AEGIS Europe’s Position Paper on the Industrial Accelerator Act

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AEGIS Europe welcomes the European Commission's proposal for an Industrial Accelerator Act (IAA), which seeks to accelerate industrial decarbonisation and strengthen manufacturing capacity in strategic sectors.

In today’s geopolitical and trade environment, EU manufacturing resilience, competitiveness and strategic autonomy are increasingly undermined by persistent global overcapacities, state-induced market distortions and unfair trade practices. These distortions risk displacing European production and weakening the industrial base required for the clean transition.

In this context, industrial decarbonisation cannot be considered in isolation from trade exposure. The Act should ensure that public support, procurement incentives and market opportunities primarily benefit manufacturing activities located in Europe, while preserving the competitiveness of European industry across strategic value chains. Industrial decarbonisation should also be supported by affordable energy prices, secure access to raw materials and a stable and predictable regulatory environment that does not create distortions within the internal market. Without addressing these enabling conditions, decarbonisation efforts risk accelerating carbon leakage, reducing industrial output and weakening Europe's manufacturing base.

AEGIS Europe Policy Recommendations

1. Establish a robust and strategic Union-origin requirement

The definition of “Made in EU” should be designed to strengthen industrial resilience, strategic autonomy and fair competition. A robust Union-origin framework under the IAA is essential to ensure that EU industrial support measures are not undermined by trade distortions and third-country subsidisation practices. Without clear origin criteria, the IAA risks indirectly reinforcing foreign production structures benefiting from non-market conditions.

As a general principle, products, components or content originating from third countries covered by Free Trade Agreements (FTAs), customs union arrangements or the WTO Government Procurement Agreement (GPA) should not automatically qualify as Union-originating for the purposes of the IAA. Furthermore, Union-origin equivalence, as well as access to public procurement schemes and public support mechanisms under the IAA, should not be granted to countries that maintain or contribute to structural overcapacities through state support, market access restrictions, requirements to purchase locally irrespective of reciprocity agreements, export controls or other non-market practices.

To ensure strategic autonomy, the regulatory framework must grant a direct prioritisation to EU-made products. Therefore, AEGIS Europe recommends the introduction of a case-by-case “opt-in” mechanism under which third-country content may be recognised as equivalent to Union-originating only when:

• the third country has public procurement commitments towards the EU that provide reciprocal access to its market;

• the third country has implemented a carbon pricing system equivalent to that of the Union and has a similar climate target ambition as the EU;

• the third country demonstrates compliance with ESG standards, respect for the rule of law, market economy principles, fair competition practices, transparency obligations and the absence of structural overcapacities.

2. Use public procurement as a strategic industrial policy instrument

Public procurement and other forms of public intervention provisions under the IAA should support the competitiveness, resilience and decarbonisation of European industry across all sectors and value chains.

AEGIS Europe recommends that:

• public procurement criteria give clear preference to Union-originating products and technologies;

• a value-chain approach is applied to benefit both upstream and downstream sectors;

• access to EU procurement opportunities is conditioned on reciprocity: third-country companies could benefit from access to EU procurement markets only where European companies enjoy equivalent and effective access to procurement markets in the countries concerned, and where all other ‘opt-in’ criteria for Union origin equivalence are met.

• the exception according to which contracting entities would not apply the obligations in case of ‘disproportionate costs’ or for ‘cost differences exceeding 25%’ needs to be modified. Indeed, in public procurement, undercutting prices has been observed as a common practice of certain third country economic operators – often going beyond the 25% difference. Against this background, the 25% cost difference should be an absolute minimum based on a sound and comparable price matrix, at the level of overall project costs, that integrates the Foreign Subsidies Regulation and CO2 allowances cost. There should also be a reasonable possibility for bidders to challenge the use of exceptions.

