France and Germany are at odds over how the European Union should define European production under its emerging industrial preference rules, with Paris favouring a narrow EU-only system while Berlin wants trusted trade partners including Britain, Canada and Japan to remain eligible.

France and Germany have reopened a fundamental dispute over the European Union’s “Made in Europe” industrial policy, this time over the question that will determine how far-reaching the programme eventually becomes: which countries should qualify as European suppliers.

The disagreement centres on the Industrial Accelerator Act, under which the EU wants to use subsidies and public procurement to strengthen domestic manufacturing and reduce dependence on Chinese production in strategic sectors.

France is pressing for a restrictive definition centred on manufacturing within the EU’s 27 member states. Germany favours a broader approach that could extend preferential treatment to countries with close trade agreements or reciprocal industrial relationships with the Union.

That could bring Britain, Canada, Japan and potentially Turkey within the system rather than treating their products in the same way as goods from China and other outside suppliers, according to reporting on the Franco-German dispute.

The dispute has important consequences because “Made in Europe” is intended to influence how large amounts of public money are spent.

The Industrial Accelerator Act is designed to introduce European-content requirements into selected subsidy schemes and public contracts in sectors including electric vehicles, batteries and clean technology. The underlying objective is to ensure that European public spending supports European industrial capacity rather than increasing dependence on imported technologies.

EU Today has followed the argument since the proposals began taking shape. In February, it reported that the Commission was preparing local-content rules for strategic technologies. The debate has since moved from whether such preferences should exist to how broadly “European” should be interpreted.

Paris wants the benefits concentrated inside the EU. The French position reflects concern that allowing manufacturers in countries with EU trade agreements to qualify could dilute the purpose of the scheme. If access is too broad, the argument runs, public procurement may do little to increase production or employment within the Union itself.

Germany is more cautious about creating a closed EU system. Its manufacturing economy is embedded in supply chains extending across Europe and into neighbouring markets, including Britain and Turkey. Berlin has therefore argued for a “made with EU” approach under which trusted trade partners could participate if their markets also provide reciprocal access to European industry.

That disagreement has become increasingly important for Britain. British manufacturers, particularly in the automotive sector, remain closely integrated into continental production networks despite Brexit.

A strict EU27 definition could therefore produce situations in which components made in Britain count as foreign content even when they are incorporated into vehicles assembled inside the Union.

France and Germany had appeared to be moving towards a broader industrial compromise last week. Their negotiations combined the “Made in Europe” question with disagreements over vehicle-emission rules and the future treatment of combustion-engine technology. The latest discussions show that one of the hardest questions remains unresolved.

There is also concern among some EU governments that an overly broad system could create routes for companies from countries such as China to obtain favourable treatment indirectly.

The argument mirrors a wider change in EU economic policy. Supply disruptions, Russia’s war against Ukraine and China’s dominance of several strategic manufacturing sectors have pushed Brussels towards a more interventionist approach.

France sees public purchasing power as an instrument for rebuilding production specifically within the Union. Germany is seeking greater flexibility for supply chains involving trusted partners and appears more concerned about the trade consequences of drawing the boundary too tightly.

For Brussels, the problem is now practical rather than theoretical. The narrower the definition, the more industrial support remains inside the EU; the broader it becomes, the easier it is to preserve existing supply chains and relations with allies.

France and Germany have proposed giving the European Commission powers to respond within days to serious trade distortions, including the possibility of restricting access to the EU single market. The initiative comes as European concern grows over Chinese subsidies, industrial overcapacity and dependence on critical imports.

French President Emmanuel Macron and German Chancellor Friedrich Merz have called for a new European Union trade instrument capable of acting rapidly against countries whose economic practices cause serious disruption to the European market.

In a joint initiative sent to European Commission President Ursula von der Leyen on Monday, the two governments proposed strengthening the EU’s ability to respond to what they describe as systemic market distortions, including dumping, widespread subsidies and restrictions affecting access to critical supplies.

The Franco-German proposal does not formally identify China as its target. However, many of the practices it describes correspond directly to long-standing European concerns over Chinese industrial policy, including excess manufacturing capacity, state support and restrictions on exports of critical minerals.

The initiative represents a further development in a harder European approach towards Beijing. EU Today reported last week that China had warned it would respond if the EU introduced new restrictions against Chinese companies or products.

Macron and Merz are proposing two additional instruments.

The first would be intended to reduce European companies’ dependence on single suppliers for strategically important products and raw materials. The second would allow the EU to restrict access to its internal market when a third country uses political or economic measures that seriously undermine fair competition.

Under the proposal, the Commission could initiate countermeasures unless a qualified majority of EU governments voted to block them. That would reverse the normal political dynamic in which Brussels must first secure sufficient support before acting.

German officials have argued that the EU needs powers comparable in effect to the United States’ Section 301 trade measures or China’s ability to restrict exports of critical raw materials.

The Commission has welcomed the Franco-German intervention as a contribution to its work on economic security and global trade imbalances. Any new instrument would, however, require legislation and approval by both EU governments and the European Parliament before it could be used.

The proposal comes amid growing concern in both Paris and Berlin over the effect of subsidised Chinese production on European manufacturers.

Germany’s position is particularly significant. Berlin has traditionally been more cautious than Paris about measures that could restrict trade with China, reflecting the importance of the Chinese market to German carmakers, engineering companies and chemical producers.

That position has shifted as German industry faces increased competition from Chinese electric vehicles, machinery and other manufactured goods.

EU Today has previously examined the emerging Franco-German alignment on tougher China trade defences and demands from German manufacturers for broader European action rather than product-by-product investigations.

The new proposals go considerably further by seeking a mechanism capable of dealing with entire sectors and acting much more quickly than conventional anti-dumping proceedings.

Chemicals, PET plastics and hybrid vehicles are among sectors identified in the Franco-German document as areas where additional action may be required.

The timing is also significant. EU leaders are due to discuss trade relations with China at their summit in Brussels on 15–16 October, while Trade Commissioner Maroš Šefčovič is expected to hold talks with Chinese officials beforehand.

The Commission is already attempting to balance two objectives: maintaining Europe’s access to the Chinese market while reducing strategic dependencies that could be used as political leverage.

The Franco-German plan would give Brussels another instrument at the more coercive end of that policy. Its eventual importance will depend on whether governments agree to create it and how readily they would permit the Commission to use it against a major trading partner.