OpenLobby.EU
Explore

AEGIS Europe

AEGIS Europe is an alliance of over 25 European associations and companies representing industries including traditional manufacturing, consumer sectors, SMEs and renewable energy, committed to European manufacturing as a driver of innovation, growth and jobs.

Lobbying Activity

AEGIS Europe urges tougher rules on distortive foreign subsidies

18 Nov 2025
Topic — This review evaluates the implementation of regulations governing foreign subsidies distorting the internal market.
Message — 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.123
Why — Strengthening these rules would protect European industrial market share from unfairly priced foreign competition.45
Impact — State-owned foreign bidders would face more frequent probes and disqualification from large European projects.6
Read full response

Meeting with Denis Redonnet (Deputy Director-General Trade) and

9 Oct 2025 · Meeting between AEGIS and DG Trade

Meeting with Denis Redonnet (Deputy Director-General Trade)

9 Oct 2025 · Meeting with AEGIS to discuss their Fourth report on the EU’s Trade defence Instruments and the proposals contained therein.

Meeting with Bart Groothuis (Member of the European Parliament)

8 Oct 2025 · Trade defense instruments

Meeting with Matthias Petschke (Director Taxation and Customs Union) and

1 Oct 2025 · Examination of economic conditions on authorisations for inward processing (IP)

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

18 Sept 2025 · Position of AEGIS on Trade Defense Instruments

AEGIS Europe demands punitive tariffs for all manufacturing sectors

18 Aug 2025
Topic — The EU is consulting on trade measures to address global steel overcapacity.
Message — AEGIS Europe insists that new trade protections must cover all manufacturing industries rather than just the steel sector. They demand a new instrument to impose punitive tariffs on countries that subsidize excessive production.12
Why — Broadened trade protections would protect various European manufacturers from being undercut by cheap foreign goods.34
Impact — State-subsidized foreign producers would face significant financial penalties and restricted access to European markets.5
Read full response

Meeting with Brando Benifei (Member of the European Parliament)

10 Apr 2025 · International Trade committee ongoing work

Response to Foreign Subsidies Guidelines

2 Apr 2025

AEGIS Europe welcomes the opportunity to submit its input to the EC on the upcoming Guidelines requested by Jan. 13 2026 as per Art. 46 of the FSR. First of all, AEGIS Europe would like to reaffirm that the FSR represents an important trade autonomous tool to protect the EU Industrys competitiveness and guarantee a level playing field on the Single Market, be it for public procurement or concentrations. Regarding articles 4 and 5 of the FSR on the identification of subsidies most likely to distort the internal market, AEGIS Europe believes that a number of foreign subsidies should be considered to have a distortive effect on a per se basis, notably all subsidies to beneficiaries active in sectors: - Characterised by structural excess capacity. - Featuring high-tech and/or dual-use products to a significant extent; or, - Designated as strategic by the government providing the subsidies (e.g. in policies such as Made in China 2025). Also to be considered distortive per se should be foreign subsidies to operators which have privileged and/or protected access to a significant non-EU market, especially if the non-EU market is the operators domestic market. The ability of non-EU companies to accept unfavourable or unconventional contract conditions should also be deemed as an indicator of such companies receiving a subsidy. Finally, these indicators should be assessed collectively rather than separately. Regarding the balancing test, we insists that a balancing assessment must start from the presumption that there is a fundamental and strong EU interest in favour of removing the effects of distortive foreign subsidies, especially those endangering sustainable and diversified supply chains and the preservation of a strong industrial base in Europe. In addition, because a balancing assessment must involve an adequately transparent and coherent analysis of both short-term and medium-term impacts of the distortions in question, the Commission should carry out full and timely consultation of relevant EU industries and give meaningful consideration of their input. When considering commitments and redressive measures, we believe that the repayment of the foreign subsidy is normally not to be considered an adequate redressive measure. Furthermore, there should be limits on the commitments that the EC may accept in lieu of redressive measures, especially in cases of less than full cooperation. In particular, the EC should not be allowed to accept commitments in cases of significant or full non-cooperation. In public procurement procedures, it is worth highlighting that: - In recent years, there has been an increasing influx of bidders from economic operators from third countries. If we consider that EU funds (e.g. European Structural and Investment Funds, Connecting Europe Facility) can be involved and de facto awarded to economic operators, distorting competition based on price, this is even more relevant as it can contribute to a decreased competitiveness of EU companies. - This situation can lead to a loss of market share and deindustrialisation of the EU, as well as having negative effects on competition in the Single Market. Coupled with increasing contractual requirements and award criteria focused mostly if not exclusively on price, EU companies could be discouraged to submit bids due to low chances of winning - which would be detrimental to the quality of the solutions supplied to public authorities. - The threshold of EUR 250 m for public procurement is high and fails to capture important projects, e.g. in the construction or rail supply industries. When an economic operator has been targeted by a public procurement investigation and if either the investigation is not terminated or results in determination that the company at stake has received distortive foreign financial contributions, there must be an automatic investigation if this company participates in other tenders above or below the threshold.
Read full response

