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Verband der Bahnindustrie in Deutschland

VDB

Der Verband der Bahnindustrie in Deutschland (VDB) führt die Hersteller sämtlicher Produkte für den Bahnbetrieb unter seinem Dach zusammen, sowohl Systemhäuser als auch mittelständische Zulieferer.

Lobbying Activity

Response to Foreign Subsidies Review Report

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 medium-sized enterprises and start-ups. The VDB members develop and manufacture components for rail vehicles, infrastructure, maintenance, control and safety technologies as well as communication systems with more than 56,600 employees in Germany alone. The German railway industry generates an average yearly turnover of 14 billion Euros and is an internationally successful export industry. It generates around 35% of its turnover from exports, and just under 40% of orders received in 2024 came from abroad. Open and fair global trade is the basis for our success. However, international competition in the railway market is becoming increasingly uneven: European companies only have access to 59% of the global railway market, down from 62% in 2022. According to the European Railway Industry Association (UNIFE), meaning that the European railway industry is losing EUR 3 billion a year. The European Union as well as its members states must enable fair competition for the railway industry in Europe within the internal market and strategically strengthen its international competitiveness. VDB would like to highlight the importance of the Foreign Subsidies Regulation (FSR) to safeguard EU sovereignty in key sectors such as rail, enhance competitiveness and promote strategic public procurement by addressing unfair competition in public procurement procedures. However, despite a positive first investigation on a rail tender that demonstrated the deterrent effect of the instrument, unfair competitive behavior in the rail supply industry have not changed their focus has just shifted to go unnoticed. Distortive market behavior in the field of public procurement have not fundamentally changed despite the initially deterrent effect of the FSR, due to high notification thresholds and/or insufficient use of ex officio measures against recurrent distortive economic operators. On the contrary, they have learnt from the scope of the instrument and now try to circumvent the rules by focusing on projects below the notification threshold. Therefore, the full effectiveness of the instrument will only be achieved through certain key adjustments. VDB believes that the main and urgent priorities of the review should be to: 1. Address the Regulations loopholes, in particular the fact that economic operators subject to in-depth investigations that remained incomplete due their withdrawal of the bid(s) can continue to be active on the European procurement market, through robust solutions (e.g. ex officio review); 2. Lower the threshold for public procurement notification to 150 million euros in order to cover key rail urban transport and infrastructure projects; 3. Strengthen enforcement towards Contracting Entities (in particular if they fail to comply with their obligations) and Member States; 4. Reduce the administrative burden for all interested parties, notably through notification once per year for public procurement and differentiated treatment of economic operators; 5. Investigate, through ex officio review, how foreign subsidies may create distortions through the opening of factories by State-owned third-country companies in the EU or change of ownership of European companies to the benefit of State-owned third country economic operators. Please refer to the attached position paper from our European umbrella organization UNIFE for a detailed explanation of these recommendations for action. An effective FSR can be a decisive lever for greater reciprocity on the global market, securing Europe as a business location and local jobs, European security and the successful implementation of environmental and social goals through public procurement.
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