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Comment by yardie

8 hours ago

One of the biggest problems that I have in the EU is that it's almost federated. EU will pass laws, countries will adopt those laws, but you end up with 20-24 different versions of those laws. With some countries being strict or lenient about the law that everyone agreed to. And a lot it is written from the perspective that large corporations are the only ones who do business throughout the EU. It's completely missed that small entrepreneurs may also want to take part. Modern technology makes it feasible, but old ideas just drags it down.

Yes. I used to sell objects on Amazon in Europe. You can sell from just one country, but then each sale outside of that country is an "export" that triggers high fees.

For sales to be "local", products need to be stored in warehouses in each country. But that in turn means the owner of said products (the seller) has to be registered for VAT in that country, and submitting annual reports in each country's language.

I went to the trouble of registering in 6 different countries; in some countries, Amazon more or less helps sellers submit reports; in others, they offer to partner with local lawyers.

The result is a mess of reports, injunctions, penalties for late filing, etc. coming to you in Polish, German, Spanish, Hungarian. I eventually gave up.

Europe is not actually a "single market". It's a federated bureaucracy entirely indifferent (or hostile) to small businesses.

  • Having worked on the inside: this is by design. You know for 100% that Pepsico and Coca Cola unleashed an army of lobbyists to make sure the laws were written in a way where the single market only worked for large business.

    • It's comforting to believe that large corporations with the greed of the rich and powerful is what makes these inefficiencies but really it's about a million little political negotiations, primarily driven by voters dislike of change.

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  • Is that with the One-Stop-Shop regulation or was that before that?

    If it was before than, then the EU recognized the problem and implemented a fix for it.

    • Yeah, it only took 4 years for them to fix an obvious screw up. Only 4 years. Surely every business can survive that.

    • I don't think any EU One-stop-shop scheme covers "local" goods sales in other EU member states yet, i.e. an EU company has to register in all EU countries they hold stock in.

      That is changing with the Single VAT Registration (SVR) legislation, effective in 2028.

    • This was 2017-2021. Not sure if One-Stop-Shop covers this as it mentions "cross-border sales" and the problem with Amazon fulfillment and storage was to make all sales local (not cross-border). But maybe it does cover it. I don't know.

  • Kinda sounds like it would have been cheaper, more profitable, and less of a PITA for you (a European!) to sell in the US?

  • Let's say I'm a German small business owner.

    Tomorrow Europe becomes a single market. How do I compete with a similar business but from a country where business costs are significantly lower ?

    • How does a Californian company compete with a company in Missouri that has lower labor costs and less overhead/ regulation?

      They seem to manage this just fine, but it's a pretty similar scenario. You could also push for standardized business costs and regulations eu wide ofc to help.

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    • You boast about the superior quality of german manufacturing. Or move your manufacturing to eastern Germany where costs are lower.

    • You specialize in things that are more difficult to make in poorer countries - you use your advantages they use theirs. Afterall this is what happened to a lot of Polish industry after we got our EU membership - it died under pressure of already developed competition from countries like Germany.

> And a lot it is written from the perspective that large corporations are the only ones who do business throughout the EU. It's completely missed that small entrepreneurs may also want to take part.

I'm not convinced that's an accident. I think politicians in Europe are just better than those in the US at hiding who they really work for.

There are numerous examples of regulations in many European countries that create a glass ceiling for anyone who strives to be more than just middle-middle-class, while creating effective loopholes for the wealthy to continue multiplying their wealth.

For example, the total (State + Federal) top tax rate for someone living in California or New York is not too different (maybe 2-3%) from someone living in France or Sweden. But the difference is that in California the top rate does not kick in until you earn north of $1M per year, while in Sweden or France the middle class is already paying those rates.

Likewise, in the US you cannot (legally) shelter your income by declaring it to be foreign income, as you can in most European countries. That is a tax dodge not applicable to the middle class.

And then we have the present discussion: The compliance costs are of course too high for any small business, so these regulations are just another form of regulatory capture to prevent anyone new from breaking into the upper class, while allowing those already there to have it easy.

  • It's a success of the upper class to pit the middle class against the lower class and the immigrants. As long as people on one "side" complain that there is too much foreign culture and they'll all be replaced and/raped and the other "side" sees the racists as their main enemy, the rich have an easy time.

Living in Europe, I find that with LLMs, it is possible to navigate the federal & law jungle. However, LLMs don't protect you from institutional envy or the resistance of people trying to block progress simply because it is perceived as 'too modern' or disruptive. I find this the hardest challenge. And I have the feeling during times of general decline, like these, it gets worse.

  • And it's like there's a uno card that's "increase taxes for freelancers". And they sure like to use it.