Meeting with Bart Groothuis (Member of the European Parliament)

13 Mar 2025 · Trade defense instruments

Meeting with Andrea Wechsler (Member of the European Parliament)

13 Mar 2025 · EU Energy and industry policy

Meeting with Svenja Hahn (Member of the European Parliament, Rapporteur for opinion) and American Chamber of Commerce to the European Union and

11 Dec 2024 · Revision of the EUs Foreign Direct Investment Screening mechanism

Meeting with Nina Carberry (Member of the European Parliament)

6 Nov 2024 · CBAM

Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

29 Apr 2024

The EU industrial sectors grouped within AEGIS Europe represent the entire value chain ranging from commodities such as ferro-alloys, non-ferrous metals or ceramics to end products like railway and maritime equipment, ships, bicycles or solar panels. Our members account for an annual turnover of 530 550 billion and 1.65 1.7 million of jobs across the EU. AEGIS Europe takes this opportunity to give input in the context of the revision of the Foreign Direct Investment Screening Regulation which it very much welcomes. The European Union needs to ramp up its existing foreign direct investment screening mechanisms in order to preserve Europes strategic autonomy and ensure a global competitive level playing field. The Proposal put forward by the Commission is a step in the right direction; however, AEGIS Europe considers that it can be improved. AEGIS Europe strongly believes that the Proposal's requirements should take a holistic approach and complement other legal instruments available to the European Union, in order to maintain the Union as a prime destination for foreign investments, while simultaneously ensuring fairness for European economic operators and preventing any potential disadvantage that would create even more strategic economic dependencies. Please see more details in our position paper.
Read full response

Response to Revision of the Union Customs Code

7 Nov 2023

AEGIS Europe appreciates the opportunity to provide comments to the European Commission proposed Regulation establishing the Union Customs Code and the European Union Customs Authority and repealing Regulation (EU) No 952/2013 (hereinafter the Revised UCC Proposal). The EU's customs union is the bedrock of the single market and plays a crucial role in EUs involvement in international trade, thus adopting and implementing appropriate rules is of tantamount importance. Hereinafter you may find the AEGIS Europe observations and suggestions to improve the existing legislative framework. The applicable provisions of the current Union Customs Code provide that IP authorisations shall be granted only where [] the essential interests of Union producers would not be adversely affected by an authorization for a processing procedure (economic conditions). Taking into account the fact that the interests of the Union producers have not been factored in properly in practice when assessing the economic conditions, AEGIS Europe and its members have been advocating for: Increasing procedural transparency for applicants and EU producers. This should notably include a full and easy access to the non-confidential IP requests lodged via the he CSD (Customs Decisions System) Establishing a database where non-confidential information about applications and authorisations are accessible to the public and interested parties and ensuring that EU industries can provide their views in time before any authorizations. Facilitating the EU test also through the involvement of industry associations; Establishing a threshold above which it is considered that any request for inward processing would prima facie fulfil the economic interest test requirements. Article 102 of the Revised UCC Proposal basically copies the existing rules in what concerns inward processing and thus the economic interests of Union producers will continue to be overlooked. AEGIS Europe welcomes the idea of setting up a new EU Customs Data Hub since it facilitates the exchange and combination of information in a single central environment managed by the EU Customs Authority. Inferring from recitals 18 & 22 of the Revised UCC Proposal, it appears that economic operators should have access to the EU Customs Data Hub, but it is not clear. Thus, we consider that in order to ensure a level playing field within the internal market for all economic operators, they should be granted access to the EU Customs Data Hub. The Commission needs to ensure that the imported products placed on the EU market fully comply with all the EU regulations. Currently, the monitoring of products compliance with EU regulations is handled by Member States market surveillance authority and, at the border, by customs under the authority of market surveillance authorities, with some variations amongst the Member States.
Read full response

Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

14 Jul 2023

AEGIS Europe appreciates the opportunity to give input in the context of the revision of the Foreign Direct Investment Screening Regulation. The European Union needs to ramp up its foreign direct investment screening mechanisms in order to preserve Europes strategic autonomy and ensure a global level playing field. Hereinafter you may find the AEGIS Europe observations and suggestions to improve the existing legislative framework. The EU industrial sectors grouped within AEGIS Europe represent the entire value chain ranging from commodities such as ferro-alloys, non-ferrous metals or ceramics to end products like railway equipment, bicycles or solar panels. Our members account for an annual turnover of 530 550 billion and 1.65 1.7 million of jobs across the EU. We believe that the FDI Screening Regulation should be revised bearing in mind todays geopolitical reality and in a context of reducing the EUs dependency vis-à-vis certain countries in industries critical for the functioning of the internal market. AEGIS Europe has always supported openness towards FDI since the EU industry relies on straightforward access to capital in order to innovate and grow. However, there was a lack of transparency as regards inward FDI into EU and the FDI Screening Regulation was adopted to tackle such issues nevertheless there is room for further improvement, and we hope to contribute to it via the suggestions you may find in our paper.
Read full response

AEGIS Europe demands stricter carbon reporting rules

11 Jul 2023
Topic — This consultation covers reporting rules for the EU carbon border adjustment mechanism transitional phase.
Message — AEGIS Europe requests mandatory reporting templates and fewer derogations to ensure data accuracy. They demand immediate penalties for incorrect reporting during the transitional phase.123
Why — This would eliminate competitive advantages for foreign firms using less stringent monitoring rules.4
Impact — Foreign producers and importers would face significantly higher administrative burdens and strict penalty risks.5
Read full response

Response to European Critical Raw Materials Act

27 Jun 2023

This document sets out AEGIS Europes views on the Commissions Proposal on a European Critical Raw Materials Act (CRMA) published on 16 March 2023. The EU will need massive amounts of strategic raw materials in the coming years to meet the requirements of the twin transition while preserving Europes strategic autonomy. The EU industrial sectors grouped within AEGIS Europe represent the entire value chain ranging from commodities such as ferro-alloys, non-ferrous metals or ceramics to end products like railway equipment, bicycles or solar panels. Our members account for an annual turnover of 530 550 billion and 1.65 1.7 million of jobs across the EU. The EU should put forward initiatives that promote European content in products across the value chain. Public procurement should be a role model for the end-consumer and prioritize goods whose components originate in the European Union, especially in case that such products are of strategic importance or destined for essential uses. The Green Deal Industrial Plan must be a comprehensive roadmap that supports and boosts our industries, creating jobs, and generating economic growth, while ensuring a cleaner and greener Europe for generations to come. This historic opportunity must be seized to build a more resilient and sustainable Europe that works for all. Furthermore, the envisaged framework should foster reciprocity in international trade exchanges and provide leverage to push third countries to open their markets in the same manner that the EU has opened its market in order to ensure a level playing field that the global trade system needs.
Read full response

AEGIS Europe urges local content priority in net-zero manufacturing

27 Jun 2023
Topic — A legislative framework to strengthen the European Union's manufacturing of net-zero technology products.
Message — AEGIS Europe advocates for a broader scope including finished products like railway equipment. They recommend mandatory targets for industrial production and prioritizing European-made components. They also seek industry representation in the new oversight body.12
Why — Strengthening European content requirements would protect their members from cheap imports and boost domestic manufacturing.3
Impact — International trading partners would face restricted market access due to new local content and reciprocity requirements.4
Read full response

