, Sir,
Please pass this on to the person who reviews confirmatory applications.
I refer to my access to documents request which was registered on 24 March with reference number GestDem 2022/1730.
On 19 April 2022, the Legal Service's Access to Documents team informed me that "in view of the number and nature of the requests for access to documents the Legal Service is dealing with, we will not be in a position to complete the processing of your request within the time limit of 15 working days".
I replied the next day to inform the Legal Service that the reason for the delay given was not in line with Regulation 1049/2001. Article 7.3 says: "In exceptional cases, for example in the event of an application relating to a very long document or to a very large number of documents, the time-limit provided for in paragraph 1 may be extended by 15 working days, provided that the applicant is notified in advance and that detailed reasons are given."
I told the Legal Service: "The number and nature of the requests for access to documents the Legal Service is dealing with, is not a valid reason for a delay. Each individual request may be of a specific nature that requires the exceptional delay to be triggered, but there is no legal basis for a delay because of the total number of requests.
If there are structural delays, the Commission should find ways to increase staff, prioitise work, update software and/or streamline processes - but the Regulation does not allow for extensions of the time limit simply as a consequence of the inability to handle requests within a certain time limit. The Legal Service above all, should know this."
These remarks were completely ignored by the Legal Service. Instead, I received a message today, 11 May 2022, to inform me that the Legal Service was "still not in a position to finalise [the request] within the extended deadline". There was no further explanation.
I believe that the original extension of the deadline was already lacking a legal basis in Regulation 1049/2001. The failure to meet even the extended - an extension which in my opinion was unwarranted - deadline without providing "detailed reasons" why more time is needed, is even more of an insult to the letter and spirit of Regulation 1049/2001. The fact that it is the Legal Service responsible for this blatant disregard of the Regulation, is perhaps the most disheartening part of the story.
Sincerely,
Peter Teffer
Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping
[5]Your request to access to documents - Ref. GestDem 2022/1730 -
Ares(2022)3998453 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Mr Teffer,
Attached, please find the Legal Service’s reply to your above-referenced
request for access to documents.
We kindly ask you to confirm and acknowledge, by return email, receipt of
the Commission Legal Service’s reply.
Yours sincerely,
Access to Documents team
[6]cid:image001.png@01D8295E.30135E70
European Commission
Legal Service
Berlaymont
B-1049 Brussels/Belgium
[7][email address]
References
Visible links
1. file:///tmp/cid:filelist.xml@01D87417.0B340CE0
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...
7. mailto:[email address]
Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping
[5]Confirmation of receipt - Ares(2022)4196001 (Please use this link only
if you are an Ares user – Svp, utilisez ce lien exclusivement si vous êtes
un(e) utilisateur d’Ares)
Dear Mr Teffer,
Further to our message below, and unless there has been an error on our
part, we have not received your confirmation on the reception of the
Commission Legal Service’s reply to your request for access referenced:
GestDem 2022/1730.
Accordingly, we kindly ask you to confirm and acknowledge, by return
email, receipt of the Commission Legal Service’s reply sent to you on
Monday 30 May 2022.
Many thanks and best regards,
Access to Documents team
[6]cid:image001.png@01D8295E.30135E70
European Commission
Legal Service
Berlaymont
B-1049 Brussels/Belgium
[7][email address]
From: SJ ACCES DOCS <[email address]>
Sent: Monday, May 30, 2022 11:25 AM
To: [FOI #10872 email]
Cc: SJ ACCES DOCS <[email address]>
Subject: Your request to access to documents - Ref. GestDem 2022/1730 -
Ares(2022)3998453
[8]Your request to access to documents - Ref. GestDem 2022/1730 -
Ares(2022)3998453 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Mr Teffer,
Attached, please find the Legal Service’s reply to your above-referenced
request for access to documents.
We kindly ask you to confirm and acknowledge, by return email, receipt of
the Commission Legal Service’s reply.
