Evaluate, Monitor and Harmonize

On Wednesday, 3 December 2025, the responsible EU Commissioner Maroš Šefčovič, together with the High Representative for Foreign Affairs and Security Policy Kaja Kallas, presented the Joint Communication on Strengthening Economic Security to the public (JOIN(2025) 977 final). Originally referred to as a “doctrine,” the communication is intended to consolidate previous efforts to promote economic security and, according to Šefčovič, shift them “into a higher gear.” The Communication now outlines various more substantial measures.

Background

The Joint Communication is the latest manifestation of a reorientation of European trade policy towards de-risking that has been ongoing for several years. Back in June 2023, the European Commission, together with then-High Representative Josep Borell, presented an initial European Strategy for Economic Security (JOIN/2023/20 final). The aim was to counter the increasing geo-economic risks triggered by geopolitical tensions, technological upheavals, and global supply chain dependencies.

The first material bundle of measures based on this strategy, the “Economic Security Package”, followed in January 2024. The provisions included in the package comprise, among other things, a reform of investment screening through a revision of the EU Screening Regulation, an expansion of export controls by adding to the list of goods in the Dual-Use Regulation (Regulation (EU) 2021/821; latest amending regulation: Delegated Regulation (EU) 2025/2003), monitoring of foreign investments (White Paper on Outbound Investments), and research security through the review and reassessment of EU funding programs and greater use of synergies between civilian and defense applications in R&D (White Paper on R&D in Dual Use). This already reflected the desired shift from a purely economic perspective to an integrated understanding of economic and security policy, which was further intensified with the Joint Communication presented on Wednesday.

In addition, the communication is accompanied by the ReSourceEU plan, which is mainly intended to amend the Critical Raw Materials Act (Regulation (EU) 2024/1252, CRMA) (these changes can be found in proposal COM(2025) 946 final). The aim of this framework plan is to establish a strategic raw materials and technology policy, for example by starting to stockpile critical minerals, implementing a joint procurement policy, and transitioning to a circular economy with regard to strategic raw materials.

The Measures in Detail

The Joint Communication is to be understood as a continuation and concretization of these goals, plans, and programs. It is intended to bring about a paradigm shift - from merely reacting to global challenges to taking more proactive action. To this end, existing instruments and competencies are to be pooled and new ones created.

The communication identifies six high-risk areas in which the announced measures are intended to achieve the following effects:

• Strengthening supply chain resilience and counteracting high-risk dependencies in critical goods and services

• Attracting value-added inbound investment that reinforces the EU’s economic security

• Supporting a vibrant defence and space industrial base and other high-risk industrial sectors

• Developing and maintaining leadership across critical technologies

• Prevent access to sensitive information and data that could undermine the EU’s economic security

• Prevent and mitigate disruptions to EU critical infrastructure affecting the EU economy

In order to achieve these effects, the Commission wants to be able to examine supply chain dependencies more quickly, with the aim of reducing them as soon as possible. In addition, numerous new groups, centers, and communication channels are to be created to facilitate the gathering and exchange of relevant information and enable greater coordination. In addition to these analysis and governance measures, the Commission also wants to improve its existing instruments.

FDI control

In addition to the reform of the EU Screening Regulation, the Commission intends to issue guidelines to ensure that authorities apply FDI screening consistently. Besides, a monitoring process will be used to identify startups in critical technology areas that could potentially become targets of foreign “hostile takeovers”, so that they can be referred to EU investment alternatives. However, in order not to jeopardize companies during the potentially lengthy periods of financial uncertainty during an FDI screening, a support mechanism is to be “explored”. Moreover, the conditions for investment will be evaluated to enable, for example, technology transfer to the EU.

The Commission also wants to work with supervisory authorities at the member state level to monitor portfolio investments in identified high-risk areas that are not currently covered by the FDI coordination mechanism. How this might work in practice is not described.

Strengthening Europe as a Business Location

The Dual-Use Regulation is to undergo a comprehensive review of its compatibility with the “new geopolitical and economic reality.” Against the backdrop of increasing unilateral export controls, an evaluation will be carried out to determine how European controls in new technology areas can be implemented efficiently under these new conditions. According to the Commission, this should prevent states from “weaponizing” dependencies against the EU.

The Commission also wants to review the use of strategic customs instruments such as tariff suspensions or autonomous quotas for EU companies and, at the same time, expand EU funding programs. This is to be aligned by the EU encouraging European companies to source their components in certain high-risk areas from at least two different suppliers. Additionally, the Commission considers adopting European preference criteria for public procurement as part of the revision of the public procurement directives. Finally, the Blocking Statute (Council Regulation (EC) No. 2271/96), which protects European companies from extraterritorial secondary sanctions imposed by the US, for example, is to be reevaluated with the goal to simplify its application and reduce compliance costs.

Outlook

The Joint Communication largely provides a summary of the current challenges, supplemented by rather vague announcements of initiatives. In order to assess the impact of the measures, it remains to be seen how the Commission will ultimately substantiate its intentions.

The Commission's goal is to make better, more coordinated, and, above all, more proactive use of its existing toolbox. For companies, this also means considering whether they should diversify their risk more effectively. In the event of unfair competition from non-EU countries, they can also insist on the use of the various instruments available to date (e.g., examining whether anti-dumping proceedings should be initiated).

In the context of FDI procedures, it remains to be seen to what extent portfolio investments will be monitored by the Commission and how the interaction with the member states leading the FDI procedure will look.

BLOMSTEIN will closely monitor further developments and keep you informed. If you have any questions on dealing with the new EU requirements for economic security, Leonard von Rummel and the entire team is ready to assist you.