Meeting with Inma Rodríguez-Piñero (Member of the European Parliament, Rapporteur for opinion) and BUSINESSEUROPE and industriAll European Trade Union

23 May 2023 · Meeting with stakeholders in the framework of the INTA opinion to the Net Zero Industry Act

Meeting with Nicola Beer (Member of the European Parliament, Rapporteur)

17 May 2023 · Critical Raw Materials Act (Meeting held by parliamentary assistant)

Meeting with Tom Vandenkendelaere (Member of the European Parliament) and Umicore and

10 May 2023 · Critical raw materials act

AEGIS Europe Urges EU to Simplify Foreign Subsidy Reporting

6 Mar 2023
Topic — Consultation on detailed procedural rules for investigating distortive foreign subsidies.
Message — AEGIS Europe wants to simplify reporting to avoid processing millions of data items. They propose introducing de minimis thresholds and limiting reports to specific relevant countries. They also seek to protect sensitive business data from being shared with public customers.1234
Why — These changes would significantly reduce administrative burdens and protect sensitive commercial data.5
Impact — The European Commission would receive less data, potentially missing some distortive foreign subsidies.67
Read full response

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

28 Nov 2022 · Carbon border adjustment mechanism, energy crisis

AEGIS Europe urges transparency in EU customs inward processing

19 Sept 2022
Topic — The EU is updating customs rules to address e-commerce and security.
Message — The group proposes a centralized database for interested parties to consult inward processing applications. They also suggest an automatic review mechanism when imports exceed specific sectoral thresholds.12
Why — Enhanced transparency enables local manufacturers to protect their market interests more effectively.3
Impact — Importers could face increased administrative hurdles and a reversed burden of proof.4
Read full response

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Aluminium AISBL and

7 Jul 2022 · Carbon Border Adjustment Mechanism

Meeting with Lucia Bonova (Cabinet of Executive Vice-President Margrethe Vestager)

27 Apr 2022 · Foreign Subsides Regulation

Meeting with Jens Gieseke (Member of the European Parliament) and European Roundtable on Climate Change and Sustainable Transition

6 Apr 2022 · Austausch zur EU-Umweltpolitik

Response to Instrument to deter and counteract coercive actions by third countries

29 Mar 2022

AEGIS Europe is an industry alliance that brings together more than 20 European manufacturing associations committed to manufacturing in the EU on a truly level playing field ensured through rules-based, free and fair international trade. Our members account for more than €500 billion in annual turnover, as well as for millions of jobs across the EU. AEGIS Europe welcomes the anti-coercion instrument as a key tool for the achievement of the EU’s open strategic autonomy. As a signal to international partners that the EU is not willing to accept economic coercion, the tool would, ultimately, help defend an open and multilateral global trade environment.
Read full response

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

18 Mar 2022 · CBAM and WTO

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

3 Feb 2022 · Carbon border adjustment mechanism

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius)

2 Feb 2022 · Meeting with AEGIS Europe to discuss the AEGIS Europe’s position concerning the Commission proposal for the Carbon Border Adjustment Mechanism (CBAM).

Meeting with Marie-Pierre Vedrenne (Member of the European Parliament, Shadow rapporteur) and UNIFE