Yours sincerely,
Access to Documents team
[9]cid:image001.png@01D8295E.30135E70
European Commission
Legal Service
Berlaymont
B-1049 Brussels/Belgium
[10][email address]
References
Visible links
1. file:///tmp/cid:filelist.xml@01D87A57.8054E3A0
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...
7. mailto:[email address]
8. https://webgate.ec.testa.eu/Ares/documen...
10. mailto:[email address]
Dear Madam, Sir,
I confirm that as of today 21 June 2022, I have received the European Commission's reply to my access to documents request which was registered on 24 March under reference number GestDem 2022/1730.
Please pass this on to the person who reviews confirmatory applications.
The Commission has decided to fully refuse access to the documents I requested, referring to the need to protect court proceedings.
The Commission argued that "there are substantive legal issues related to the validity of the contested regulation which have not been adjudicated by the Court of Justice and that are likely to be the subject of future judicial proceedings (for example, requests for a preliminary ruling regarding the validity of the contested regulation)".
However, the Commission does not explain *why* it considers that it is “likely” that the regulation will be the subject of future judicial proceedings. Without such an explanation, it is a purely hypothetical and not a real and concrete assessment. I have not seen any party announcing future judicial proceedings related to this regulation.
Only when there is already a party which wants to open future judicial proceedings, can we speak of “the principle of equality of arms” – without a second party, one cannot speak of a need to “ensure a procedural balance between the parties to court proceedings”.
If the Commission is aware of any such intention, it should identify this party in order to make a convincing case that it is likely that regulation will be the subject of future judicial proceedings. If the Commission cannot identify any statement of intent to open future proceedings, its assessment that such proceedings are “likely” is nothing more than an unproven claim.
Furthermore, the Commission acknowledges that the validity of the regulation it has adopted is contested. I believe this alone is sufficient to conclude that there is an overriding public interest in publishing the requested documents.
The rule of law in our European democracy is one of the fundamental values of the European Union. Its importance is reflected in the fact that the respect for the rule of law is included in the second article of the Treaty on European Union.
The European Commission is tasked with ensuring that Member States uphold the rule of law. In that context, it is paramount that the Commission itself correctly follows legal procedures and adopts legislation in a way that is in line with the treaties. It should go without saying that it is in the public interest that when the Commission adopts regulations, this is done in line with EU law. This is why the initial judgment of the General Court of 13 December 2018 was so important: it established that the Commission was wrong to use comitology to adopt this regulation.
If the public has reason to believe that the Commission can ignore EU law when adopting regulations, this can greatly undermine the public’s trust in the EU. It is thus important for journalists such as myself to establish the arguments of the Commission’s Legal Service and reaction to this judgment. This public interest is far greater than the Commission’s desire to keep the documents confidential.
In closing, I take note that the Commission has chosen to ignore my e-mail from 20 April 2022, in which I told the Commission that the reason given for the delay in replying was not in line with Regulation 1049/2001.
I also take note that the Commission has chosen to ignore my e-mail from 11 May 2022, in which I filed a confirmatory application regarding the Commission’s failure to reply within the extended deadline and its failure to provide a detailed explanation for the delay that can be
regarded as being in line with Regulation 1049/2001.
Sincerely,
Peter Teffer
Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping
Dear Sir,
Thank you for your email dated 21 June 2022 by which you request, pursuant
to Regulation No 1049/2001 regarding public access to European Parliament,
Council and Commission documents, a review of the position taken by the
Legal Service in reply to your initial application GESTDEM 2022/1730.
We hereby acknowledge receipt of your confirmatory application for access
to documents which was registered on 22 June 2022 (Ares(2022)4588751).
Your application will be handled within 15 working days (13/07/2022). In
case this time limit needs to be extended, you will be informed in due
course.
Please be informed that the answer to your confirmatory application is a
formal Commission decision that will be notified to you by express
delivery. Thank you for providing your contact phone number, so that the
external delivery service can contact you in case of absence.
Please note that the Commission will not use your phone number for any
other purpose than for informing the delivery service, and that it will
delete it immediately thereafter.
