The European Union and its member states are members of the World Trade Organization (WTO). Under the Treaty on the Functioning of the European Union (TFEU), the EU has exclusive competence over the common commercial policy. As a result, the European Commission represents the EU in WTO negotiations and dispute settlement proceedings, while member states participate in decision-making through the European Council ("the Council").

In addition to the multilateral WTO agreements, the EU participates in a number of plurilateral agreements concluded within the WTO framework. These include the Government Procurement Agreement, the Trade Facilitation Agreement, the Civil Aircraft Agreement and the Information Technology Agreement. Participation in these agreements commits the EU to enhanced obligations relating to tariff elimination, regulatory transparency and procurement market access. 

Although WTO law does not have direct effect in EU law in most circumstances, WTO commitments influence legislative design and may inform judicial interpretation before the Court of Justice of the European Union (CJEU).

The EU maintains one of the most extensive networks of free trade agreements (FTAs) globally. These agreements are negotiated by the European Commission on behalf of the EU and require approval by the Council and consent of the European Parliament. For an overview of existing FTAs, please see the European Commission website. 

Among the EU’s major trade agreements currently in force or moving into provisional application are those concluded with Canada, Japan, South Korea, Singapore, New Zealand and Mercosur. The EU also maintains partnership and association agreements with neighbouring countries such as Ukraine, Georgia and Moldova, as well as economic partnership agreements with several African, Caribbean and Pacific countries.

In addition to reciprocal trade agreements, the EU operates several autonomous trade preference regimes. The most significant of these is the Generalised Scheme of Preferences (GSP), under which developing countries benefit from unilateral tariff reductions when exporting goods to the EU.

The GSP framework includes a special incentive arrangement known as GSP+, which provides additional tariff preferences to countries that commit to implementing a series of international conventions relating to human rights, labour standards, environmental protection and good governance.

The EU also maintains preferential arrangements with overseas countries and territories associated with member states. These arrangements are designed to support economic development and integration with the EU internal market.

Although these schemes are not reciprocal trade agreements, they create binding obligations relating to tariff treatment, rules of origin and compliance requirements for importers operating in the EU market.

Ongoing negotiations include discussions with countries such as Indonesia, Thailand and the Philippines. The EU is also updating and modernising several existing agreements in order to incorporate provisions addressing digital trade, sustainability commitments and regulatory cooperation.

A significant development occurred in February 2026 when the EU and India concluded negotiations for a comprehensive free trade agreement. The agreement is expected to eliminate tariffs on the vast majority of EU exports to India and improve market access in areas such as financial services, intellectual property protection and government procurement. The agreement is currently undergoing legal review and ratification procedures before entry into force.

The EU also continues to negotiate complementary agreements in areas such as investment protection and geographical indications with certain trading partners.

A notable development was the signing of the EU–Mercosur free trade and partnership agreement after more than two decades of negotiations. The agreement aims to remove most tariffs on bilateral trade and create one of the largest free trade areas globally. However, the agreement remains politically sensitive within the EU, particularly with regard to environmental protection and agricultural market access. In January 2026, the European Parliament requested an opinion from the Court of Justice of the European Union on the agreement’s compatibility with EU law, while the European Commission subsequently announced that the agreement would move towards provisional application.

More broadly, the EU has increasingly integrated sustainability, supply-chain resilience and economic security considerations into its trade agreements. This trend reflects a shift from traditional tariff-focused trade policy toward a broader regulatory framework addressing environmental protection, labour standards and strategic dependencies.

Over the next 12 months, several developments are expected in the EU’s trade policy framework.

The ratification and implementation of recently negotiated agreements, including the EU–India agreement, EU-Australia agreement and the EU–Mercosur agreement, will remain key priorities.

The EU is also reviewing its GSP. Proposed reforms aim to strengthen environmental and human rights conditionality and improve monitoring of beneficiary countries. Concerning Mercosur, on 27 February 2026, the President of the European Commission announced the provisional application of the EU–Mercosur Agreement following ratification by Uruguay and Argentina. Brazil also followed these countries in the ratification of this trade deal. This happened after the European Parliament accepted a request for judicial review by the ECJ of the EU-Mercosur agreement, which has delayed proper EU ratification.

In addition, EU trade agreements are increasingly expected to incorporate provisions addressing economic security, supply chain diversification and strategic autonomy. Future agreements may therefore include stronger enforcement mechanisms relating to sustainability commitments and supply-chain transparency.

