96In those circumstances, it must be held that such obstacles to the effective application of the rules of EU law in relation to that procedure and on the binding effect of E 101 certificates cannot reasonably be justified by the principle of legal certainty and must therefore be considered to be contrary to the principle of effectiveness (see, by analogy, judgment of 3 September 2009, Fallimento Olimpiclub, C‑2/08, EU:C:2009:506, paragraph 31).
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