Yours faithfully,
ACCESS TO DOCUMENTS TEAM (GD)
[5]cid:image001.png@01D45409.F767C980
European Commission
Secretariat-General
SG C.1
[6][email address]
Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping
[5]Your confirmatory application for access to documents under Regulation
(EC) No 1049/2001 - GESTDEM 2022/1730 - 1st holding letter -
Ares(2022)5132901 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Mr Teffer,
I refer to your email of 21 June 2022, registered on the following day, by
which you submitted a confirmatory application in accordance with Article
7(2) of Regulation (EC) No 1049/2001 regarding public access to European
Parliament, Council and Commission documents ("Regulation (EC) No
1049/2001"), registered under reference number above.
Your confirmatory application is currently being handled. Unfortunately,
we have not yet been able to gather all the elements needed to carry out a
full analysis of your request and to take a final decision. Therefore, we
are not in a position to reply to your confirmatory request within the
prescribed time limit which expired on 13 July 2022. Consequently, we have
to extend this period by another 15 working days in accordance with
Article 8(2) of Regulation (EC) No 1049/2001. The new deadline expires on
4 August 2022. However, I can assure you that we are doing our utmost to
provide you with a final reply within the new time limit.
I regret this additional delay and sincerely apologise for any
inconvenience this may cause.
Yours sincerely,
Mariusz Daca, Ph.D.
Deputy Head of Unit
European Commission
Secretariat General
Unit C.1 (Transparency, Document Management and Access to Documents)
References
Visible links
1. file:///tmp/cid:filelist.xml@01D8977F.20B76400
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...
Dear Madam, Sir
I refer to my confirmatory application for access to documents which was registered on 22 June 2022 (Ares(2022)4588751), and your decision to extend the time-limit to reply.
Article 8.2 of Regulation 1049/2001 says: "In exceptional cases, for example in the event of an application relating to a very long document or to a very large number of documents, the time limit provided for in paragraph 1 may be extended by 15 working days, provided that the applicant is notified in advance and that detailed reasons are given."
An extended time limit is thus only possible in "exceptional cases" and when "detailed reasons are given".
The only (not very detailed) reason you have now given me for the need to extend the time limit is that you "have not yet been able to gather all the elements needed to carry out a full analysis of your request and to take a final decision". Gathering all the elements needed to carry out a full analysis of a request is part of the standard tasks of handling an access to documents request, which the regulation requires is done within 15 working days.
Can you explain why you believe that reason to qualify as "detailed reasons" that show my application is an "exceptional" case?
Sincerely
Peter Teffer
Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
Dear Madam, Sir,
I refer to my confirmatory application for access to documents which was registered on 22 June 2022 (Ares(2022)4588751). (Initial application GESTDEM 2022/1730.)
On 14 July 2022, I was informed that the Commission needed to extend the time limit to reply until 4 August 2022. The next day I asked the Commission to explain why it believed that it had provided me with "detailed reasons" that show my application is an "exceptional" case, but I did not receive any reply.
I also did not receive a reply on 4 August 2022. Today is 22 August 2022, twelve working days later. If the Commission does not reply within 48 hours, I will file a complaint to the European Ombudsman.
Sincerely
Peter Teffer
Dear Mr Peter Teffer,
Please find attached the electronic version of the Commission Decision
C(2022)7566 as adopted by the European Commission on 18.10.2022.
The formal notification of the decision under Article 297 TFEU is being
made only in electronic form.
Could you please confirm receipt of the attached document by return
e-mail?
Many thanks in advance.
Kind regards,
Dimitra PROTOPSALTI
SG.B2 Procédures écrites, habilitation, délégation
[1]cid:image001.png@01D7CA95.913B9D20
European Commission
Secretariat-General
BERL 005/155
B-1049 Brussels, Belgium
Tél: (+32) 2 29 56750
References
Visible links
Dear Mr Peter Teffer,
Please, could you please acknowledge the receipt of the document enclosed
in the message addressed to you, by return email?
It is very important for us.