• while AEGIS Europe appreciates and supports the ‘light’ self-declaration system – i.e. without third party assessment – which has been proposed to limit the administrative burden of economic operators participating in public procurement procedures, clear and robust enforcement is needed. The absence of clearly defined enforcement provisions in the current text presents several risks, such as circumvention or arbitrary, inconsistent, or disproportionate penalties, thereby increasing the likelihood of legal challenges and administrative disputes. The responsibilities of the different levels (European Commission, Member States, contracting entities) are highly unclear at this stage. There should be sanctions defined and enforced by the European Commission – i.e., with broader implications than just the procurement procedure in question – regarding bidders which would be found to “have constructed” a false declaration; this would strengthen the credibility of the obligations and mitigate the risk of anti-circumvention. Furthermore, bidders in the framework of a specific procedure should be able to alert competent authorities based on initial suspicions of non compliance in order to trigger ex-post controls by the European Commission and/or national authorities, thereby preventing unreliable or inaccurate self-declarations.

  3. Design public support schemes that create lead markets for Made in EU products

  AEGIS Europe calls for public support schemes and incentives to support EU manufacturers and EU consumers. Public incentives constitute a complementary instrument to public expenditure and should therefore be designed in line with the same principles that govern public procurement frameworks.

  AEGIS Europe sees the IAA as an opportunity to define a regulatory framework that could help consumers benefit from incentives when opting for low-carbon or Made in EU products on the market.

  As for public procurement, public incentives should give preference to Union-originating products and technologies, to low-carbon products, and to both upstream and downstream goods. Access to public support scheme opportunities should be conditioned on reciprocity: third-country companies should benefit from access to EU public incentives only where European companies enjoy equivalent and effective access in the countries concerned.

  4. Develop a clear framework for low-carbon products

  The absence of a harmonised definition and methodology on low-carbon products creates uncertainty for industrial operators and investors and risks undermining investment decisions necessary for the clean transition.

  AEGIS Europe recommends therefore that low-carbon requirements under the IAA be based on transparent, science-based and internationally recognised methodologies and rely on comprehensive life-cycle assessment approaches covering the entire environmental footprint of products. Such methodologies should be technologically neutral, proportionate, verifiable and should avoid creating competitive distortions arising from differences in national energy systems. Therefore, the European electricity mix should serve as the benchmark for electricity-related emissions, with this principle set out directly in the IAA to ensure legal certainty and a level playing field across the Union.

  5. Strengthen industrial resilience through strategic foreign direct investment

  Foreign direct investments in strategic sectors should contribute to the Union’s long-term industrial resilience, technological sovereignty and innovation capacity, while demonstrating a genuine and verifiable contribution to the European economy, including technology and know-how transfer, the development of local industrial ecosystems, the creation of high-quality jobs, and progressive integration into Union value chains.

  Clarifications on responsibilities are needed to ensure that a multi-layered approach delivers meaningful results; should the proposed multi-layer system be maintained, procedural uncertainty should be reduced, and clarity and predictability further increased, including by safeguarding investment timelines for non-targeted sectors.

  To ensure that such contributions are effectively delivered, AEGIS Europe recommends that joint ventures benefiting from the IAA include appropriate corporate governance safeguards guaranteeing the effective participation of Union partners in strategic, technological and manufacturing decisions. Formal ownership thresholds alone should not be considered sufficient where governance arrangements limit the effective influence of Union partners.

  For greenfield investments, Union-origin and low-carbon requirements should be implemented through a phased and roadmap-based approach, allowing supply chains to be progressively localised while preserving investment attractiveness and supporting industrial scale-up. Such roadmaps should be subject to approval, monitoring and periodic verification by the competent authority or, where applicable, by the Commission. This approach would support fair competition, balanced industrial development across all Member States, and the resilience of the Union’s industrial base.

  6. Reinforce the framework for industrial manufacturing acceleration areas

  AEGIS Europe supports the proposed framework for Industrial Manufacturing Acceleration Areas. However, it stresses that the initiative should encompass new industrial projects as well as existing strategic industrial installations and production capacities. Fast, predictable, and simplified permitting procedures are essential to safeguard and expand Europe’s upstream industrial base and to reduce strategic dependencies on third countries.

  AEGIS Europe also notes with concern the absence of credible funding instruments, as well as the lack of clear oversight and coordination mechanisms, which risks leading to fragmented implementation across Member States.

  7. Limit the use of delegated acts

  The IAA should provide a clear, stable and predictable regulatory framework directly in the primary legislation.