13 Jan 2022 · Lutte contre les subventions étrangères et instrument anti-coercition

Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

19 Nov 2021

AEGIS Europe welcomes the fact that the proposal of the new EU’s Generalised Scheme of Preferences for the period 2024-2034 includes new provisions linking the tariff preference withdrawal with violations of environmental and good governance international conventions and to extend this negative conditionality also to standard GSP countries. However, AEGIS Europe considers that any revision of the GSP regulation should focus on fair trading practices to ensure consistency with other EU policies aimed at achieving sustainable development through trade. We wish to raise awareness on fact that Article 19(1)(d) - allowing a temporary withdrawal of standards GSP preferences, remains unchanged even though, in practice, there has been no effective use of it since a previous determination by a WTO competent body that there are serious and systematic unfair trading practices which have an adverse effect on the Union industry which renders the instrument unusable. We consider that the requirement for a WTO adjudication is inconsistent with the object of the GSP and with the right of the Union to address serious and systematic unfair trading practices in a timely manner and thus it should be replaced by a Trade Barrier Regulation decision. Furthermore, AEGIS Europe considers that a non-exhaustive list of unfair trading practices should be established in order to pinpoint the values of the European Union and the major concerns of the European industries in relation to unfair trading practices. AEGIS Europe also calls for a periodic report issued by the European Commission that would identify any exceptionally grave violations of the international conventions listed under Annex VI by standard GSP countries. AEGIS Europe considers that a shorter timeline should be envisaged in the withdrawal procedure in order to allow the European Commission to swiftly and effectively adapt the GSP coverage to the countries the most in needs that respect the GSP eligibility criteria. AEGIS Europe welcomes the reduction of the graduation threshold from 57% to 47% (for most sectors) envisaged in the new GSP proposal. However, AEGIS considers that the product graduation mechanism should be revised to reflect significant specialisations of production. This can be done by (a) narrowing down GSP sections and (b) changing the timeline applicable to the graduation mechanism. AEGIS Europe considers that extending from two to three years the period for the submission of the report of the European Commission to the Parliament and to the Council is in the detriment of the overall accountability of the scheme, since it would provide civil society with less opportunities to comment on the findings of such reports and flag issues that do not comply with the GSP provisions.
Read full response

Response to Carbon Border Adjustment Mechanism

17 Nov 2021

AEGIS Europe’s membership is committed to participate in the emissions reduction efforts. However, given that EU’s international trading partners do not have the same level of climate ambition, EU policymakers need to ensure that the EU’s high climate ambition does not result in carbon leakage. AEGIS Europe firmly opposes the automatic phase-out of ETS free allowances and considers these should be maintained in full for as long as necessary (i) to allow sufficient time for the deployment of low carbon technologies and until it is proven beyond any doubt that CBAM is effective and carbon leakage is averted, (ii) as well as to minimise the impact on downstream industries and users. By refusing to address the carbon leakage associated with EU exports in its proposal, the Commission has failed to address a fundamental element that must be part of an overall climate strategy to prevent all forms of carbon leakage. This failure puts at risk the achievement of the EU’s ambitious climate goals. Furthermore, the adoption of “export adjustments” should be an integral part of the EU ETS to ensure consistency with the WTO rules. In order to maximise the effectiveness of its climate policies, the EU must strive to avoid carbon leakage and promote low-carbon production. By becoming a significant exporter of low-carbon products and technologies and replacing high-carbon products in third countries, the EU can contribute to a significant reduction in global emissions. Furthermore, it is essential to strike an optimal balance between the export interests of the EU downstream industry currently managed under the EU’s duty relief schemes and in particular the inward processing relief scheme and the interests of the EU upstream industry manufacturing input materials. AEGIS Europe considers that an EU CBAM must apply to products from all origins. However, countries with equivalent ETS systems - equivalent carbon costs and reduction obligations - should be treated fairly and CBAM exemptions should be considered. “Double carbon costs” or unjustified export adjustments should be avoided when implementing the overall EU ETS mechanism in order to ensure consistency with WTO rules. However, AEGIS Europe observes that rigorous controls should be envisaged to evaluate the equivalence of carbon costs and reduction commitments in third countries. AEGIS Europe considers that the CBAM proposal is complex which could become an instrument prone to gameing, loopholes and circumvention. The definition of circumvention in the current CBAM proposal is narrow and vague since it only covers cases of slight product modification and does not cover, for instance, resource shuffling and cost absorption. AEGIS Europe reiterates that a CBAM will not work for all sectors. For some sectors with very specific value chains, products, and global trade flows, a CBAM will not be an effective tool to address carbon leakage, reduce emissions, and create leverage towards third countries to up their climate ambition. On the contrary, it will lead to further costs for the industry and increase carbon leakage rather than prevent it. AEGIS Europe concludes that achieving decarbonisation and limiting the rise in global temperatures to 1.5° C will require a range of policies in addition to a reformed EU ETS with effective carbon leakage instruments.
Read full response

