On 29 September, the European Commission launched a call for feedback on its plans for new trade tools that would strengthen the EU’s trade diversification and economic resilience. The initiative is intended to address situations where a high level of strategic dependence on a single supplier country creates a risk to the EU’s security of supply. The consultation is open until 27 October 2026.
The Commission has provided little detail on the legal architecture of the proposed instrument. The Commission indicates only that trade measures would be complemented by regulatory and financial support measures. In particular, it remains unclear what level of dependency would trigger intervention, whether measures would be product- or country-specific, and what form any autonomous trade measures could take. It also remains unclear how the new instrument would interact with the EU’s increasingly extensive trade and economic security toolbox, including the anti-dumping and anti-subsidy instruments, the EU safeguards regime, the Anti-Coercion Instrument, the International Procurement Instrument, the Foreign Subsidies Regulation, the recently updated Foreign Investment Screening Regulation, the EU dual-use export-control regime, and emerging “Made in Europe” measures, such as those proposed under the Industrial Accelerator Act.
The design of any new instrument is likely to be contested: recent think tank proposals range from an EU analogue to Section 301 of the U.S. Trade Act of 1974 (e.g., Centre for European Reform report) to a tariff-rate quota model structured around GATT Article XXVIII and inspired by the EU’s updated steel regime (e.g., Jacques Delors Institute report).
The proposal fits within a broader shift in the EU’s economic security policy. In its December 2025 Communication on strengthening economic security (see our blog), the Commission stressed that companies should diversify critical supply chains and eliminate complete reliance on a single high-risk supplier. The concern is increasingly concrete: a 2026 Commission report identified 204 products in sensitive ecosystems for which the EU is heavily dependent on a single supplier country, with more than half of those dependencies originating in China.
The timing for this consultation is significant. During a mid-September dialogue with European industry, Trade and Economic Security Commissioner Maroš Šefčovič discussed critical supply chain dependencies and whether greater use should be made of existing policy tools or whether new ones may be required. A few days earlier, President von der Leyen used her State of the Union address to highlight both mounting Chinese competitive pressure and the EU’s continued dependence on China for critical raw materials, noting dependency levels above 80% for many materials and 90% for certain rare earths. Commissioner Šefčovič is also expected in Beijing this autumn for further EU-China trade discussions, including on trade imbalances and supply-chain dependencies.
Businesses operating in strategically sensitive or highly concentrated supply chains may wish to assess whether their sourcing patterns could fall within the Commission’s emerging concept of a “high-risk dependency” and consider engaging in this critical window of policy formation.