AEGIS Europe’s Position on the European Commission’s 17 December 2025 CBAM Package

AEGIS Europe’s Position on the European Commission’s 17 December 2025 CBAM Package

AEGIS Europe supports the strengthening of the EU’s Carbon Border Adjustment Mechanism (CBAM) but argues that the Commission’s proposed Temporary Decarbonisation Fund is only a partial solution to the risk of carbon leakage for EU exporters. We call for a long-term, WTO-compatible export mechanism, stronger anti-circumvention rules, and targeted extensions of CBAM to downstream products to preserve the competitiveness of European industry.

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The EU needs action on Trade Defence now

The EU needs action on Trade Defence now

AEGIS Europe warns that European manufacturing is facing growing pressure from unfair trade practices, global overcapacities, and imports that fail to respect EU environmental and social standards. The paper calls for stronger and faster EU trade defence measures, including reinforced anti-circumvention rules, broader investigations across entire value chains, and new tools to address market distortions and industrial overcapacity. It provides recommendations based on changes to the current practice and changes to the law.

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AEGIS Europe endorses Antwerp Declaration Community, calls for more man-power for trade defence, and for emergency industrial measures

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AEGIS Europe endorses Antwerp Declaration Community, calls for more man-power for trade defence, and for emergency industrial measures

Following the European Industry Summit in Antwerp, AEGIS Europe reiterates that Europe’s resilience, security, and prosperity rest on the competitiveness of its industrial base.

In a period marked by geopolitical shocks, structural dependencies, overcapacities and intensifying global competition, Europe cannot safeguard its strategic autonomy without a strong European industry. At the Summit, more than 500 business leaders and representatives of the workforce met with senior European decision-makers, including European Commission President Ursula von der Leyen and several heads of state. As Belgian Prime Minister De Wever warned during the Summit, Europe is “on the brink of an existential crisis”, due to increased energy prices, dumping and regulatory pressure.

Two years after industrial leaders first signed the Antwerp Declaration, the outlook has deteriorated across most indicators, as indicated in a recent Deloitte report. In parallel, the Draghi Observatory report by EPIC indicates that as of January 2026 only 15.1% of the recommendations associated with the Draghi agenda have been fully implemented over the past two years. These findings underline a widening gap between Europe’s industrial ambitions and delivery on the ground, even as the pace of site closures and job losses accelerates in vital sectors. In this context, AEGIS Europe endorses the Antwerp Declaration Community’s call for urgent and bold action by EU leaders meeting in Alden-Biesen.

We urge the adoption of a package of emergency industrial policy measures centered on:

Ensuring fair trade and a level playing field. Trade defence instruments (TDI) must be faster, stronger, and adapted to current market realities. This requires the immediate allocation of additional man-power to DG TRADE to ensure timely and effective use of the existing trade defence instruments action and the modernising the EU’s TDI toolbox. The Foreign Subsidies Regulation (FSR) should be beefed up and used more systematically by DG COMP and DG GROW to tackle distortions on the Single Market.

Introducing European content in public procurement. Public procurement should prioritise products made in Europe in forthcoming initiatives, including the Industry Accelerator Act, to support industrial capacity and jobs across the Union in sectors already facing dependencies and in those at risk due to their strategic importance and evolving market conditions.

This should also apply to the use of public funds more generally. Furthermore, risk assessments should be carried out vis-à-vis foreign high-risk suppliers. These initiatives should improve transparency on the origin of products and rely on sectoral and consistent principles and criteria, ensuring that demand-side measures, funding and procurement rules jointly contribute to strengthening EU-based production.

This is a decisive moment. Europe must move from diagnosis to delivery – restoring industrial competitiveness, safeguarding high-quality jobs, and turning the Clean Industrial Deal into tangible outcomes in 2026. 

AEGIS Europe Feedback on the Revision of the Public Procurement Directives

AEGIS Europe welcomes the opportunity to provide its input to the revision of the Public Procurement Directives.

We are an industry alliance bringing together more than 30 European manufacturing associations representative of the whole value chain, from commodities down to consumer end products.

Public procurement is a strategic tool that can be used to strengthen Europe’s industrial base, competitiveness, and strategic autonomy. Its revision should ensure strong enforcement and alignment with EU industrial, trade, and climate policies to prevent price-driven practices that allow unfairly subsidised or non-market products to undercut European production. If effectively structured, public procurement can incentivise high environmental and social standards and contribute to strategic autonomy.

Below, you may find some of our suggestions, based on our members’ input:

Exception on international rules: Article 20, Directive 2014/25/EU allows the derogation of EU public procurement rules ‘pursuant to international rules’ (e.g. through an international agreement). This has created a route for the undisputable circumvention of EU public procurement rules and unfair competition, especially through China’s Belt and Road Initiative projects in certain Member States (e.g. Hungary). AEGIS Europe calls for the removal of Article 20, which threatens the general interest of European Union. The uniform application of EU procurement rules across all contracting entities will then be ensured, and vital EU public interest objectives such as transparency and non-discrimination will be upheld.

Systematic exclusion of Foreign Bidders in strategic sectors. Clear and more uniform rules for the participation of Foreign Bidders – understood as bidders from countries which are not a party to the WTO Agreement on Government Procurement (GPA) or other trade agreements with the EU, i.e. in line with EU international obligations – must be ensured to provide legal certainty to bidders and contracting entities alike. As the EU has exclusive competence on this matter, we call on the systematic exclusion of these bidders for public procurement procedures related to strategic sectors, especially for State-owned economic operators since they are of direct concern for the security of the Union.

A long-term vision for European content: In the longer term, EU content must become the cornerstone of a credible public procurement policy. Public procurement should aim for a high share of European-based production, with limited exemptions where products are unavailable.

Definition and enforcement of “Made in Europe”. The concept of “Made in Europe” is central to the effectiveness of EU preference in public procurement, yet it currently lacks a clear and robust definition. Experience from trade and climate policies show that origin-based criteria can be easily circumvented if they rely on formalistic or minimal transformation rules. Public procurement should therefore rely on substantive production criteria rather than formal origin labels.

Strategic alignment with the Foreign Subsidies Regulation (FSR): The current Regulation allows a suspicious bidder already targeted by an in-depth investigation of the European Commission that has not yet been completed to bid on – and potentially be awarded – new projects. Given the systemic risks this represents for the procurement market, no such bidder should be allowed to participate in procurement procedures, be it alone or part of a consortium, unless they cooperate and facilitate the completion of an ex officio investigation. Additionally, public procurement should also consider the presence of industrial subsidies and structural overcapacities in the country of origin. In non-market economies, such factors often result in systematically underpriced products that cannot be matched by EU producers operating under normal market conditions.

Very low bids and distortion of competition: Public procurement rules already provide contracting authorities with the possibility to exclude tenders where there is a distortion of competition, including in cases linked to dumping practices (abnormally low tenders). However, this possibility is rarely used in practice, and very low bids are often treated as a purely commercial issue. This approach ignores the reality that many such bids are the result of non market practices, including state subsidies, environmental dumping or structural overcapacities. The provisions on abnormally low tenders should therefore be reinforced, in full alignment with the FSR rules.