    • That makes sense given the structure of the society, no? If you were to build an organization whose purpose was a predictable amount paid out to the senior most members committed ahead of time for an indefinite period, you would prioritize predictable income. In the ideal, your contracts would all be long-term contracts that don’t fluctuate very much.

      Any entity that seeks to take risks to earn outsize income increases the income variance and makes it hard to organize your committed payouts. So you are forced (by your priorities) to discourage the entrepreneur and freelancer and encourage the 18-60 salaried employee. Fixed fungible production unit can be used as an input to a machine that produces committed output.

      Then you import guest-workers etc. to improve throughput. You are forced by your priorities. Probably the expansion of the US welfare state will meet similar constraints soon enough.

      It’s a bit just-so so I think there’s an over-claim in there but I think the seed is there.

  • Right, it's a zero-sum mentality versus a growth mentality. When people don't believe that growth is possible then they focus on guarding what they have.

  • I personally hate the "reenact" the old- good times to recreate the prosperity cargo cults. What created those prosperous times, where "characters" that would just do things, and ask for forgiveness by the law later. And that was actually priced into the justice system, by giving the judges a range to verdict from. In a way, the rule of law was much less strict in the 50s and 60s and way more informal.

US Sales tax is the exact same way. Each state has a different rate, Texas has multiple rates inside a zip code you have to manage. Each state also has a nexus requirement that is either money, or number of transactions based. Then the filings you have to do and have a Foreign LLC registration, a registered agent in that state, and a yearly annual report to file to tell them you are still in business and here is my $40-200.

  • Except you can sell through Amazon (or other online store) and they will manage all that for you as a single fee. Exactly the solution that the article proposed for the EU rules.

  • Except you don’t have min threshold requirements for neither PPWR nor WEEE, it's before you can sell anything. And you need to register, hire an authorized agent and get contract (which always has minimal amount rather than per-kg pricing) with local recycling company in each member state.

    Also you have Streamlined Sales Tax Registration System (SSTRS) for actual registration in US which covers 24 states.

> It's completely missed that small entrepreneurs may also want to take part

This is by design. It’s the same all over the world. The wealthy are not going to just let you compete

  • Dunno about that. I live in the US. I can start a small business today and the only thing I'd have to do differently is file an additional form on my taxes next year. Yes, that's a simplification that doesn't apply to every situation, but it is still completely accurate.

    • That's pretty much the situation in the UK if you are a sole trader. If you set up a limited liability company, that's a separate entity and has its own tax reporting requirement, but nothing onerous. I am a sole trader, and manage a small company separately from that.

      One thing I have heard of in the USA is the need for a "business licence". I'm not sure what that is or whether it applies to all businesses, so I'm not sure what it would correspond to in the UK. Neither of my businesses needed any licences or permissions to start trading.

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  • Laws are voted by politicians. Do you mean that most EU politicians are puppets of EU corporations?

  • It is not the same all over the world. Starting a small company in the US is a breeze compared to what I’ve watched peers in the EU fight against.

    • Back in college (USA) friends would spin up LLCs for the summer just to buy mowers or vans to do yard work. They would hire all the students who didn't get summer jobs. Those hired students would make about 3x a STEM intern makes in western europe today.

    • Interstate commerce also seems to be vastly easier inside the US in comparison to the alleged single market of the EU. The most companies seem to deal with is California-specific regulations. Meanwhile, most companies in the EU eventually opt to create a ton of subsidiaries, basically one per state, to handle all the localized duties that the EU requires.

  • well said. like WB said, "There's class warfare, all right, but it's my class, the rich class, that's making war, and we're winning."

  • That is the issue across the entire world. Large corporations can easily bear the cost of regulatory laws, environmental requirements, rules, and regulations. They can also go to great lengths to promote an environment that is almost nightmarish for a smaller company or entrepreneur trying to enter the game.

    They create barrier after barrier through their lobbying efforts. A good example is having to pay $50,000 for an inspector to come and determine whether your automatic door opens and closes properly, or to verify that your facility does not have a chimney. A friend of mine who owns a business in Niagara Falls, Canada, had to pay around $10,000 for a wind assessment to determine where chimney exhaust would go once released. He didn’t even have a chimney. They ended up having to have another inspection to verify they didn't have a chimney.

    Many of these environmental laws are intentionally created and applied to small businesses as well, even when the cost of meeting the requirements is greater than what the business could realistically generate in sales.

    The result is that large corporations can absorb these costs, while small businesses and entrepreneurs are often priced out before they even have a chance to compete.