  While delegated acts are key to guarantee a certain extent of flexibility, AEGIS recommends avoiding their extensive use, which could increase regulatory complexity, reduce legal certainty for investors and industrial operators and create an overly fragmented framework.

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  AEGIS Europe is an industry alliance that brings together more than 30 European manufacturing associations representative of the whole value chain, from commodities down to consumer end products. Our members account for more than €500 billion in annual turnover, as well as for millions of jobs across the EU.

AEGIS Europe Letter to President von der Leyen on Trade Defence

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Dear President von der Leyen,

Dear Executive Vice-Presidents of the Commission

Dear Members of the College of Commissioners,

AEGIS Europe is an industry alliance that represents more than 30 European manufacturing associations and companies across entire industrial value chains, from metals and ceramics to transportation industries. Together, our members account for more than €500 billion in annual turnover and millions of direct and indirect jobs across the European Union. European manufacturing is under extreme pressure from state-controlled and export-driven economies, which subsidise enterprises, resulting in global overcapacities flooding world markets. While striving to maintain a competitive edge, European industries in many sectors can no longer endure unfair trade practices resulting from such overseas overcapacities.

As highlighted in the Draghi Report, Europe urgently needs a stronger industrial and trade strategy capable of preserving a competitive manufacturing base and ensuring a level playing field internationally. AEGIS Europe supports the EU’s existing Trade Defence Instruments, which remain essential but must be strengthened. European industries continue to face investigations that are too slow, measures that are too weak, and instruments that are insufficiently adapted to the scale and speed of distortions that evolve, and strategies to avoid EU measures.

AEGIS Europe calls, therefore, for faster and more effective trade defence procedures, as well as the urgent allocation of additional human resources in the trade defence services of DG Trade in order to enhance the speed, effectiveness, and enforcement capacity of investigations. At the same time, AEGIS Europe calls for the urgent establishment of a new EU instrument specifically designed to address overcapacities and their disruptive consequences for European industries and value chains.

This instrument should:

• be available on demand to any industrial sector affected by loss of market share in the EU and export markets due to overcapacities and other trade distortions;

• give competence to the Commission to act;

• allow for a full value-chain approach, hence addressing the impact of unfair practices throughout industrial ecosystems and in anticipation of circumvention or shifts in production;

• as overcapacities and distortions are not limited to one country alone, the instrument must be available for all countries;

• rely on publicly available information and/or market intelligence analyses provided by the industry to trigger investigations

• require respondent countries to demonstrate the absence of overcapacities.

The European Union cannot remain exposed to unfair competition while other global actors continue to deploy increasingly assertive industrial and trade policies. A stronger, more responsive, and more effective EU trade defence toolbox is essential to safeguarding European industry.

Sincerely, Inès Van Lierde Renaud Batier Co-Chairs AEGIS Europe

The EU needs action on Trade Defence now

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The EU needs action on Trade Defence now

European manufacturing is under extreme pressure from unfairly traded imports: state-controlled and export-driven economies, overcapacities in many sectors and in many countries, as well as imports that disregard EU environmental and social standards, create an uneven playing field, leaving European industries at a disadvantage.

The Draghi Report has highlighted the urgent need for a resilient and competitive European industry that aligns with Europe’s strategic interests1. The Report highlighted the gaps in the EU’s current trade defence mechanisms that need to be addressed. We need flesh on the Draghi bones.

In recent strategy papers, the European Commission seems to have recognised the need for a more effective trade defence toolbox, but it has not backed up these easy statements with effective action. In the meantime, world class, efficient and innovative EU industries are dying. AEGIS Europe has been calling for more action for many years.

In this paper we set out some of the actions needed.

• Changes to current practice

Allocation of additional human resources: There must be the immediate allocation of additional human resources to DG Trade. This will allow for more investigations into unfair practices, more time to understand and address changes in state-run trade strategies, more creative use of current instruments and to make proposals for legislative change.

A value chain approach: Investigations encompassing a whole supply chain: The Commission must initiate one or more simultaneous investigations covering the full value chain to address similar unfair trading practices at all levels of a value chain.

Duties on downstream products incorporating upstream products: Duties on incorporated products: the Commission must impose, as they do in the USA, measures not only on the upstream product itself but also on that part of the downstream product that is made up of the upstream product. This can be done by drafting the NOI sufficiently broadly.

