Richard,
given that this Directive was over 5 years in the making, was the subject of numerous reviews, complaints, refinements, etc., etc. I would very carefully consider whether I would embark on that venture. Unless you have discovered a material error that nobody else has found, you better bring lots of patience, full dedication and enough money to sustain you. You will first have to convince the staff of DGIII that you have a cause, good enough, to make them want to open this can of worms once again. They in turn would have to convince their masters that moneys should be set aside to go through a full cycle (5 years?) of deliberations and negotiations with all parties concerned. Obviously, that would have to be a political decision and would require that your change in the eyes of the EC moneybags, is the best way to spend scarce Euros. Perhaps it will be cheaper to live with the Directive as is. Ciao, Vic Boersma