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Matthieu Coget

Matthieu Coget's practice sits at the intersection of law and policy, with a focus on European economic security. He advises on the EU’s evolving trade, industrial policy and regulatory tools in response to growing geopolitical and trade tensions, including relevant legal and regulatory frameworks, as well as the geopolitical and reputational risks arising from cross-border transactions pertaining to strategic supply chains.

Matthieu also regularly supports clients in designing and implementing policy engagement strategies, and building and coordinating coalitions at both EU and Member State level.

Matthieu also maintains an active pro bono practice.

Contact:Read more about Matthieu CogetEmail

EU Member States are currently designing two possible new Important Projects of Common European Interest (“IPCEIs”) to support the development of AI and compute infrastructure in the EU (together the “Digital IPCEIs”), subject to European Commission (“Commission”) approval.

On 10 March 2026, the “matchmaking” phase under the IPCEI on Artificial Intelligence (“IPCEI-AI”) was officially launched in Berlin. It brings together companies whose AI projects have been pre-selected through national calls for expressions of interest (“CEIs”) in each participating Member State. Its objective is to form European consortia eligible for State co-funding under the IPCEI-AI. National CEIs in 17 participating Member States are now closed; Finland and Lithuania are still expected to launch their CEIs.

A second digital IPCEI on Compute Infrastructure Continuum (“IPCEI-CIC”) was launched in late 2025 by 15 Member States. Several of these participating Member States – including Belgium, Croatia, Estonia, Finland, France, Germany, Hungary, Lithuania, the Netherlands, Romania, Slovakia, and Spain – have not yet launched their CEIs.  

Continue Reading Important Projects of Common European Interest (IPCEIs) on Artificial Intelligence and Compute Infrastructure Continuum

On 4 March 2026, the European Commission (the “Commission”) published its proposal for a regulation establishing a framework for the acceleration of its industrial capacity and decarbonisation in strategic sectors (“Proposed Industrial Accelerator Act”, or “Proposed IAA”), accompanied by four annexes. The initiative is intended to strengthen the EU’s industrial base while accelerating decarbonisation in key manufacturing sectors considered strategically important (i.e., energy-intensive industries, net-zero technology manufacturing, and the automotive manufacturing ecosystem). These sectors currently represent less than 15% of EU GDP, and the Commission’s objective is to increase this share to 20% by 2035. The Proposed IAA was delayed three times before publication and underwent significant rewriting, which reflects both internal debates within the Commission and diverging reactions from Member States.  It also reflects the challenges posed by the broader geopolitical context, as the Commission aims to address economic security concerns through industrial policies whilst navigating international trade relationships and commitments.

The Proposed IAA introduces a regulatory framework combining three policy tools. First, it establishes demand-side measures designed to create “lead markets” for low-carbon and “Made in EU” industrial products through public procurement and certain public support schemes. Second, it introduces conditions for allowing certain foreign direct and indirect investments (“FDI”) in strategic sectors, aimed at maximising the industrial benefits of such investments within the EU. Third, it includes measures to streamline permitting procedures and facilitate industrial clustering, with the objective of accelerating the deployment of manufacturing projects.

This blog summarises the key aspects of each tool and their potential implications for companies active in the covered industries or looking to invest in the covered industries.

Continue Reading European Commission Publishes the Proposed Industrial Accelerator Act

On 10 February 2026, the EU released the agreed compromise text of the new Regulation on the screening of foreign investments in the EU (the “New FIR Regulation”).  The three EU institutions (Commission, Parliament and Council) reached the compromise on the text in December 2025 (see our blog) following several months of trilogues (see our blog).  The text, while not yet officially published, is expected to remain unchanged.  The New FIR Regulation will repeal and replace the current FDI Screening Regulation (EU) 2019/452 (the “2019 FDI Regulation”).  The New FIR Regulation further integrates the EU’s investment screening framework into the EU’s economic security strategy.