Meeting with Christophe Hansen (Member of the European Parliament, Rapporteur)

15 Nov 2021 · Instrument on Foreign Subsidies

Response to Addressing distortions caused by foreign subsidies

21 Jul 2021

The Commission's Proposal for a regulation regarding foreign subsidies is promising but requires substantial clarifications and revisions before it can become an effective tool for addressing the foreign subsidies distorting the EU internal market. As a general matter, because effective countermeasures under the WTO Agreement on Subsidies and Countervailing Measures are being blocked by the failure of other countries to meet their WTO transparency obligations, the proposed Regulation needs modification in order not to rule out in advance any action against distorting foreign subsidies, regardless of the sector involved. The scope of subsidies and distortions covered, and of possible redressive measures, needs clarification to ensure comprehensiveness, for example to recognise that foreign subsidies may cause major distortions of the EU market already at the time contracts are entered into, or even earlier. To lessen evidentiary burdens in the face of the failure of other countries either to meet WTO transparency obligations or to provide full cooperation in subsidy proceedings, and/or the fact that they have economies significantly distorted by State intervention, the Proposal should include presumptions, farther-reaching consequences of non-cooperation, and an alternative threshold for an ex officio review which would, for example, be based on the magnitude of the (potential) distortive impact on the EU internal market. The Proposal's provisions regarding interim measures, the balancing assessment, and redressive measures and commitments, need major strengthening in order to be capable of safeguarding a strong and strategic EU industrial base with sustainable and diversified supply chains, able to deliver on the EU’s political priorities. More generally, the Proposal needs to include provisions recognising the fundamental interest of EU industry most affected by the distortions in question to request initiation and to participate meaningfully in proceedings, and to have recourse against Commission decisions. Similarly, there need to be rights of private legal action with a view to allowing EU persons to obtain compensation for damages in relation to injury caused to them by distortive foreign subsidies established by the Commission. Regarding the review of concentrations, the Proposal's procedural rules should be further aligned with the EU Merger Regulation (“EUMR”), by decreasing the notification threshold to EUR 250M (instead of EUR 500M). In parallel to this decrease, and to enhance legal certainty, 1) the Commission's ability to open an ex officio review of a concentration should be clearly limited to strategic M&A's conducted by SOE's (e.g., acquisition of notified bodies); and, 2) the Commission should not be able to request ex ante notification below the fixed threshold. With regard to public procurement, AEGIS Europe supports the compulsory notification mechanism, the threshold of EUR 250M (with a number of pre-conditions) and the proposed Commission’s decision, as well as the obligation to notify for “main subcontractors and main suppliers” where the economic share of their contribution exceeds 30% of the estimated value of the contract. At the same time, a number of provisions need fine-tuning in order to minimise the risk of circumvention, in particular regarding the control of European economic operators by foreign entities or concerning the most economically advantageous tender. Further, in addition to addressing procurement based on a specific individual procurement procedure, ex officio reviews should also examine more generally the behaviour of a given operator in a sector, with a potential remedy being the exclusion from EU procurement for a certain period of time. In this context, it is also important to address private procurement, to the extent there is a risk of circumvention.
Read full response

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

24 Jun 2021 · CBAM

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and The European Steel Association and

