How Not to Engage With the Commission

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I’ve got a talk coming up next week on how to engage with the European Commission.
In advance, I’ve jotted down some tried and tested ways about how not to engage with the Commission.
If you have some more, please send them my way.
How Not To Engage With the Commission
  1. Step in late. New initiatives are signposted early on in a new Commission. The later you step on, your chances of influencing the direction of travel or content decrease.
  2. Blackout or hibernate and act surprised when the proposal comes out the door.
  3. Target officials/Commissioners with private investigators to bizarre Twitter campaigns.
  4. Pick a fight in public or in private.
  5. Think that the political fringes will have any influence. I call this the Roger Helmer effect.
  6. Ignore political reality. If 27 Heads of State are acting for the proposal, it is going to happen.
  7. Have a fuzzy to no understanding of how the proposal is adopted.
  8. Don’t know the key officials working on the proposal: The Task Force, Inter-Service Steering Group, Inter-Service Consultation group.
  9. Ignore or don’t know what the Working Methods, Political Guidelines, and Better Regulation Toolbox
  10. Provide little to no evidence during Public Consultations. Instead, you posture.
  11. Communicate in Sanskrit. A lot of people in Brussels write to the Commission, EP and the Member States in language that is charitably hard to understand.
  12. Your expert preparing your evidence is happy to say gravity is fake and says so in your submissions.
  13. Provide no viable public policy solution to the issue at hand.
  14. Forget that their role is to act in the ‘European Interest’. A lot of people forget this.
  15. Channel your inner passive-aggressive self in interactions.
  16. Don’t pick up the phone and speak to the desk officer.
  17. Send long letters from lawyers claiming the Commissioner can’t do what he/she is about to do threatening to sue them if they do, and then not follow through.
  18. Not being trusted. If you are, for whatever reason, not trusted, you’ll have a hard time.
  19. Have no or limited existed good working relationships. Hoping that the cleaner in the Berlaymont
    will get you the in you need is not going to work.
  20. Turn up late knocking on the wrong door. Don’t anticipate what they need to know to change their mind.
  21. Don’t send a pre-read to a meeting a week ahead on a complex issue.
  22. Communicate by telepathy. Don’t speak to the officials and spend endless hours in internal meetings anticipating what is driving them, when a simple phone call will give you the answer.
  23. Don’t look at the issue from their perspective.
  24. You are in the same camp as ‘Gazprom’. Some interests are going to be frowned upon. Your chances of success hover around 0% on a good day.
  25. You are the poster child for a hostile third country.