Customs matters within the EU are governed at the supranational level under the EU customs union. The legal framework is primarily set out in the Union Customs Code and related implementing and delegated regulations.

The European Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD) is responsible for developing customs legislation and coordinating customs policy across the EU. However, operational customs enforcement remains the responsibility of national customs authorities in each member state.

Customs legislation is enforced by national customs administrations within the member states. These authorities are responsible for implementing EU customs rules, collecting customs duties and ensuring compliance with import and export regulations.

National authorities also supervise goods placed under special customs procedures such as transit, warehousing or inward processing. In addition, they may conduct investigations into customs fraud, misclassification and undervaluation.

At the EU level, the European Commission monitors the application of customs legislation and facilitates cooperation between member states.

The EU Trade Barriers Regulation provides a mechanism through which the EU addresses trade practices in third countries that negatively affect EU businesses. Under this regulation, EU companies, industry associations or member states may file complaints requesting the European Commission to investigate market access barriers or violations of international trade rules. The Commission may also initiate investigations on its own initiative.

Investigations are conducted on an ad hoc basis following a complaint or Commission initiative. During the investigation process, interested parties – including foreign companies and third-country governments – may submit information and participate in consultations.

The Commission publishes the initiation and conclusions of investigations, typically through notices or reports made publicly available, including in the Official Journal of the European Union.

In addition, the EU has adopted the Anti-Coercion Instrument (Regulation (EU) 2023/2675), which enables the EU to respond to economic pressure exerted by third countries through trade or investment restrictions. Potential countermeasures may include tariffs, restrictions on services or investment measures. 

Recent developments in EU customs policy have focused on strengthening enforcement and modernising customs procedures. In November 2025, the European Commission confirmed that the long-standing EUR150 exemption from customs duties for low-value imports will be abolished and a EUR3 levy per parcel will be charged starting 1 July 2026.

The change is intended to address concerns that the exemption has been widely used in e-commerce shipments to avoid customs duties and distort competition with EU-based retailers. Under the new framework, low-value parcels will instead be subject to simplified duties.

At the enforcement level, customs fraud and evasion remain a significant focus for both OLAF and, where the EU’s financial interests are affected, the European Public Prosecutor’s Office. Their investigations increasingly concern undervaluation, misclassification, origin fraud and organised abuse of import procedures, particularly in high-volume trade flows and e-commerce.

Additionally, concerning the USA-EU transatlantic tariff tensions, the EU extended until 6 August 2026 the suspension of its commercial rebalancing measures against the United States, following earlier EU and US understandings reached in 2025. The underlying dispute remains relevant because the EU countermeasures have not been withdrawn and may be reactivated if negotiations deteriorate.

The EU is currently undertaking a comprehensive reform of its customs framework, the Union Customs Code. The reform aims to simplify customs procedures, strengthen enforcement and improve data exchange across member states.

A central element is the creation of an EU customs data hub and a more integrated risk-management framework, with the first operational phase currently expected in 2028. 

The EU–US tariff dispute also remains a live issue. Although EU countermeasures are currently suspended, that suspension only runs until 6 August 2026, so further negotiations or renewed retaliatory measures remain possible. As a result, transatlantic tariff tensions continue to affect the outlook for EU import measures and customs policy.

The EU maintains a comprehensive sanctions regime adopted under the Common Foreign and Security Policy. Sanctions may be imposed to promote international peace and security, prevent human rights violations or respond to geopolitical developments.

EU sanctions may target specific individuals or entities or restrict selected sectors or entire economies. Measures commonly include asset freezes and travel bans as well as trade restrictions and financial prohibitions.

Sanctions may implement United Nations Security Council measures or may be adopted autonomously by the EU.

Sanctions are adopted in a two-step process by the Council of the European Union. Acting unanimously under the Common Foreign and Security Policy, the Council first adopts a Council Decision, which is then implemented through a Council Regulation. In practice, the two legal acts are adopted at the same time. The European Commission as well as the High Representative of the Union for Foreign Affairs and Security Policy are involved in the drafting process of these legal acts.

The Council Decision establishes the political framework for the sanctions regime, while the Regulation gives the measures direct legal effect within the EU.

Sanctions enforcement is primarily the responsibility of member state authorities. These may include national financial regulators, export control and sanctions authorities as well as customs administrations.

