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Europe’s Trade Agenda

Position paper - Trade

9 September 2026

KEY RECOMMENDATIONS

The EU’s trade agenda should reinforce Europe’s resilience while preserving the openness that underpins its global competitiveness. While acknowledging the need to defend Europe’s strategic autonomy, a balanced approach is essential to avoid unintended consequences for supply chains, businesses, workers and consumers.

Openness as a strategic asset

The EU’s openness to global trade is not a weakness, but a strategic asset. Diversified sourcing across international markets allows companies to mitigate risks, adapt to disruptions, and maintain continuity of supply. Overly restrictive approaches risk concentrating dependencies rather than reducing them, while weakening the EU’s position in global value chains. Trade policies should therefore reinforce diversification and trusted trade partnerships, rather than limit them.

Targeted, evidence-based, proportionate, and transparent measures

To remain effective and credible, economic security measures must be grounded in clearly identified and evidence-based, data-driven risks. Broad or precautionary restrictions risk creating uncertainty, discouraging investment, and sending ambiguous signals to the EU’s trade partners. Measures should be carefully targeted, proportionate to the specific risk addressed, and limited in scope and duration. Transparency and predictability are critical to provide legal certainty for operators and to maintain trust among international partners.

Safeguarding supply chains and affordability

Well-functioning supply chains are essential to the EU economy and to the availability of affordable goods for consumers. Measures that unintentionally disrupt these flows can have cascading effects, including shortages, increased costs, and reduced choice. Downstream impacts should be reflected more clearly in the Union Interest assessment. This should include market availability, sourcing and cost impacts, consumer affordability, and whether EU production can meet demand on the necessary scale and quality. Appropriate transition periods should also be provided taking into account that supply chains are planned months in advance.

Inclusive policymaking with downstream sectors

Retail and wholesale sectors are key intermediaries in Europe’s supply chains, with direct insight into sourcing, logistics, and consumer demand. Their involvement in policy design and implementation is essential to ensure that measures are workable and proportionate. In particular, trade defence investigations should better integrate downstream users’ perspectives to avoid outcomes that undermine competitiveness or distort the market.

The case of anti-dumping

Retail and wholesale are not simply importers. They are links between EU trade policy and European consumers and industry and a key downstream sector. The European retail and wholesale sector is important as it provides 26 million jobs, accounting for 1 in 7 jobs in Europe. While anti-dumping instruments are designed to address unfair trade practices, their effects extend well beyond the producers and importers formally involved in investigations. Retailers and wholesalers ultimately absorb a significant share of the resulting impacts through higher sourcing costs, supply chain disruption, reduced sourcing flexibility and, ultimately, effects on consumer prices and purchasing power.

Key messages
  1. Recognition of retail and wholesale as an affected sector: Retailers and wholesalers are increasingly registering as interested parties and contributing evidence in individual investigations – a clear signal of how directly the sector is affected. However, there is a need to create space for the structured involvement of retail and wholesale organisations in ongoing discussions on trade defence policy, economic security and trade relations.
  2. Consumer affordability and the cost of anti-dumping measures: Anti-dumping duties on everyday consumer goods translate, directly or indirectly, into higher prices at the point of sale. Such higher prices affect the affordability of a wide range of consumer goods on the EU market. It also entails costs for EU exporters thereby lowering competitiveness. The Union interest test needs reform and should give explicit and measurable weight to consumer prices and purchasing power, alongside the interests of Union industry. It should demonstrate that their overall economic benefits outweigh the costs for users, retailers, processors, exporters and consumers.
  3. Sourcing realities and exposure to China - what the data shows: Eurostat import statistics, broken down by CN code, demonstrate that in the general merchandise category there are no clear alternative sourcing markets to China. More than 70% of total EU imports by retailers and wholesalers in these categories originates in China, with alternative sourcing options remaining limited or entailing significant cost and quality trade-offs. Where EU production cannot meet demand, global sourcing remains essential to ensure continuity for consumers and businesses.
  4. Cumulative impact of multiple measures: While each investigation may appear justified on a case-by-case basis, the same retail and wholesale value chains are being hit simultaneously by multiple measures. There is currently no systematic assessment of this cumulative burden on downstream sectors and this needs to be addressed. Recent and ongoing cases illustrate the scale of this cumulative burden: duties of up to 70.9% on candles (AD726), up to 99.7% on certain glass fibre fabrics, and up to 90.1% on polyamide yarn, alongside the anti-dumping investigation into alkaline batteries opened in July 2026 (AD756) – each affecting everyday consumer goods with limited or no alternative sourcing. Retailers and wholesalers sourcing across several of these categories face the combined effect of multiple, independently-assessed measures, none of which is required to account for the others.
  5. European competitiveness: Trade defence measures intended to strengthen a specific upstream group of producers may ultimately weaken the competitiveness of European retail and wholesale if sourcing costs rise significantly compared to global competitors. Operators sourcing for other major markets are not subject to equivalent duty levels, creating a structural cost disadvantage for European retailers and wholesalers and for Europe as a consumer market and retail destination. Before introducing trade defence measures, policymakers should also consider whether stronger enforcement of existing EU rules on products originating from third countries could provide a more proportionate and effective response. Trade defence policy should distinguish between cases where such measures are necessary and those where better enforcement would be sufficient.
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