Social and Environmental Costs in dumping calculations: Social and environmental costs are factored, by law, into the injury calculations. To avoid an unfair comparison between the dumping and the injury, they must be factored into the calculation of the dumping margin.

Better SMEs Support: The Commission must establish an office, not only to explain TDI but to actually assist sectors, dominated by Small and Medium Enterprises, in the filing of complaints and in the completion of the injury questionnaire.

Better monitoring of trade patterns: The Commission must improve the trade monitoring system with the obligation to advise industry and build cooperation with industry on ex-officio investigations.

More robust use of circumvention rules to address new forms of circumvention practices: Third-country exporting producers hit by trade defence measures, or the imposition of unilateral tariffs, are becoming more and more skilled and innovative to immediately circumvent the duties in place. Boosted by domestic subsidies, third-country exporting producers subject to duties, are engaging in “duty offshoring” practices, which consist in establishing a production presence, whether partial (through finishing operations) or total (through production) outside their home country (in the EU or outside the EU), in order to bypass a duty (tariff, anti dumping duty).

Duty offshoring practice is a practice for which there is insufficient due cause or economic justification other than the imposition of the duty, and for which there is evidence of dumping and injury and evidence that the remedial effects of the duty are being undermined in terms of the prices and/or quantities.

Third-country exporting producers subject to duties are also circumventing duties by adding an additional processing step to their products initially subject to duties to avoid the measures and export downstream products. This results in displacing the issue of unfair trading practices from Chinese exporters in the value chain, from upstream producers to downstream producers, equally affected by these systemic unfair trading practices.

When there is a change in the pattern of trade which consists in an increase of imports of a product immediately derived from products subject to anti-dumping duties and belonging to the same value chain, the Commission should qualify this practice as a new form of circumvention practices falling under Article 13(1) of the Basic Anti-Dumping Regulation.

More extensive use of particular market situation: Increasingly, an input from one country (often China) is exported at dumped or distorted prices into a second country (often another Asian country), which then exports a finished product to the EU at injurious prices. This is sometimes referred to as “input dumping”. The Commission should be more robust in finding a particular market situation (to adjust the distorted input from the first country) in such scenarios to enable the EU industry to have an effective remedy.

• Changes to the law

Improvement of the safeguard instrument: Reform the voting system in safeguards procedures: the current rule of a qualified majority voting only adds another obstacle to a procedure which already asks the concerned industries to meet very strict conditions. As done for the anti-dumping instrument, the voting rule should change in blocking a proposal from the Commission only if a qualified majority votes against the Commission’s proposal. Allowing the EU industry to file a safeguard complaint would also streamline the procedures – rather than having to provide the data via Member States.

Removal of the Lesser Duty Rule: In cases where the dumping margin is higher than the injury margin, and only in these cases, the simplest and most straightforward solution is to remove the need to make a comparison between the dumping margin and the injury margin. In other words, to remove the lesser duty rule. The lesser duty rule is not required by WTO law. It is a WTO + provision of EU law. There is nothing to prevent the Union from removing this requirement. The removal of the lesser duty rule must become the priority for EU policy makers, therefore, AEGIS Europe supports the reference to this important change in the Steel and Metals Action Plan. The lesser duty rule should be automatically not applied where there is evidence on the file of significant overcapacities in the countries of origin of the dumping.

A new instrument to deal with overcapacities: The Commission is proposing an overcapacities instrument for steel. The EU needs a similar instrument for other sectors: The instrument must allow for the imposition of punitive tariffs, or any equivalent measure, at the border, on goods sourced in third countries which have given support directly or indirectly to the rise of economically irrational overcapacities.

This instrument: i) must be available independent of the Safeguard instrument; ii) must result in measures made effective at the EU border; and iii) must be triggered by the EU industry (and not a Member State) to give the initiative to industry.

AEGIS Europe and Plastics Recyclers Europe call for swift and effective actions to secure the future of EU industry

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Brussels, 29 October 2025. As the European Union faces growing global competition, European producers already face several trade challenges, including high production costs (especially energy), global overcapacities, and aggressive third-country industrial policies.