Kind regards,
Dimitra PROTOPSALTI
SG.B2 Procédures écrites, habilitation, délégation
[1]cid:image001.png@01D7CA95.913B9D20
European Commission
Secretariat-General
BERL 005/155
B-1049 Brussels, Belgium
Tél: (+32) 2 29 56750
From: SG GREFFE CERTIFICATION <[email address]>
Sent: Wednesday, October 19, 2022 2:37 PM
To: [FOI #10872 email]
Cc: WADHWANIA Nadia (SG) <[email address]>
Subject: C(2022)7566 addressed to Ekko Voorkamer - Peter Teffer
Dear Mr Peter Teffer,
Please find attached the electronic version of the Commission Decision
C(2022)7566 as adopted by the European Commission on 18.10.2022.
The formal notification of the decision under Article 297 TFEU is being
made only in electronic form.
Could you please confirm receipt of the attached document by return
e-mail?
Many thanks in advance.
Kind regards,
Dimitra PROTOPSALTI
SG.B2 Procédures écrites, habilitation, délégation
[2]cid:image001.png@01D7CA95.913B9D20
European Commission
Secretariat-General
BERL 005/155
B-1049 Brussels, Belgium
Tél: (+32) 2 29 56750
References
Visible links
Dear Mr Peter Teffer,
Please, could you please acknowledge the receipt of the document enclosed
in the message addressed to you, by return email?
It is very important for us.
Kind regards,
Dimitra PROTOPSALTI
SG.B2 Procédures écrites, habilitation, délégation
[1]cid:image001.png@01D7CA95.913B9D20
European Commission
Secretariat-General
BERL 005/155
B-1049 Brussels, Belgium
Tél: (+32) 2 29 56750
From: SG GREFFE CERTIFICATION
Sent: Friday, October 21, 2022 1:46 PM
To: [FOI #10872 email]
Subject: C(2022)7566 addressed to Ekko Voorkamer - Peter Teffer
Dear Mr Peter Teffer,
Please, could you please acknowledge the receipt of the document enclosed
in the message addressed to you, by return email?
It is very important for us.
Kind regards,
Dimitra PROTOPSALTI
SG.B2 Procédures écrites, habilitation, délégation
[2]cid:image001.png@01D7CA95.913B9D20
European Commission
Secretariat-General
BERL 005/155
B-1049 Brussels, Belgium
Tél: (+32) 2 29 56750
From: SG GREFFE CERTIFICATION <[3][email address]>
Sent: Wednesday, October 19, 2022 2:37 PM
To: [4][FOI #10872 email]
Cc: WADHWANIA Nadia (SG) <[5][email address]>
Subject: C(2022)7566 addressed to Ekko Voorkamer - Peter Teffer
Dear Mr Peter Teffer,
Please find attached the electronic version of the Commission Decision
C(2022)7566 as adopted by the European Commission on 18.10.2022.
The formal notification of the decision under Article 297 TFEU is being
made only in electronic form.
Could you please confirm receipt of the attached document by return
e-mail?
Many thanks in advance.
Kind regards,
Dimitra PROTOPSALTI
SG.B2 Procédures écrites, habilitation, délégation
[6]cid:image001.png@01D7CA95.913B9D20
European Commission
Secretariat-General
BERL 005/155
B-1049 Brussels, Belgium
Tél: (+32) 2 29 56750
References
Visible links
3. mailto:[email address]
4. mailto:[FOI #10872 email]
5. mailto:[email address]
Dear Madam, Sir,
I asked the Commission on 15 July 2022 if it could I explain why it believed that it sufficiently given "detailed reasons" that show my application is an "exceptional" case.
I did not receive a response.
I told the Commission on 22 August 2022 in an e-mail that I did not receive a response. There was also no reply to that e-mail.
On 19 October, the Commission FINALLY sends its response, after 85 (!) working days.
And when I do not confirm receipt immediately, you already start sending me multiple reminders WITHIN TWO WORKING DAYS? Because, I quote, "It is very important for us."?
Come on.
Peter Teffer