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Foreign Subsidies Review Report

Competition

This initiative aims to provide transparency to the Commission’s implementation of the 2022 rules on foreign subsidies. The Commission will notably report on: i) the assessment of foreign subsidies distorting the internal market; ii) the application of the balancing test to distortive foreign subsidies; iii) the ex officio review of foreign subsidies; iv) the notification thresholds; and v) more generally the complexity of the rules and the cost to businesses they entail.

Links

Public consultation

ID: 14760

Lobbying Activity

23 responses

American Chamber urges sweeping overhaul of EU foreign subsidies rules

American Chamber of Commerce to the European Union, 18 Nov 2025

The organisation requests narrowing the regulation's scope to focus only on selective subsidies with clear EU connections, significantly raising notification thresholds by at least 50%, and streamlining procedures through annual reporting instead of real-time data collection. They argue the current rules create disproportionate burdens requiring engagement of over 100 division managers per company.
This would reduce their compliance costs and administrative burden from tracking subsidies globally.
The proposal could weaken scrutiny of distortive foreign subsidies affecting EU competition.

EFPIA Urges EU to Slash Foreign Subsidy Reporting Burden

European Federation of Pharmaceutical Industries and Associations, 18 Nov 2025

EFPIA requests higher notification thresholds and specific exemptions for patent-protected medicines and clinical research. They propose a single yearly notification system to simplify repetitive reporting across different transactions.
Reducing this burden would lower compliance costs and protect funding for pharmaceutical innovation.
EU regulators would lose oversight of foreign subsidies that could potentially distort pharmaceutical markets.

SolarPower Europe urges clarity in foreign subsidies rules to avoid deterring clean energy investment

EPIA SolarPower Europe, 18 Nov 2025

The organization calls for clearer criteria defining foreign subsidies, transparent thresholds for low-risk cases, guidance on ex officio investigations, sector-specific balancing test guidance for solar, and simpler public procurement reporting requirements.
This would reduce administrative burden and provide predictability for their members participating in EU tenders and projects.
The current rules risk deterring investment in EU clean energy projects needed to meet 2030 solar deployment targets.

Swedish Business Urges Major Cut to EU Foreign Subsidy Rules

Confederation of Swedish Enterprise, 24 Oct 2025

The organization requests fundamental changes to reduce reporting requirements, including removing mandatory notifications for mergers and procurement, raising turnover thresholds by 20%, and allowing companies to use annual accounts instead of real-time data. They argue the Commission underestimated both affected companies and administrative burden.
This would massively reduce their compliance costs and reporting workload across thousands of transactions.

EDF Calls for Simplified Foreign Subsidies Rules to Reduce Bureaucratic Burden

ELECTRICITE DE FRANCE, 18 Nov 2025

EDF requests raising notification thresholds, particularly for public procurement, and introducing exemptions for EU companies bidding on EU contracts. They propose a safe harbour system for EU public companies and renewable individual exemptions. They want to eliminate negative declarations when no foreign contributions exist.
This would significantly reduce their administrative compliance costs for public procurement procedures.

Oil and Gas Producers Call for Major Overhaul of Foreign Subsidies Rules

International Association of Oil Gas Producers Europe, 18 Nov 2025

The organization requests elimination or major simplification of merger notifications, significantly raised thresholds, and alignment with accounting standards. They argue the current system creates disproportionate burdens and should be replaced with existing FDI screening mechanisms.
This would substantially reduce their compliance costs and administrative burden from multiple overlapping regulatory processes.

Tech Industry Urges EU to Narrow Foreign Subsidies Rules

ITI - The Information Technology Industry Council, 18 Nov 2025

The organization requests exempting non-selective financial contributions from notification requirements, clarifying distortion criteria, and establishing guardrails around presumptions of cross-subsidization. They argue the current rules create excessive compliance burdens and unpredictable procedures at odds with EU competitiveness goals.
This would reduce their compliance costs and administrative burden from unexpectedly high filing volumes.
EU market oversight loses tools to identify subsidies that distort competition and harm European companies.

Hyundai Motor Group urges simpler EU foreign subsidy rules

Hyundai Motor Europe, 18 Nov 2025

The group requests higher notification thresholds and exemptions for routine state support to lower administrative burdens. They also recommend targeted scrutiny of Chinese bidders to protect fair competition from state-backed enterprises.
Revised thresholds would reduce the legal and administrative costs of their international operations.
State-supported Chinese companies would face stricter barriers when competing for European public tenders.

Danish Shipping Urges Lighter Compliance Burden in Foreign Subsidies Rules

Danish Shipping, 18 Nov 2025

The organization requests simplified thresholds, higher de minimis levels, and exemptions for recurring transactions. They emphasize that regulatory frameworks must not unduly burden European companies operating globally, and urge targeted risk-based approaches that distinguish legitimate international support from harmful distortive subsidies.
This would reduce compliance costs for shipping companies with complex global operations.
European competitors in markets where Danish shipping companies receive foreign subsidies.