  • The US is wealthier, has more billionaires and has fewer of these barriers for small entrepreneurs. So no, this is not the monocausal explanation that applies equally everywhere.

    (YES, the US has regulatory capture, YES the wealthy attempt to use it, YES we should try to eliminate it here too, but it remains true that it is easier to run a small business in the US, while having more billionaires. There are other explanations to the differential here).

    • Agreed, europe has a culture of "stability" first. The fear of disruption and chaos is larger after two WW and it outsourced the risks of disruption to the US. Basically, use the us as a test-mouse for new ideas and innovations, then when proven safe introduce them and ride those coat-tails to infinity.

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Even medium-sized corporations are not willing to send products across borders to consumers (say, outside Germany), further destroying the single market.

>One of the biggest problems that I have in the EU is that it's almost federated

I would argue it's even worse, because with properly designed federated system you get checks and balances to some extent.

There are parts of EU that have almost zero oversight.

  • Can you elaborate more? When you say "checks and balances" do you mean explicit legal mechanisms or implicit mechanisms like Tiebout-style foot voting? For the latter areas with "almost zero oversight" seem advantages. Also, can you give an example of these low-oversight places and how it manifests? I'm thankful even for some pointers in what to search for.

  • Yeah, this in between state is really frustrating. I hope we will see a push towards more federalization, but that’s unlikely

    • It’s unlikely because smaller member states wouldn’t want that as they’d be outvoted by bigger members and thus forced to implement laws that might not even make sense in those (smaller) countries.

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I think this is a big factor. While I would prefer a more federated US, the US as is is a great market to start in. It's 350M fairly wealthy people under mostly the same tech restrictions. That's a great place to grow.

It's important to remember that even without the fact that big companies basically write the regulations, regulations naturally tend to being effectively regressive wrt company stage/size. Every new one is a hurdle that a bigger company has more resources to overcome.

  • > It's 350M fairly wealthy people under mostly the same tech restrictions

    and, on a case-by-case basis, those people are generally happy to adopt other states' standards in the name of convenience and efficiency (California notwithstanding). Look at E-ZPass/I-Pass as a great example of harmonization across states.

    It's funny. Ask any Illinoisan how they feel about adopting Ohio's policies and they'd bristle. But say "hey we're gonna make your highway transponder work in every state east of the Rockies" and they're all for it.

    I have to wonder if Europe has the same thing going on.

    • Your example of adoption is interesting. I think California has actually influenced other states on efficiency. I wanted to say disproportionately, but perhaps in exact accordance with their economic and political power.

      I don't know the details well enough, but I do know that there is an effective anti-fedaralist force in the US wherever federal funding is concerned, as it comes with rules conditions (rules) attached. I would be interested to what extent this acts as a bias toward cooperation in the case of ez pass, given the interstate system.

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In the EU you have to distinguish between "Directives" and "Regulations".

A "Regulation" becomes "law" in any member state without modification. No member state has to adopt anything. Examples are the GDPR and the new Machine Regulation.

A "Directive" does not become "law" in any member state. A member state has to enact their own national laws to implement the directive until a given date. It does not have to be single law. It could spread many laws. An example is the Machine Directive before it was re-released as Machine Regulation.

More on the different types can be found here from the EU itself: https://commission.europa.eu/law/law-making-process/types-eu...

> It's completely missed that small entrepreneurs may also want to take part

This was traditionally something that the UK was better than the rest of Europe, having carve-outs for small businesses.

The bigger issue in OP's case is they are dependent on de minimis.

The de minimis crackdown [0] and EPR [1] are both being rolled out because Chinese conglomerates like Pinduoduo (Temu) and SHEIN took undue advantage of that while ignoring European regulators on issues such as environmental regulations on packaging [2], dark patterns [2], breaching the Digital Services Act [3], and gacha/addictive engagement mechanisms [4].

All of OP's proposals directly conflict with the goal of de minimis taxation and the EPR.

Seems European HNers are fine with European regulations until it hurts their niche interests or pocketbook.

[0] - https://www.ft.com/content/102e18d7-d06b-4405-a347-97bb3c373...

[1] - https://www.vereev.com/news/europe-faces-trade-conflict-is-e...

[2] - https://www.ft.com/content/ef72f186-2a02-4c51-927d-2c01ddece...

[3] - https://www.reuters.com/sustainability/eu-says-temu-breach-r...

[4] - https://www.reuters.com/sustainability/eu-probes-shein-over-...

  • The issue is that those marketplaces got too mainstream, and the average consumer is too stupid.

    10-15 years ago if you were importing stuff from China you'd know that the trade off for cheaper prices is that you'd lose your consumer laws protection and you'd be on your own. If you wanted those, then you'd go to your local retailer and pay extra.

