I'm sure technically you are right on the written wording of the law, but you can be technically right on many subjects and make the wrong business calls. Avoiding a vanishingly small regulatory risk by making real damage to your company seems like a bad call.

You could totally eliminate the risk of meteorite impact on your business by relocating down a mineshaft...

A 20€ million fine for that would not be proportionate, nor would they have taken into account the relevant factors ("the nature, gravity and duration of the infringement [...] as well as [...] and the level of damage suffered by them").

Edit: typo (proportional->proportionate)