The European Commission plays a coordinating role and monitors the consistent application of sanctions across member states.

EU sanctions apply within the territory of the member states and to a broad range of actors. These include EU nationals and companies incorporated in member states, regardless of where they are located, as well as any legal person conducting business within the EU.

Sanctions may therefore apply to activities taking place outside the EU where they involve EU persons or entities.

The EU maintains consolidated lists of sanctioned persons and entities. These lists are adopted through Council Regulations (or Council Implementing Regulations) and are regularly updated.

Individuals and entities may be listed, for example, where they are considered responsible for actions threatening international peace, violating human rights or undermining democratic institutions.

The EU is currently not imposing full embargoes. However, it maintains sectoral sanctions regimes against several countries and regions. These regimes typically focus on strategic sectors such as defence, finance and energy.

Examples for more comprehensive sanctions programmes include sanctions targeting Iran, Russia, and North Korea.

In addition to country-specific embargoes and asset-freeze listings, the EU maintains a range of other restrictive measures. These include thematic sanctions regimes, such as measures targeting terrorism, cyber-attacks, chemical weapons proliferation and serious human rights violations.

The EU also uses sectoral sanctions that do not depend on the listing of individual persons. These may restrict trade in specified goods, the provision of certain services, access to capital markets, investment, transport or financial transactions. In practice, the EU frequently combines listed-party restrictions with broader sectoral measures aimed at particular industries or activities.

The EU generally avoids adopting sanctions with extraterritorial application comparable to the secondary sanctions used by some jurisdictions. EU sanctions normally apply only where there is a jurisdictional connection to the EU. Nonetheless, it is conceivable that certain measures could have indirect or secondary effects on recipients in third countries. This is especially the case under the framework of the EU’s sanctions against Russia, where the EU has imposed restrictions vis-à-vis economic operators from non-EU countries other than Russia for being allegedly involved in EU sanctions circumvention. Also, both the Belarus and Russia sanctions regimes require EU companies to use their best efforts to ensure that their subsidiaries outside of the EU comply with these restrictions.

Penalties for sanctions violations are primarily determined by member states and may include administrative fines, criminal penalties, or both for natural persons as well as supervisors and the company concerned. Depending on the applicable national regime and the seriousness of the breach, consequences may also include confiscation of assets, increased scrutiny in audits, loss of customs privileges such as Authorised Economic Operator status, loss of export licences or other authorisations, and exclusion from public tenders.

At EU level, enforcement is also being partly harmonised through Directive (EU) 2024/1226 on criminal offences and penalties for the violation of Union restrictive measures. The Directive requires member states to introduce minimum rules for serious infringements, including circumvention, and to provide for effective, proportionate and dissuasive penalties. For legal persons, this includes maximum fines of at least 5% of total worldwide turnover or EUR40 million, depending on the offence.

Member state authorities may grant licences allowing certain activities that would otherwise be prohibited under sanctions regulations, but only where the relevant sanctions regime expressly provides for a derogation or exemption. In practice, these are usually individual licences granted by the competent national authority rather than general licences.

The availability and scope of such licences depend on the wording of the relevant EU regulations. Sanctions restrictions are also often accompanied by express exemptions that place certain activities outside the prohibition altogether, such as transactions for humanitarian or medical purposes, or transactions necessary for the execution of contracts concluded before the entry into force of the relevant sanctions.

Companies operating in the EU are expected to maintain effective sanctions compliance systems. This includes screening counterparties and monitoring transactions. There is no one-size-fits-all compliance standard, however, and the expected level of controls depends on the size, activities and risk profile of the business.

In practice, companies are expected to take a risk-based approach, carry out appropriate due diligence and respond to red flags indicating possible sanctions exposure or circumvention.

Certain sanctions regimes impose reporting obligations, requiring financial institutions and companies to disclose information relating to frozen assets or accounts held for sanctioned persons. In some cases, the obligation is broader and requires entities to provide information that would facilitate the implementation or enforcement of the sanctions regime.

In practice, these requirements are particularly relevant for banks and other financial institutions, which may be required to identify and freeze funds or economic resources held by designated entities. Depending on the regime, exporters or other operators may also be subject to notification requirements when relying on specific exemptions or derogations.

