CECIMO and 49 other European industrial organisations are asking EU governments and the European Commission to strengthen trade defence against unfair competition and state-supported overcapacity. Their 23 October joint position calls for additional investigative resources, fuller use of existing instruments and targeted measures addressing distortions extending beyond individual shipments. These are policy demands from industry, not newly imposed duties.
The coalition represents manufacturers and other industrial interests concerned about the effect of underpriced imports on investment decisions, jobs and supply chains. Establishing unfair trade practices requires investigation under the relevant legal tests; a complaint alone does not demonstrate dumping, unlawful subsidies or injury. The organisations want those examinations to be more accessible and effective, particularly for companies with limited resources to prepare evidence.
The statement cites a €359.8bn EU goods trade deficit with China in 2025, persistent overcapacity and high European energy costs. A bilateral deficit measures the balance of merchandise trade, not whether a particular import is dumped or subsidised. Any remedy would still need to address specific products, pricing or support arrangements, and the required injury or market conditions under EU law.
One immediate request is to increase the staffing and specialist capacity of the Commission’s Directorate-General for Trade. Anti-dumping cases require investigation of export prices, normal values and alleged injury; anti-subsidy cases examine particular forms of financial support and their effects. Gathering evidence can involve production costs, sales volumes, supply relationships and information supplied by domestic manufacturers and exporters.
The organisations also want smaller and medium-sized manufacturers to have practical access to case procedures. Additional investigative staff and technical support could improve the ability to examine complaints and possible circumvention, but the joint position sets no binding staffing increase, budget or timetable. Changes to institutional resources would have to be agreed through the relevant EU processes.
Existing trade defence measures do different jobs. Anti-dumping duties address specified pricing practices subject to investigation, anti-subsidy measures respond to countervailable financial support, and safeguards can be applied under separate rules when qualifying import surges cause serious injury. A decision on one product does not automatically extend to another product, and not all low-priced imports meet the criteria for intervention.
Circumvention is a particular concern where goods are processed, repackaged or shipped through several jurisdictions. Enforcement authorities need evidence of the relevant manufacturing steps, origin, export arrangements and movement of products, rather than assuming that a final shipping port establishes where a good was made. The coalition wants the existing tools applied more effectively to such commercial structures.
A further proposal is to account more fully for environmental and social costs in assessing dumping margins and duties. Supporters argue that unequal treatment of those costs can distort competitive comparisons. Translating the idea into binding methods would require detailed legal work and evidence standards, including consistency with the EU’s obligations under international trade rules. No such change is in force merely because the coalition has requested it.
The statement also asks the Commission to consider whole value chains. European manufacturers can sell machinery and components to each other across borders, and import restrictions intended to protect one domestic producer can increase input costs for another. The signatories therefore seek remedies that do not unnecessarily harm closely integrated European partners or the downstream customers of affected materials.
A targeted new toolkit is proposed for wider state-driven production distortions, including facilities in third-country markets that contribute to surges of goods sold into Europe. Such cases can involve production capacity and investment decisions made years before a particular shipment. The coalition has not put forward a legally adopted instrument or named companies that would automatically face sanctions under the suggested approach.
Industrial equipment makers have particular exposure to those trade flows. European machine tool, component and capital equipment producers compete internationally on price, specifications, service support and delivery schedules. Large orders may be decided over long investment cycles, so sustained pricing differences can influence where customers source machinery and where producers commit capital. However, price competition alone is not evidence of an unlawful subsidy or trade practice.
Trade measures can themselves alter purchasing decisions, raw material costs and manufacturing lead times. Before a remedy is applied, authorities need to assess the relevant domestic industry, the cause of injury and the effect on companies importing inputs. The coalition’s proposed approach therefore combines faster enforcement with its stated aim of preserving complex European value chains rather than imposing duties indiscriminately.
The coalition’s October 23 position lists 50 organisations, compared with an appeal involving 44 organisations earlier that month. The additional signatories do not constitute the introduction of new EU law. Member-state responses, any Commission proposals and the outcome of relevant investigations will determine whether the requested changes affect actual import conditions.
Until an institution changes the rules or completes a product-specific investigation, manufacturers remain subject to the existing trade defence framework. The coalition has set out priorities for faster and more extensive enforcement, while the necessary legal evidence, remedies and possible effects on European users of imported materials remain to be assessed.