Market performance indicators reveal a decline in competitiveness in the last ten years. This is evident in reduced production across sectors such as steel, silicon, ferroalloys, aluminium, and paper & board. Additionally, exports have dropped significantly in sectors like finished steel, man made fibres, and paper & board. Increased energy prices also play a role, but the real problem is the dumping of excess capacities on the open EU market and the need for new approaches to deal with industrial subsidies in addressing these overcapacities.

We are losing manufacturing jobs at an alarming rate. In AEGIS Europe sectors alone, approximately 34,000 direct jobs have been lost compared to the pre-COVID period. Considering that each direct job loss triggers 3-4 indirect job losses, this amounts to around 100,000 total jobs lost.

Since the 2008-2009 financial crisis, the situation has worsened, with 2.5 million industrial jobs disappearing and numerous plants across Europe shutting down. A wave of closures has been rolling out across the EU, mainly in the automotive sector and energy-intensive industries, but also in green tech sectors such as batteries. These closures are occurring throughout the EU.

Against this backdrop, and a year after the publication of the Draghi Report, AEGIS Europe, together with Plastics Recyclers Europe, calls on the EU to:

1. Strengthen and expedite the use of Trade Defence Instruments (TDIs) to timely protect EU industry from unfair foreign practices:

• Injury Margin: WTO law does not provide for injury margins; thus, the EU has full discretion in determining the calculation method. The current methodology does not account for the volumes of imports or potential volumes. Therefore, factors such as the actual market share of imports and potential market share (due to overcapacities) can be legally used to increase the injury margin.

• Dumping Margin: The normal value in the country of origin is compared to the export price to the EU, subject to a fair comparison. If the export price to the EU reflects a higher price due to social and environmental costs borne in the EU, an adjustment should be made to increase the margin by subtracting these costs from the export price. Both changes do not require an amendment to the basic Anti-Dumping Regulation.

• Small and medium-sized enterprises (SMEs), often the most harmed by unfair trade, are effectively excluded from investigations due to the heavy data-gathering burden. While DG TRADE has set up an SME Helpdesk, it must be empowered to support enterprises in collecting data and completing injury questionnaires. Legally, injury evaluations for SMEs do not have to follow the same standards as those for large enterprises.

• Address energy subsidies: Energy has a big share in the cost of production of key industries in the Union. While EU industries have been affected by an increase of energy costs, notably due to Russian’s invasion of Ukraine, third countries which have subsidised energy have been able to unfairly take market shares from EU industries. Consideration must be given to taking action, both in the WTO and in domestic Anti-Subsidy actions, to counter these massive subsidies which can be considered Specific in that they apply to fossil fuels only.

2. Upgrade the toolbox of EU industries by optimizing old instruments or designing new ones, such as an overcapacities instrument:

• We call for an instrument that: i) must not be limited to the steel sector; ii) is available independent of the Safeguard instrument. Iii) can be triggered by the EU industry, to avoid political interferences. The instrument must allow the imposition of punitive tariffs, or any equivalent measure, at the border, on goods sourced in third countries which have given support directly or indirectly to the rise of economically irrational overcapacities.

3. The Foreign Subsidies Regulation represents an important trade autonomous tool to protect the European Industry’s competitiveness and ensure a level playing field on the Single Market. In recent years, there has been an increasing influx of subsidised bidders from State-owned economic operators from third countries: this unfair 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. Ahead of the publication of the EC guidelines in 2026, and the deadline for the regulation’s evaluation, we call for key improvements such as:

• Thresholds: The threshold of EUR 250 million for public procurement is high and fails to capture many important projects, for example in the construction or rail supply industries.

• Withdrawing bidders: It should not be permitted, in case of recurrent suspicions of unduly advantageous tenders, that bidders withdrawing from a procedure to avoid redressive measures can again bid in another procedure unless they have proven that they do not benefit from distortive subsidies.

• Nature of bidders: The shareholders’ structure of bidders should be checked and go beyond a mere declaration, in order to avoid participation from State-owned enterprises in bids.

• Reduction of the administrative burden for European companies which are equally concerned by the reporting obligations stemming from the Regulation.