SEA Europe urges EU to close shipbuilding subsidy loophole

Shipyards' and Maritime Equipment Association of Europe, 28 Aug 2025

SEA Europe demands that the Commission close a legal loophole that leaves shipyards unprotected from foreign subsidies. They argue current rules fail to address direct injury caused by non-EU competitors.
New rules would provide shipyards with a functional legal tool to challenge subsidized foreign competition.
Non-EU shipbuilders would face new penalties for selling vessels at injuriously low prices.

Construction industry seeks tighter controls on foreign infrastructure subsidies

European Construction Industry Federation, 18 Nov 2025

FIEC proposes lowering notification thresholds to better include major infrastructure projects. They also advocate for clearer definitions and simplified procedures via annual declarations.
Tighter scrutiny would help eliminate the severe competitive disadvantage currently facing European contractors.
Large foreign state-owned firms would lose the ability to win contracts with subsidized bids.

CCIA Europe urges Commission to simplify foreign subsidy notification rules

Computer and Communications Industry Association, 18 Nov 2025

CCIA Europe requests narrowing the definition of contributions and raising notification thresholds. They also advocate for simplified procedures for frequent bidders.
This would lower compliance costs and reduce administrative delays for tech firms.
EU oversight would be restricted, potentially overlooking smaller instances of market distortion.

Solar Manufacturers Urge EU to Prioritise Chinese Subsidy Investigations

European Solar Manufacturing Council, 18 Nov 2025

The organization calls for more frequent and rigorous application of the Foreign Subsidies Regulation within the solar value chain. They specifically recommend expanding probes into Chinese manufacturers and using proactive powers to investigate opaque subsidy schemes.
Stronger enforcement would restore fair competition and protect the survival of European manufacturers.
Subsidised Chinese firms face increased scrutiny and potential exclusion from the European market.

AEGIS Europe urges tougher rules on distortive foreign subsidies

AEGIS Europe, 18 Nov 2025

AEGIS Europe recommends lowering tender thresholds and treating strategic sector subsidies as automatically distortive. They suggest giving the Commission power to overrule contract awards when notification rules are bypassed. Finally, the group calls for more investigations into foreign firms buying European companies.
Strengthening these rules would protect European industrial market share from unfairly priced foreign competition.
State-owned foreign bidders would face more frequent probes and disqualification from large European projects.

Syensqo Urges Stricter EU Curbs on Foreign Chemical Subsidies

Syensqo, 18 Nov 2025

Syensqo recommends lowering notification thresholds for acquisitions in strategic sectors like specialty chemicals. They argue the Commission should prioritize long-term market resilience over immediate benefits during investigations. Additionally, the regulator should consider multi-layered subsidies and historical intellectual property theft.
These measures would shield European producers from predatory buyouts and subsidized foreign dumping.
Subsidized foreign competitors, particularly Chinese firms, would face greater scrutiny and potential bans.

GÉANT Association urges clearer guidance on foreign subsidy rules

GÉANT Association, 18 Nov 2025

GÉANT requests the provision of more practical guidance through use case examples. They also suggest sharing experiences between contracting authorities and suppliers to improve efficiency.
Clearer instructions would reduce time-consuming uncertainty and simplify the process for submitting mandatory forms.

Consultation response

European Dredging Association, 18 Nov 2025

EuDA welcomes the adoption of the FSR as a first step in correcting a discrimination stemming from the fact that EU State Aid Regulations only apply to Member States and not to all companies working in the EU: only the European companies have to comply with the State Aid rules and not the non-EU…

Graphite industry urges stricter scrutiny for strategic foreign acquisitions

European Advanced Carbon and Graphite Materials Association, 1 Sept 2025

The association requests mandatory notification for acquisitions in strategic sectors regardless of turnover. They also demand investigations into subsidized materials imported through third-party countries.
Lower thresholds would shield European graphite manufacturers from predatory, state-subsidized foreign takeovers.
State-subsidized foreign firms would find it harder to acquire strategic European assets.

Consultation response

Canada Pension Plan Investment Board, 17 Nov 2025

BCI, CPP Investments, La Caisse, OMERS, OTPP and PSP welcome the opportunity to contribute to the European Commissions review of the Foreign Subsidies Regulation (FSR). We are Canadian pension funds and fund managers with long-standing investment activity in the European Union (EU), with…

Consultation response

Association of in-house competition lawyers, 18 Nov 2025

Please find attached ICLA's input to the consultation. We remain available to discuss any questions you may have.

Consultation response

Korea Business Association Europe, 18 Nov 2025

The Korea Business Association Europe (KBA Europe), representing over 400 Korean companies operating in Europe, together with the Korea International Trade Association (KITA), representing more than 77,000 international manufacturing and trading firms in Korea, appreciates the opportunity to…

Consultation response

Verband der Bahnindustrie in Deutschland, 18 Nov 2025

The German Railway Industry Association (VDB) welcomes the possibility to comment on the review of the Foreign Subsidies Regulation (FSR). VDB unites more than 250 Germany-based companies under its roof, from worldwide leading original equipment manufacturers to highly specialized small and…

Consultation response

, 17 Nov 2025

Europacable, the voice of Europe's leading cable system manufacturers, urges the European Commission to develop a more efficient and effective Foreign Subsidies Regulation (FSR) closing existing enforcement gaps. Doing so will ensure a level playing field for European cable system manufacturers…