The EU maintains a Blocking Statute (Council Regulation (EC) No 2271/96) designed to counter the extraterritorial application of certain foreign sanctions regimes, namely the extraterritorial sanctions imposed by the United States against Cuba and Iran. EU operators are barred from complying with those legal acts, unless the European Commission grants an authorisation under certain specific conditions.

In addition, certain member states – for instance, Germany – may have national anti-boycott laws.

On 29 September 2025, the Council reimposed a broad range of restrictive measures against Iran following the reintroduction of United Nations sanctions under the Joint Comprehensive Plan of Action snap-back mechanism. The measures include asset freezes, travel bans and extensive restrictions across sectors including energy, finance, trade and transport.

In addition, in October 2025, the EU adopted its 19th sanctions package against Russia and Belarus. The package expanded vessel blacklisting targeting Russia’s so-called shadow fleet, added further financial institutions and trading entities – including entities located in third countries – and broadened export restrictions on dual-use and advanced technology goods. The measures also removed previous exemptions benefiting certain Russian energy companies and introduced a phased prohibition on imports of Russian liquefied natural gas, effective from 25 April 2026, with long-term contracts covered from 1 January 2027. The broader enforcement focus continues to lie on anti-circumvention, which has been progressively strengthened since February 2022.

Another important development has been the increasing attention given to the use of proceeds generated by immobilised Russian central bank assets. While the assets themselves remain frozen, the debate over the use of extraordinary revenues and windfall profits to support Ukraine has become a significant feature of the wider sanctions discussion.

At the same time, the EU also adjusted other sanctions regimes. In February 2025, the Council suspended certain restrictive measures on key economic sectors in Syria, and in May 2025 it formally lifted all economic sanctions on Syria except those based on security grounds.

In parallel, several member states, including Germany, Italy and France, have started implementing Directive (EU) 2024/1226, leading to higher penalties and broader criminalisation of sanctions violations and circumvention. 

Over the next 12 months, a key issue will be whether the EU revives its long-discussed reform of the Blocking Statute. Since 2021, the Commission has considered amendments intended to strengthen protection for EU operators against the extraterritorial application of third-country sanctions, streamline the current regime and reduce compliance burdens. Although the review remains formally announced, it does not appear as a headline initiative in the Commission’s 2024–2029 political guidelines, so the timing and scope of any legislative proposal remains uncertain. 

Another important issue on the horizon is the possible adoption of a further Russia package, potentially a 20th package, as the EU continues to tighten restrictions, close loopholes and expand anti-circumvention measures. In that context, further measures targeting trade flows, financial services, energy-related transactions and third-country facilitators remain possible.

EU export controls are governed primarily by Regulation (EU) 2021/821 on dual-use items, together with member state rules on military items and other controlled goods. The regime applies to the export of controlled goods, software and technology and, in certain cases, also to brokering, technical assistance, transit and transfers, including intra-EU transfers of particularly sensitive dual-use items and transfers of military goods under national rules. In addition to listed items, controls may also apply based on end use, end user or destination.

The legal framework for export controls is set at EU level, principally through the Dual-Use Regulation. The European Commission co-ordinates the system and updates the control list, while member states remain responsible for national licensing and enforcement. Military export controls remain largely governed by national law.

Export controls are administered and enforced mainly by national export control authorities and customs authorities in the member states. Customs authorities supervise exports at the border, while licensing authorities assess applications and compliance. The Commission supports co-ordination and information exchange between member states.

EU export controls apply to exporters established in the EU and, depending on the measure, to brokers, providers of technical assistance and persons involved in transit or transfer operations. The regime covers dual-use items, military goods under national rules, and certain non-listed items where a catch-all control applies because of military, weapons-related or sanctions-related end uses. 

The EU does not maintain a single export-control-specific list of restricted persons separate from its sanctions framework. In practice, export restrictions linked to persons or entities usually arise under EU sanctions regulations, which may prohibit exports to listed persons, entities or sectors. Persons are added to those lists by Council Decisions and Regulations, typically on foreign policy or security grounds. 

The principal list of sensitive exports is Annex I to the Dual-Use Regulation (Regulation (EU) 2021/821), which identifies controlled dual-use items. Annex IV contains a narrower category of especially sensitive dual-use items subject to stricter controls, including for intra-EU transfers. The lists are updated by the Commission to reflect changes agreed in multilateral export control regimes. In September 2025, Annex I was amended to cover additional technologies, including items relevant to quantum computing, semiconductors, additive manufacturing and advanced materials.