AEGIS Europe urges the Commission to take action on global overcapacities and support the safeguard case on ferroalloys and silicon

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Brussels, 14 October 2025 – AEGIS Europe welcomes the European Commission’s initiative to address the negative trade-related effects of global overcapacity in the steel sector, and warns that the challenge of overcapacities extends far beyond steel. This requires a solution for the steel value chain as well as for other sectors facing similar challenges.

Overcapacities have become a value-chain problem, affecting upstream and downstream industries alike – from raw materials to final goods. China alone can meet Europe’s entire industrial demand several times over in many manufacturing sectors, while other third countries are also expanding production, making overcapacity a truly global phenomenon. This systemic distortion, largely – but not exclusively - driven by state-supported production, is undermining Europe’s drive toward strategic autonomy, deterring investment, and accelerating deindustrialization.

Recent developments in the ferroalloys and silicon sector, in particular, illustrate the scale of the challenge. With existing spare capacity exceeding 21 million tonnes and planned capacity increases of more than 13 million tonnes worldwide, global overcapacity for manganese and silicon-based alloying elements has reached unprecedented levels. These volumes cannot be absorbed by the market, especially amid declining European consumption and shrinking export opportunities as third countries adopt their own trade defence measures.

This crisis has brought Europe’s ferroalloys and silicon industry to the brink of collapse. As noted by Euroalliages – the European federation representing that industry, and active member of AEGIS Europe, the last silicon-metal producer in the EU recently closed. Silicon and ferro-alloys materials are indispensable for the production of steel, aluminium, batteries, and advanced defence applications – from cars and energy storage to drones and strategic infrastructure. Without them, Europe’s industrial resilience and economic security are at risk.

AEGIS Europe therefore expresses its strong support to the imposition of measures in the framework of the safeguard case on manganese and silicon-based alloying elements. The adoption of effective safeguard measures is essential not only to preserve the future of the ferro alloys and silicon industry, but also to prevent further deindustrialization across interconnected value chains.

AEGIS Europe believes this case is an example of the urgent need to adopt a comprehensive approach to overcapacities, extending to all affected sectors. This includes:

• Establishing a regular EU monitoring system of overcapacities risks by country and sector, building on the model of import surveillance;

• Creating an EU instrument to counter overcapacities based on the rationale behind the new steel measures. This instrument should be applicable across all sectors, independent of the safeguard mechanism, and triggered by industry;

• Enabling effective border measures, including punitive tariffs or equivalent actions, against imports originating from countries that directly or indirectly subsidize overcapacity.

As Commission President Ursula von der Leyen stated, “Global overcapacity is damaging our industry. We need to act now.” AEGIS Europe fully supports this call and urges the Commission to translate this recognition into a robust and forward-looking policy response.

DG Trade TDI Report 2024: Progress made, challenges remain

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Brussels, August 2025: AEGIS Europe welcomes the release of the 2024 Report on the Trade Defence Instruments (TDI) by the Commission, which confirms the EU’s continued commitment to tackling unfair trade practices and defending European industry. The report highlights a record 33 new investigations launched in 2024 – the highest number since 2006 – and an increase in the total number of definitive and provisional measures in force, rising from 186 at the end of 2023 to 199 at the end of 2024.

However, AEGIS Europe remains concerned about the Commission’s ability to sustain this level of activity without additional resources in Directorate G of DG TRADE. Already, staffing shortages have contributed to delays in launching new investigations. AEGIS Europe calls for the urgent reinforcement of human resources to ensure timely and effective investigations and enforcement of TDIs.

A significant share of the new cases shows evidence of overcapacities putting unfair pressure on European industries in the EU and in export markets. This phenomenon must serve as a wake-up call: Europe’s manufacturing base is at risk. An EU instrument to address systemic overcapacities across all sectors – not just steel – is urgently needed. This instrument must be independent of the Safeguards instrument. AEGIS Europe welcomes the Commission’s commitment to take social and environmental costs into consideration when assessing injuries sustained by European producers. However, poor social and environmental standards in countries where dumped imports originate also exert significant distorting effects on export prices, which should be further reflected when calculating the dumping margins.

