Action in preparation
HATVP complaint
Reporting to the High Authority for Transparency in Public Life that Mack One France SAS engages in lobbying activities targeting public officials without being registered in the mandatory lobbyist registry.
What we're reporting
Lobbying conducted in complete opacity, without registration in the mandatory registry.
Failure to register in the lobbyist registry
The company Mack One France SAS (SIREN 893 901 678), a French subsidiary of the Europa-Park group, engages in documented lobbying activities targeting French public officials (sub-prefect, state agents, elected officials of local authorities) in order to influence public decisions related to the Europa Valley project — without being registered in the registry required by law.
Verification
The HATVP registry is publicly searchable online. Searches for "Mack One," "Europa-Park," and "Mack One France" return no results. Screenshots of these searches will be attached to the complaint as supporting evidence.
What to realistically expect
In full transparency: the HATVP is a transparency oversight body, not a court. It can open an investigation, issue a formal warning (potentially made public) and refer the matter to prosecutors. In practice, no criminal conviction has ever been handed down since the rules came into force in 2016 — the HATVP itself has been requesting direct sanctioning powers that it has not yet obtained.
The value of filing a complaint is above all to document the opacity of the lobbying being conducted, to compel Mack One to register and declare its activities, and to make visible an influence campaign that is currently being carried out in secret.
Documented evidence
4 lobbying activities documented by the press and public sources.
Confidential meeting of July 7, 2025
Benfeld (headquarters of the CC canton d'Erstein)
~20 participants: Mack One representatives, sub-prefect Michel Robquin, DREAL agents, DDT, ONF, DGFIP, CEA executives, ADIRA, Grand Est Region, mayor of Diebolsheim. The minutes were marked 'CONFIDENTIAL'.
"Everyone must keep the secret (...) this case must not become an issue for the municipal elections."
Meeting at Mack One headquarters in Plobsheim
1, chemin de l'Amitie, 67115 Plobsheim
Alsatian elected officials were invited to the company's headquarters, where Michael Mack asked them to show 'a clear political will' in favor of the project.
Dedicated lobbyist: Moritz Feninger
The DNA newspaper identifies Moritz Feninger, 'executive director' of Mack One France and former assistant to Roland Mack, as being explicitly in charge of lobbying French elected officials.
"Even before Michael Mack was appointed honorary consul, we were in discussions with the ambassador."
Source: DNA, September 24, 2025
SCoT modification in favor of the project
On May 22, 2025, the CEA voted behind closed doors to modify the SCoT territorial plan to integrate Europa Vallee, despite the study's unfavorable conclusions. The <a href='/en/scoters/' class='text-ried-green hover:underline font-medium'>revised SCoTERS</a> approved in December 2025 ultimately did not include the project — the document even proves it was explicitly rejected (p.559). Frederic Bierry, CEA president, was president of ADIRA (2015-2023) when it led the study.
Source: Rue89 Strasbourg
Who is Mack One France
The French subsidiary of Europa-Park, created to carry the project.
| Company name | Mack One France SAS |
| SIREN | 893 901 678 |
| Registered office | 1, chemin de l'Amitie, 67115 Plobsheim |
| Share capital | EUR 1,000,000 |
| Director | Michael Mack |
| Parent company | Europa-Park GmbH & Co Mack KG (Rust, Germany) |
| Owning family | Mack family (Roland, Michael, Thomas) |
What the law says
Three pieces of legislation establish the obligation to register in the lobbyist registry.
Law of October 11, 2013 — Transparency in Public Life
- Art. 18-2: a lobbyist is any person who communicates with a public official in order to influence a public decision
- Art. 18-3: obligation to register and declare activities
- Art. 18-7: the HATVP can issue a formal warning and make it public
- Art. 18-9: criminal penalties — 1 year imprisonment, EUR 15,000 fine
Sapin II Law (2016)
Strengthened the lobbying transparency framework by broadening declaration obligations and the HATVP's oversight powers.
3DS Law (2022) — Extension to local elected officials
Since July 1, 2022, covered public officials include presidents of local authorities with over 20,000 inhabitants and their chief executives. This directly covers Mack One's interlocutors: the CEA, inter-municipal bodies, the prefecture.
Application to the Mack One case: all documented contacts (sub-prefect, CEA officials, CC president, DREAL agents) are "public officials" within the meaning of the law. The documented activities aim to influence the SCoT territorial plan modification and territorial planning — "public decisions" within the meaning of article 18-2.
Penalties provided by law
| Offence | Penalty (art. 18-9) |
|---|---|
| Failure to register | 1 year + EUR 15,000 |
| Failure to declare activities | 1 year + EUR 15,000 |
| False or incomplete information | 1 year + EUR 15,000 |
Note: these criminal penalties have never been applied since 2016. In practice, the HATVP issues formal warnings (47 in 2024) that can be made public. A reform is underway to grant it direct administrative sanctioning powers.
Precedents
The HATVP does act on undeclared lobbying reports.
GBH (Groupe Bernard Hayot)
February 2025Report by Transparency International. Investigation opened 18 days later. Undeclared lobbying of ministers.
Nestle Waters
2024-2025Failure to declare meetings with the Minister of Industry's office. Late registration in the registry in October 2022.
Deveryware
2021-202315 contacts with members of parliament identified. Formal warning on June 22, 2021. HATVP method validated by the Council of State (October 4, 2023, no. 454659).
Shein / Castaner
May 2025Report by Friends of the Earth for lobbying against the fast-fashion bill. HATVP launched an audit.
Takeaways for the Mack One complaint
- A well-documented complaint triggers a rapid response (18 days for GBH)
- Press articles constitute admissible evidence
- The absence of registry entry is a verifiable and irrefutable fact
- The Council of State validated the HATVP's methodology (Deveryware ruling, Oct. 4, 2023)
HATVP in numbers (2024 activity report)
129 breach notifications in 2024 (vs. 5 in 2023), 47 formal warnings — source: 2024 HATVP activity report
Current status
The complaint file is being assembled. Documented evidence has been gathered; screenshots of the HATVP registry will be taken just before submission.
Next step
Submission of the complaint by registered letter to the HATVP (98-102, rue de Richelieu, 75002 Paris) with a copy sent by email. The complaint will be coordinated with other ongoing actions (CADA freedom of information request) to maximize institutional pressure.
Sources
Legislation
HATVP
Evidence — Press
GBH precedent
Reported entity
Lobbying transparency is a legal obligation
0 registry entries. 4 documented lobbying activities. A complaint in preparation.