That's not true - at least for Germany. Here a repeated action to earn a profit is considered commercial activity.
I'm not sure what a court would think about 10€/m, but I guess 100€/m would be considered commercial.
EDIT: the common description of being commercial in Germany is: a planned, longer term acting to make money - it's not even necessary to make a profit. Source (in German): http://www.it-recht-kanzlei.de/verbraucher-unternehmer.html