In addition to list-based controls, the EU applies catch-all controls to certain non-listed items. Under Article 4 of Regulation (EU) 2021/821, authorisation may be required where the exporter has been informed, or is aware, that non-listed items are or may be intended for use in connection with weapons of mass destruction, military end use in a destination subject to an arms embargo, or as parts or components of military items exported in breach of an arms embargo.

Article 5 of the Regulation also introduces controls on certain non-listed cyber-surveillance items where there is a risk that they may be used for internal repression or in connection with serious violations of human rights or international humanitarian law. In addition, member states may adopt national controls for public security or human rights reasons.

Penalties are set by member states and may be administrative, criminal or both. Depending on the jurisdiction and the seriousness of the breach, consequences may include fines, seizure of goods, loss of export privileges and, in serious cases, imprisonment.       

The EU system provides for individual licences, global licences and Union general export authorisations. Member states may also issue national general export authorisations. The availability and conditions of these licences depend on the item, destination, end user and risk profile.

The EU expects exporters to identify whether their goods, software or technology are controlled and to assess destination, end use and end user risks. Internal compliance programmes are not universally mandatory, but they are increasingly expected in practice and are often relevant when applying for broader license types. Liability standards depend on national law, but exporters are generally expected to exercise adequate due diligence.

Reporting requirements arise mainly in connection with licensing. Exporters must apply for licences where required and, in some cases, report the use of general authorisations to national authorities. Member states may also require record keeping and post-export reporting. 

Recent developments have focused on economic security and tighter control of advanced technologies. In December 2025, the Commission’s Economic Security Communication announced measures aimed at harmonising export control procedures across member states and assessing whether additional controls, including possible outbound investment screening, are needed in strategically sensitive sectors. In September 2025, the Commission also amended Annex I to the Dual-Use Regulation, expanding controls over a number of advanced technologies (see 4.6 Sensitive Exports in fine).

Over the next 12 months, the main issue will be whether the EU moves towards greater harmonisation of licensing practice and a broader economic security framework. Current policy discussions also concern emerging technologies, outbound investment risks and resilience in sectors such as semiconductors, clean tech and critical raw materials. These debates are likely to shape both future export control reforms and national enforcement priorities.

EU anti-dumping, anti-subsidy and safeguard measures are governed by EU legislation and administered by the European Commission, principally through the Directorate-General for Trade and Economic Security ("DG Trade"). Definitive measures are imposed by Commission regulation following the applicable procedure under the basic anti-dumping, anti-subsidy and safeguard regulations, in accordance with the comitology procedure where member states exercise oversight over the Commission’s adoption of implementing acts through the examination procedure and voting by qualified majority.

The European Commission investigates, imposes and monitors trade defence measures. Enforcement of duties is carried out by member state customs services at the border, which impose duties upon importation and ensure their collection in accordance with the Union Customs Code. National customs authorities of EU member states may also investigate evasion or non-payment. The European Anti-Fraud Office (OLAF), and in some cases the European Public Prosecutor’s Office (EPPO) assist enforcement by investigating fraud, evasion, and circumvention of trade defence measures.

EU producers and/or industry associations may petition the Commission to initiate the review of anti-dumping or anti-subsidy measures, provided the applicable standing requirements are met. The Commission may also initiate  certain review proceedings of anti-dumping and anti-subsidy measures (ie, interim reviews) ex officio.

Safeguard reviews, on the other hand, are initiated ex officio by the Commission. Unlike anti-dumping or anti-subsidy measures, there is no formal mechanism for EU producers or industry associations to petition for the initiation of a safeguard review.

AD and CVD reviews are generally initiated on an ad hoc basis following a request by interested parties or, in some cases, by the Commission itself. However, there are important nuances and statutory time periods for certain types of review. Most notably, expiry reviews can be requested by domestic producers no later than three months before the lapse of measures. Moreover, interim reviews can be requested by interested parties only after at least one year has elapsed since the imposition of definitive measures. Within the first year, only the Commission or a member state may initiate an interim review on their own initiative.

