The Brussels-Paris Nexus: Strategic Anticipation, Circular Economy Compliance, and the New Rules of Economic Security

Antoine Quentin: The basic rule of lobbying has always been to deliver the right message to the right decision-maker at the right time. In a single market and an EU economy open to the world, a strategy designed in the vacuum of a single Member State is doomed to fail. Supply chains are interlinked, institutions and decision-makers reflect this reality.

To succeed, organisations need to use the institutional dialogues that take place regularly to convey their messages and prove their added value by bridging the information gap between the local, national, European and even global levels.

For instance, a French organisation that finds that a draft national measure conflicts with EU law should alert the European Commission and other Member States when it is notified under the TRIS procedure, so that they issue comments or a detailed opinion, and ask the Commission to flag the barrier in the European Semester. The Triman sorting logo shows both the value and the limits of this route: the Commission commented on the French draft as early as 2020, then opened infringement proceedings and referred France to the Court of Justice in 2025, while the PPWR will eventually replace national sorting labels with a harmonised EU label.

Conversely, national organisations that want to export a successful national model can turn a national proof of concept into a European case. That was the purpose of the European policy roundtables “Tackling unfair trading practices at EU level” that I organised at Ilec, the French brand manufacturers’ association, between 2021 and 2025. They brought together policy-makers who had too few opportunities to exchange best practices : national enforcement authorities, Members of the European Parliament, national MPs and Commission officials. That lack of dialogue was detrimental to economic operators interested in tackling unfair trading practices across the EU. The adoption of the cross border enforcement regulation in 2025 and the forthcoming review of the Unfair trading practices directive are direct answers to recommendations made by policy makers during these roundtables.

Successful federations build allies in several Member States and back their arguments with data that matter for the Single Market or other relevant EU policy objectives. They engage with the European Institutions via national administrations and parliaments.

For instance, an EU association should take the opportunity of Commissioners’ appearances before national parliaments, so that national MPs relay its messages with local examples relevant to each country, complementing its direct lobbying in Brussels. And at a time when the Commission is actively concluding trade agreements to defend an open economy against rising protectionism, the association could convey its messages through the EU’s trade partners.

This requires monitoring developments at every level and ensuring that decision-makers locally, where factories and suppliers are located, nationally, at EU level and internationally hear a consistent message, illustrated each time with examples relevant to each country, complementing its direct lobbying in Brussels. And at a time when the Commission is actively concluding trade agreements to defend an open economy against rising protectionism, the association could convey its messages through the EU’s trade partners.

Having worked at international, European and national levels for nearly twenty years, I have seen that the gap is often about narrative and timing.

Antoine Quentin: The biggest operational challenge is not the ambition of EU sustainability rules. It is the gap between when obligations are adopted, when they are actually specified, and the contradictions with national laws adopted at the same time, including between health and environmental obligations at national level. This sends contradictory signals to economic operators that slow down investments and create massive waste, when these laws are precisely meant to reduce it. Rigorous enforcement of the primacy of EU law vis-à-vis Member States would therefore be useful to economic operators.

When I was Director of Public Affairs at ANIA, the French food industry federation, I found it very frustrating to spend months negotiating the AGEC law on the circular economy, then, barely eighteen months later, to see the Climate and Resilience law revisit, and in places conflict with, some of the provisions of the AGEC law and of the Single-Use Plastics Directive.

Headline texts such as the Packaging and Packaging Waste Regulation (PPWR), applicable since August 2026, set the direction. The details that drive investment come later and in pieces: delegated and implementing acts, harmonised standards, and national EPR schemes that keep their own logic.

Companies must commit capital to packaging redesign, recycled-content sourcing and reporting systems while the targets are still moving.

A resilient anticipation model therefore tracks the secondary legislation pipeline, not only the main texts. It also brings public affairs, procurement, R&D and finance together in one governance loop.

The firms that cope best treat regulatory intelligence as an input to their business plan, not as a compliance afterthought. They also engage early in technical consultations, where many of the real decisions are made, and engage with national and EU policy-makers to ensure consistency and alert them early to contradictions between the various compulsory requirements.

Antoine Quentin: What sets a proactive campaign apart is that it exists before the text does. Reactive campaigns start when a proposal is published, and by then the problem has already been defined, the impact assessment written and the options narrowed.

Proactive campaigns shape the problem definition itself. They gather evidence early, form coalitions that go beyond the usual sector associations, and line up their asks with the institutional calendar, from the Commission’s work programme to the rotating Council Presidencies.

This matters even more now that EU competition policy is being reframed around scale, resilience and competitiveness. As market boundaries and bargaining power along supply chains are reassessed, the organisations that will be heard are those that bring credible, verifiable data on market realities to the table first. Anticipation is less about predicting the outcome than about being in the room, with the right evidence, when the questions are being framed.

When I was working for AIM, the European Brands Association, I coordinated with a law firm the Brands for Europe coalition, which did precisely that: it ensured that brand manufacturers’ case for selective and exclusive distribution was heard by DG Competition and national competition authorities during its e-commerce sector inquiry (2015–2017). The Commission’s final report recognised that selective distribution can be justified to protect quality and brand image, a position the Court of Justice confirmed in Coty later that year.