    • Means nothing though because no European country can produce the goods an impoverished European can afford to pay for the goods so the local store is just the same Chinese goods shipped to that address other than your home address.

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    • And then everyone started doing it, which meant that your local retailer isn't in business anymore (see local high streets in many countries). The choice you had 10-15 years ago doesn't exist anymore because everyone went for the cheaper price, and now the question is where the extra goes that we used to pay to the local retailer.

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    • This got downvoted but is basically correct. We had a great "grey" market, but the tradeoff for that is having to stay small enough to not be visible.

> old ideas just drags it down.

Are these old ideas? The broad regulatory apparatus in the EU appears very modern and intentional.

Ah yes, let’s give the EU and its undemocratic system in which policy formation is heavily filtered through a relatively narrow professional political class, ordinary voters have weak or almost no direct control over major policy choices, dissent encounters administrative/economic punishment, and central institutions possess and use powerful financial means to discipline peripheral governments should have even more centralised power?

And no, just because voting for MEPs is bolted on there as a pressure valve doesn’t suddenly make it all okay when most of the real decisions happen behind closed doors and adherence to the passed laws, no matter how damaging is ensured through financial coercion.

Not a single person voted or agreed to this law, and yet here we are.

  • Yeah, that's always been my concern with the EU (I'm American, for context): the long worrying practice where the legal concept of the EU is assembled by a small group who very much want EU citizens to go back to sleep and only wake up once all the laws and regulation has been created.

    A federation makes sense to me: I live in one. But how the EU has assembled itself in a way that seems to unrepresentative has been worrying to watch over the last couple decades.

  • US House term is 2 years, European Parliament is 5 years. The latter is actually proportional at least but you can see how they’d only feel pressure every so often

  • But it seems relative immune to the current rise of populism.

    Not a bad tradeoff, all included.

  • It seems you have an issue with representative democracy.

    • There is no such a thing as "representative democracy", that’s antinomic bullshit throw at people to lower it down to powerless populace.

      Either citizens have the power, exercise it continuously in practice and are supplied with everything it takes to assume that role properly with all the duties it implies, or there is no democracy beyond empty words.

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> It's completely missed that small entrepreneurs may also want to take part

There's truth to this but it's an overstatement as it stands. For example, GDPR rules are less strict for small companies.

  • Please elaborate on less strict rules for Gdpr? There is Record of Processing Activities exemption for <250, but if you have to comply with Gdpr (and you do), you need essentially same info as Ropa and of course it has to be up to date. How else can you ensure you are in compliance?

Because if the EU tried to force countries into single compliance, there would no end of "EU is trampling national interests" and similar screaming.

It's an unwinnable situation. Again, EU-level politics keep assuming everyone (corporations and states) are adults. Unfortunately, everyone are just a bunch of screaming, scheming petulant children.

  • >Again, EU-level politics keep assuming everyone (corporations and states) are adults. Unfortunately, everyone are just a bunch of screaming, scheming petulant children.

    One in four MEPs are involved in scandals [0] ranging from harassment to organized crime and corruption. The European Parliament also remains a free out-of-jail card through abuse of parliamentary immunity, and they do abuse it [1]. EU politics is a circus.

    0. https://archive.is/neTOG

    1. https://www.politico.eu/article/eu-parliament-accused-overre...

    • MEPs in many countries do not actually have immunity.

      However, the bigger issue is that european parliament is treated in many countries as essentially dumping ground between national elections.

  • > there would no end of "EU is trampling national interests" and similar screaming

    To just call this "screaming" is to completely dismiss a real and huge problem. The EU is the idea that countries should fuse into economic areas, but the countries are also individual still. Of course there's a lot of friction.

    For example, because Greece was in the Euro, they couldn't inflate their currency to compensate for the fact that they gradually outsourced more and more work to Germany, until they had nothing left and hit a financial crisis because their government couldn't borrow more money. That's not mindless screaming.

    • Do you realize that your example actually counters your point? The Greece's example illustrates that a misbehaving minority shouldn't have an outsized influence on the majority, which is a correct thing to aim for, I completely agree with you on that. But the current EU arrangement actually allows minority entities to veto majority's initiatives and improvements, exactly because EU is not fully federated. 1 member country can screech and blackmail 26 other members for any arbitrary reason, and they all must comply with this minority's ultimatum. If EU was a federation, majority would simply outvote any obstructionists.

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    • So you've described Greece as a bunch of scheming petulant children.

      "Our plan to be inaccountable didn't work, so we'll try a different scheme instead".

      And yes, it's a huge problem. That's why I called the situation unwinnable.

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