7 Jun 2021 · Carbon Border Adjustment Mechanism

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

26 Apr 2021 · Videoconference - Exchange of views on the forthcoming proposal for a Carbon border adjustment mechanism

Response to Addressing distortions caused by foreign subsidies

27 Oct 2020

AEGIS Europe is increasingly concerned by distortions on the EU's internal market created by foreign subsidies. As confirmed in Chapter 3 of the Commission's White Paper on levelling the playing field as regards foreign subsidies, this problem is not adequately addressed by existing EU law. Non-binding guidance alone would not fill this gap and reliance on international rule-making would only delay essential action. As explained in detail in its observations on the White Paper (attached to this submission), AEGIS Europe therefore strongly favours Option 2 of the Inception Impact Assessment (i.e., taking legislative action at EU level). In some cases, especially where quicker action is needed, adapting existing law may be sufficient, e.g., in sector-specific situations, or regarding abnormally low tenders in public procurement or the enforcement of EU trade defence measures. In other areas, new rules will be required, especially to establish a sufficiently broad and effective general scrutiny framework. Thus, although the development of EU guidance and the strengthening of international rules can be a useful complement, Option 2 must be the cornerstone of the EU strategy to address distortions caused by foreign subsidies on the internal market. A level EU playing field in relation to subsidy rules requires above all the unilateral establishment of ambitious and workable legal rules that can then be promoted in the multilateral context. While the focus of new law will be distortions in the Single Market, the source of those distortions is external. This requires a strong common and centralised approach towards both the investigations and the resulting redressive measures. Thus, the legal basis for new measures must be Article 207 TFEU. While there must be a role for the Member States in enforcing the new disciplines, centralised EU-level action under the EU's common commercial policy will be essential. Lastly, any tool to address distortions of the internal market caused by foreign subsidies must apply in principle to all sectors, regardless of whether imports of individual products may or may not be covered by trade defence instruments. The White Paper appeared to exclude from Module 1 foreign subsidies provided for goods imported into the EU on the grounds that they are covered by the EU trade defence instrument (TDI). This is too simplistic and fails to recognise that TDI measures concern only individual products and address only one type of distortion, without addressing for example: i) subsidies that distort markets for services and intellectual property in relation to physical goods; ii) distortions caused by goods not actually imported (e.g., those placed under an inward processing regime or a temporary import regime); iii) distortions on downstream markets due to subsidisation of an imported upstream input (and the upstream EU industry may not be able or willing to bring a TDI complaint against those imports); iv) injury caused without regard to actual imports, e.g. by future sales contracts which occur long before imports actually take place. To the extent there would be a concern of overlapping remedies in a specific case, that can be addressed in the determination of appropriate remedies. By way of conclusion, AEGIS Europe underlines the importance of taking legislative action at EU level, primarily on the basis of the common commercial policy, and in particular ensuring that the legislative actions which are proposed address distortions in all sectors of the EU economy. AEGIS Europe values highly this Commission initiative which has great potential to help the EU achieve a level playing field, especially critical in the present uncertain global context. Action under this initiative would not be protectionist, but a simple recognition that the EU must not naively favour free trade, and that it must systematically fight unfair competition on the single market and worldwide.
Read full response

Response to Carbon Border Adjustment Mechanism

23 Apr 2020

AEGIS Europe is an industry alliance that brings together more than 20 European manufacturing associations representing the whole value chain, committed to Europe manufacturing as the fundamental driver of innovation, growth and jobs in Europe. Our members account for more than €500 billion in annual turnover, as well as for millions of jobs across the EU. The Alliance believes a CBAM must be designed so as to contribute to the objective of decarbonisation in the EU by strengthening and completing existing measures protecting European industries from the risk of “carbon leakage”, or the risk of relocation of manufacturing and investment. Accordingly, free allocations should be maintained as a complement to border measures to avoid all forms of carbon leakage. On the other hand, it must be recognised that for some sectors, CBAs may not be appropriate and complementary measures in addition to free allocations and indirect costs compensation should be considered. Please find attached our full contribution.
Read full response

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

3 Sept 2019 · Trade Defense instruments

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker) and The European Steel Association

23 Jul 2019 · Investment Protection Instrument

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

4 Jul 2019 · WTO reform

Meeting with Jyrki Katainen (Vice-President)

5 Sept 2017 · Meeting with AEGIS on new dumping calculation methodology

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

7 Aug 2017 · Anti-Dumping, state of play

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

31 Mar 2017 · Commission proposal to change anti-dumping methodology for non-market economies

Meeting with Peteris Ustubs (Cabinet of High Representative / Vice-President Federica Mogherini)

21 Sept 2016 · MES China