Exporting producers, importers, users, foreign governments and other interested parties may participate in both AD and CVD and safeguard reviews if they register their interests within the deadlines prescribed in the relevant Notice of Initiation. Once registered, parties can typically submit evidence or written comments, request for a hearing and access non-confidential versions of the investigation files. Although the Commission tends to only consider submissions from parties that register on time, it retains discretion to take into account late submissions of significant relevance, provided that this does not compromise the procedural fairness of the investigation.

AD & CVD Investigations

Anti-dumping and anti-subsidy investigations usually start with a complaint lodged by the EU industry. The complaint must contain sufficient prima facie evidence of dumping or subsidisation, injury and causation. The Commission then decides whether to initiate proceedings within a 45-day deadline and, if it does so, publishes a notice of initiation in the Official Journal of the European Union. The Commission may also initiate investigations ex officio where sufficient evidence of dumping/subsidisation, injury, and causation exists. 

Once an investigation is initiated, interested parties are invited to register, submit questionnaire responses, request hearings and provide written comments. The Commission typically conducts sampling where there are numerous exporters, importers or Union producers involved. Following the submission of questionnaire responses, the Commission typically carries out on-site verifications to ensure accuracy of the data submitted by interested parties. The Commission then assesses whether the legal conditions to impose measures are met, determines the appropriate level of duties to remedy dumping/subsidisation or injury, and evaluates whether the imposition of measures would be in line with or against the Union interest.

Provisional measures may be applied if the legal conditions are met, generally for up to six months, and may be retroactive for a maximum of 90 days, if imports were registered at customs following the Commission’s request. Following provisional measures, the Commission adopts definitive measures in the implementing regulation, taking into account all comments and submissions. Investigations are usually concluded within 13 months, extendable to 16 months in exceptional circumstances. Member state customs authorities then enforce and collect duties at importation.

SG Investigations

Safeguard investigations follow a different logic and require higher thresholds, as they focus on a sudden, sharp increase in imports causing serious injury. 

Unlike in AD and CVD cases, safeguard actions are initiated by the Commission. The investigation is initiated upon information provided by a member state (or member states) that there is sufficient evidence to support the initiation of a safeguard investigation. The Commission is required to initiate the investigation within one month of receiving information from a member state and to publish a Notice of Initiation in the Official Journal of the European Union. In practice, safeguard complaints are predominantly prepared by the domestic industry or industrial associations, which collect and structure the evidence of import surges and injury. These complaints are then coordinated with, and formally transmitted by, the relevant member state(s) to the Commission, which triggers the initiation of the investigation.

A safeguard investigation must normally be completed within nine months, although in exceptional circumstances the period may be extended to eleven months. Questionnaires are not as comprehensive as AD and CVD investigations and focus on overall trends in imports, market conditions, and injury indicators rather than individual prices or costs. Interested parties may have access to relevant non-confidential information and may be able to present their comments in writing, which may be crucial in determining Union interest. 

Provisional measures may be applied in critical cases for a limited period (up to 200 days), and they are usually not retroactive in nature.

The Commission publishes notices of initiation, regulations imposing measures, and regulations or decisions concluding or terminating proceedings in the Official Journal of the European Union. Disclosure documents and case information are also provided to interested parties during the investigation but are usually not available to external stakeholders not registered to the investigation as interested parties. 

In principle, the EU may impose trade defence measures on imports from any jurisdiction if the legal conditions are met. An exception exists in sectors covered by the European Economic Area framework, where the use of such instruments between the parties is generally excluded, subject to sector-specific limitations (agriculture and fisheries). Moreover, certain developing countries (eg African, Caribbean, and Pacific states) benefited from preferential arrangements which in some sectors temporarily limited or waived the application of trade defence measures. Most of these arrangements have expired or been replaced by new frameworks. Therefore, trade defence measures may now apply where they previously could not. In the case of Türkiye, the Customs Union Agreement does not include a limitation on imposing trade defence measures. 

Anti-dumping and anti-subsidy measures normally remain in force for five years unless repealed earlier or extended following an expiry review. Before the five-year period ends, the EU industry may request a review if it can show that the expiry of the measures would likely result in the continuation or recurrence of dumping or subsidisation and injury. For other proceedings, such as interim reviews, new exporter reviews and anti-absorption investigations, the five-year timeframe does not apply. 