The basic Anti-Dumping Regulation should be amended to remove the Lesser Duty Rule, a WTO+ provision which weakens the deterrent effect of TDI measures by capping duties at the lower of the dumping or injury margins. AEGIS Europe supports its removal and calls for broader use of the Commission’s discretion to apply full dumping duties where warranted.

Finally, we commend the Commission’s constructive dialogue with the European industry, including its recognition of AEGIS Europe’s contribution to the Brussels trade policy debate. Such engagement must now translate into concrete measures that strengthen Europe’s industrial resilience.

AEGIS Europe statement on U.S. reciprocal tariffs

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Brussels, April 7, 2025. The European Union and the United States maintain the most integrated economic partnership in the world. When considering trade in goods, services, and investment, the transatlantic relationship is unmatched in scale and depth, supporting millions of jobs on both sides of the Atlantic.

On February 13, the White House published a statement announcing the introduction of "reciprocal tariffs" targeting several U.S. trade partners, including the EU. This was swiftly followed by the imposition of duties on European steel and aluminium in March, alongside a sweeping 20 percent tariff on all EU imports, and a further 25 percent global tariff on cars, which entered into force between April 2 and 3. The U.S. administration has indicated it will respond with additional retaliatory measures in case of a European counteraction.

AEGIS Europe is deeply concerned by these developments. We strongly support free and rules-based trade conducted on fair terms. A spiral of retaliatory measures risks triggering a trade war that would have severe consequences for the global economy. Furthermore, U.S. tariffs on a wide range of partners—including China, Canada, Mexico, Japan, and Korea—risk generating trade diversion towards the EU. This is particularly concerning for export-oriented sectors like pulp and paper or ceramics, as well as for industries already facing global overcapacities, such as steel and aluminium, where redirected exports could lead to a surge in imports and drive prices down.

Ultimately, a self destructive trade dispute between the EU and the U.S. would primarily benefit illegally dumped imports and state-subsidized companies from China and other countries contributing to non market overcapacities, when both sides should instead cooperate to rebalance the global market and tackle the root causes of distortions. An escalating trade war between the EU and the U.S. could also affect other sectors like fertilizers and crops, which have already been severely disrupted—first by the pandemic, then by Russia’s war on Ukraine. These two major crises have revealed the vulnerability of the global food system, which cannot sustain higher global food prices. It is therefore essential to avoid placing this system under additional strain through new trade barriers.

In light of these risks, AEGIS Europe encourages the European Commission to act cautiously, maintaining close dialogue with the business community to safeguard European competitiveness and minimize harm to the EU industrial value chains. At the same time, we urge continued engagement in negotiations with the U.S. to de-escalate tensions and maintain the stability of transatlantic supply chains.

However, should negotiations fail and escalation further develop, AEGIS Europe calls on the EU to:

• Respond swiftly, firmly, and proportionately with targeted restrictions on U.S. imports: the aim should be to preserve leverage, deter further escalation, and keep pathways to a negotiated solution open.

• Conduct sector-specific vulnerability assessments: exclude from retaliation lists those products that are essential to EU industries and at risk of supply shortages. The 2018 retaliation list should be reviewed following broad consultations with industry sector representatives, as sectoral trade dynamics have evolved.

• Distribute the burden of retaliatory measures: not only goods but also services—given the substantial U.S. surplus in this area—should be included in the scope of European countermeasures.

• Proactively deploy Trade Defense Instruments (TDIs): monitor trade flows from third countries and be ready to expeditiously activate TDIs to prevent market disruption and protect the EU’s industrial base.

Tariffs would raise costs in the United States and distort trade flows globally. At a time when economic stability is most needed, such measures risk undermining the efficiency and integration of global markets. Maintaining open strategic autonomy as a key objective, while upholding WTO principles, is essential for the European Union to ensure economic resilience and avoid excessive dependence on external actors. A coordinated, measured, and forward-looking response is therefore required to safeguard Europe’s economic interests and support a stable and predictable international trading system.

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AEGIS Europe is an industry alliance that brings together more than 25 European manufacturing associations representative of the whole value chain, from commodities down to consumer end products. Our Members account for more than €500 billion in annual turnover, as well as for millions of jobs across the EU.