Comment by ablob

You have to deal with this no matter what unless you can live with wasting storage space. You have to arrange extra sales or try and donate stuff (basically, go through all possible options that exclude it from being exempted) if you want to get rid of an item. Your estimates on sales count need to be pretty spot on to keep that low. Donations are still taxable where I live, by the way, so all that shenanigans is added too. It's not just about the report itself. You can't get rid of products not valuable enough to keep around without adapting your whole business model. Even if you are _not_ looking for an exemption, you will have to accommodate.

No one bothered to make any of the other options easier, only the previously simplest option was barred behind trying everything else. This is what over-bureaucratization looks like.

To use a different example: No one wants to switch to public transport (which is already crowded anyway)? No problem, just ban driving unless you can prove that it's orders of magnitude faster and it's not feasible to move your residence. No further preparation is done; no thought goes beyond the horizon. "Eat this rule and deal with it, you don't have to deal with the paperwork if you're willing to spend 2 hours more on commuting". That's the line of thought here. There are no plans to make it actually viable to use the train, the other options are just barred behind this veil of plausible optionality. You can do it, of course. The issue arises from doing this with literally anything you tackle.

You essentially only add rules and special cases without ever consolidating them or even considering possible impact on adjacent topics. Everything grinds to a halt by doing this and nothing ever gets simplified. It is a huge issue on a landscape that favored small businesses (that can't afford divisions dealing with this) when the way the law is written suddenly requires structures only big companies or consultancies can provide. It entombs the market structure and drowns any competition in regulatory capture. We haven't even seen what happens once the markets are dominated by oligopolies and monopolies. By that time the only way to deal with the fall out will be even more rules, as the competitive landscape will already be dead.

I'm not against the goal of this regulation, but the recent way the rules have been made favor a market structure I consider incompatible with the goals of the EU.