Safeguard measures operate on a shorter timeline. Definitive safeguard measures may remain in force for up to four years, including any provisional period. Where their duration exceeds three years, a mid-term review is required, and the measures may be extended once, up to a total maximum duration of eight years. In practice, safeguard measures have been subject to frequent, sometimes annual functional reviews, such as in the case of steel safeguard measures. This reflects the Commission’s effort to ensure the measures remain proportionate, effective, and in line with the Union interest.

AD & CVD Investigations

A review is usually initiated following a substantiated request by the EU industry (or by the Commission ex officio), an exporter, an importer or another interested party, depending on the type of review. The request must contain sufficient evidence supporting the grounds for review, such as changed market conditions, continuation of injury, circumvention or the need to reassess the duty level.

If the Commission considers that the evidentiary threshold is met, it opens the review by notice in the Official Journal. The procedure then broadly follows the structure of an original investigation, including questionnaires, submissions, hearings and disclosure of essential facts. Existing measures generally remain in force while the review is pending, especially in expiry reviews.

The outcome may be the maintenance, amendment, extension or repeal of the measures depending on the type of the review. In expiry reviews, the Commission can only extend the duration of the measure or repeal it. The exact timetable depends on the type of review, but many reviews must be concluded within nine to 15 months.

SG Investigations

In safeguard reviews, the Commission follows a similar procedure as an original safeguard investigation, but focuses on whether the conditions for the measure continue to exist, including import trends, the existence of a serious injury, the causal link between increased imports and injury, Union interest, and adjustments in the Union industry. In practice, however, the Commission has greatly extended the scope and role of safeguard reviews, not just to verify whether the conditions for a measure continue to exist but also to redesign and adapt its design and operation. In successive steel safeguard reviews, the Commission conducted detailed assessments of the operation of tariff rate quotas, the impact of liberalisation rates, quota utilisation and circumvention issues, and trade diversion caused by global capacity. This has led to adaptations in quota volumes, liberalisation rates, quota flexibilities, and country coverage.

EU regulations and/or imposing or maintaining trade defence measures may be challenged before the General Court of the European Union under Article 263 TFEU, within two months of their publication. Actions are typically brought by exporting producers, associations or, in some rare cases, EU complainants that can show direct and individual concern.

The General Court reviews whether the Commission respected procedural rights, applied the law correctly and committed any manifest error of assessment. Judgments of the General Court may be appealed on points of law to the Court of Justice of the European Union.

Importers and users often have more limited standing for direct actions and may instead challenge the validity of measures before national courts. Those courts may then refer questions to the Court of Justice for a preliminary ruling on validity or interpretation under Article 267 TFEU.

In February 2026, the Commission imposed definitive anti-dumping duties on imports of valine from China after finding that dumped imports were causing injury to the EU industry. The duties range from 31.3% to 53.8%, which illustrates the Commission’s continued readiness to act in relatively specialised product markets where it considers EU producers to be materially injured.

The EU has recently adopted a new Global Overcapacity Instrument (GOI), which is an additional instrument in the EU’s toolbox aimed at fighting global overcapacity in certain sectors, offering structural adjustments in third countries and providing for the possibility of tailored measures.

In its recently concluded fuse alumina investigation, the Commission for the first time has explicitly referenced economic security considerations in its reasoning, opening the door to a broader interpretation of the Union interest test that goes beyond traditional injurious effects.

The ongoing ferroalloys safeguard investigation shows the Commission’s willingness to apply safeguards to intermediate products that play essential roles in manufacturing supply chains. This points to a more granular targeting (eg, distinct CN codes within related product groupings) to address specific distortions.

The Commission has recently streamlined the registration of imports practice during investigations. This means that retroactive duty applications may be observed more commonly.

No major legislative reform is currently expected in this area. However, certain EU industry stakeholders are requesting changes to the following aspects.

• Lifting the Lesser Duty Rule in order to allow duties to be based on the full amount of dumping in cases where it is greater than injury.
• Factoring labour and environmental compliance costs into normal value or export price calculations to ensure a fair and equitable calculation and to align with injury margins.
• Developing a system of support for SMEs and refining the sampling procedure to ensure greater user involvement in investigations.
• Relaxing the high threshold applied for safeguard investigations to address structural problems in certain key industries.

At EU level, investment security is governed by Regulation (EU) 2019/452, which establishes a co-operation framework for screening foreign direct investment on grounds of security or public order. The Regulation does not itself create a single EU screening authority. Instead, screening remains primarily a matter for member states under their national laws, while the Commission and other member states may comment on transactions of concern.

The review process therefore depends mainly on national law. Where a transaction is subject to national screening, the member state concerned conducts the review and may exchange information with the Commission and other member states. The Commission may issue an opinion, particularly where projects or programmes of EU interest are affected.

Investment screening is administered by the competent national authorities designated under each member state’s screening regime. At EU level, the Commission co-ordinates the co-operation mechanism and receives notifications of transactions under review in the member states. See the available list of screening mechanisms notified to the Commission here.

A transaction may be subject to review where it involves a foreign investor acquiring control, influence or a qualifying participation in a business active in sensitive sectors. The precise thresholds and sectors depend on national law, but common focus areas include critical infrastructure, defence, energy, digital infrastructure, sensitive data and advanced technologies.

Many member states require mandatory notification where a foreign investment meets specified thresholds and concerns sensitive sectors. In addition, member states must notify the Commission and the other member states when a transaction is undergoing screening under the EU framework.

Exemptions depend on national law. They may include certain internal reorganisations, intra-group transactions or transactions falling below the relevant thresholds. The scope of any exemption is determined by the screening regime of the member state concerned.

Penalties are governed by national law and may include criminal or administrative fines, suspension of voting rights, invalidity of the transaction, behavioural conditions or an order to unwind the investment. In serious cases, closing without approval may expose the parties to substantial sanctions (in some cases time in prison).

There is no general EU-level filing fee. Whether fees apply depends on the national regime of the member state concerned. In some jurisdictions filings are free of charge, while others may impose administrative fees.

A key recent development is the political agreement reached in December 2025 on the reform of the EU FDI Screening Regulation. The reform is intended to make the current framework more uniform by requiring all member states to maintain screening mechanisms, introducing minimum sectoral coverage, strengthening the Commission’s co-ordination role and providing clearer procedural timelines. This reflects the EU’s broader concern that uneven national screening regimes create gaps in the protection of critical assets and technologies.

At the same time, the policy debate has moved beyond traditional FDI screening. The Commission’s December 2025 Economic Security Communication reinforced the link between investment screening, export controls and supply-chain resilience, particularly in sectors such as semiconductors, clean tech and critical raw materials. In parallel, the leaked draft Industrial Accelerator Act suggests a more interventionist approach in strategic sectors, including a separate screening mechanism for certain large investments linked to clean tech, AI and EV batteries. Although that proposal is not yet law, it shows that investment control is increasingly being discussed not only in security terms but also in industrial policy terms.

The principal change on the horizon is the formal adoption of the revised FDI Screening Regulation, expected in 2026. The main issues will be the extent of mandatory sectoral coverage, the role of the Commission in reviewing transactions of broader EU concern, and the degree of harmonisation across member states. If adopted in its current direction, the reform would reduce differences between national systems and likely increase the number of transactions subject to filing or closer scrutiny.

A further issue is whether the EU moves towards broader investment controls as part of its economic security agenda. Current discussions increasingly cover investments involving sensitive technologies, EU subsidiaries controlled by non-EU parents, and possibly certain greenfield or expansion projects in strategic sectors. The draft Industrial Accelerator Act also points to possible additional scrutiny of larger transactions in priority industries, together with conditions linked to ownership, local production and intellectual property retention. Even if those ideas are modified before adoption, they indicate that investment screening in the EU is likely to become more integrated with industrial policy and strategic autonomy objectives.

This issue does not arise at EU-level but within the member states.

This issue does not arise at EU-level but within the member states.

This issue does not arise at EU-level but within the member states.

This issue does not arise at EU-level but within the member states.

This issue does not arise at EU-level but within the member states.

The EU is party to the WTO Government Procurement Agreement and its public procurement regime is generally based on non-discrimination and open competition. That said, current policy discussions increasingly refer to “Buy European” or similar concepts in strategic sectors, especially defence and industrial policy. The leaked draft Industrial Accelerator Act also points towards possible sourcing, production and ownership requirements in particularly sensitive sectors, although this is not yet binding law.

The EU maintains an extensive system for protecting geographical indications for agricultural products, foodstuffs, wines and spirits. These schemes are intended to protect product names linked to specific origins and production methods, rather than to reduce imports. They nevertheless provide commercial advantages to qualifying EU and non-EU producers whose products meet the relevant conditions.

There are no other significant issues or developments in the law to mention at this time.