Against the backdrop of rising geopolitical friction, the New FIR Regulation aims to address the risk that investors structure transactions to get access to the EU market by anchoring their investments in Member States with lighter FIR controls.  To do so, the New FIR Regulation establishes a unified minimum screening framework across the Member States (e.g., through mandatory national screening mechanisms, harmonised review timelines, and strengthened cooperation obligations), whilst preserving Member States’ ultimate sovereignty on matters of national security.  This will be a major evolution from the 2019 FDI Regulation, which was limited to establishing an information-sharing mechanism while leaving Member States wide discretion as to whether and how to screen foreign investments.

This post discusses the five major areas of change for prospective investors, before offering a few forward-looking considerations.

Continue Reading New Foreign Investment Screening Regulation – Key Takeaways from the Agreed Compromise Text

On 16 December 2025, the European Commission presented the Automotive Package (the “Package”), a set of interlinked legislative and policy initiatives aimed at supporting the European automotive sector’s transition to clean mobility. The Package has four core components: (i) a proposal to revise the CO₂ emission performance standards for cars and vans, (ii) the so-called “Battery Booster Strategy”, (iii) a proposal on greening corporate vehicle fleets, and (iv) a proposal for an “Automotive Omnibus” regulation that would amend several pieces of automotive legislation to simplify regulations for vehicle manufacturers. Together, these initiatives signal a material recalibration of the EU’s approach to vehicle decarbonization.

Continue Reading The EU Automotive Package: Increased Compliance Flexibility, but Growing “Made in the EU” Conditionality

On 3 December 2025, the European Commission adopted the RESourceEU Action Plan, signaling that Europe’s industrial competitiveness will increasingly depend on its ability to secure and diversify critical raw material (“CRM”) supply chains.  For companies, inside and outside the EU, RESourceEU is more than a technical update: it marks a policy shift toward a more interventionist and security-driven approach to CRM governance.

The analysis below outlines the drivers behind the initiative, its main components, and the implications for multinationals trading into the EU.

Continue Reading RESourceEU Action Plan – Strengthening the EU’s Access to Critical Raw Materials

On 3 December 2025, the European Commission unveiled the next phase of its economic security agenda.  Building on the 2023 Economic Security Strategy and the 2024 European Economic Security Package (see our prior blog), the new communication sets out a more assertive and coordinated approach to managing risks linked to trade, investment, technology and critical infrastructure.

The EU intends to remain open to trade and investment, but that openness will increasingly be conditioned on economic security objectives.  For businesses and investors, this translates into more scrutiny, more due diligence, and a more integrated interplay between the EU and Member States.

Continue Reading Strengthening EU Economic Security – More of the Same or a New Approach?

On 23 May 2025, the European Commission adopted several pieces of secondary legislation under the Net-Zero Industry Act (“NZIA”), including an Implementing Regulation on Non-Price Criteria in Renewable Energy Auctions (“Implementing Act”). The Implementing Act gives legal effect to Article 26 NZIA, which obliges each Member State to apply, from 30 December 2025, non-price criteria to either at least 30% of their annual auctioned capacity or, alternatively, to at least six gigawatts annually.

Continue Reading Adoption of Implementing Act on Non-Price Criteria in Renewable Energy Auctions

On July 27, the United States and the European Union announced a trade framework agreement, following a meeting between President Donald Trump and European Commission President Ursula von der Leyen. The deal avoided imposition of a 30% reciprocal U.S. tariff on EU goods that was set to take effect August…

Continue Reading U.S.-EU Trade Framework: Outcome and Next Steps

On 4 June 2025, the European Commission published a decision recognising 13 critical raw material projects located in non-EU countries as “Strategic Projects” under the Critical Raw Materials Act (“CRMA”, Regulation (EU) 2024/1252). This first set of Strategic Projects based outside the EU adds to the 47 Strategic Projects based within the EU announced earlier this year. These Strategic Projects are recognized as significantly contributing to the security of the EU’s supply of strategic raw materials, and will benefit from preferential access to finance and other advantages. For more information on the CRMA and the framework for Strategic Projects, see our previous blog post here.

Continue Reading EU Designates 13 Non-EU Critical Raw Materials Projects as Strategic

On 8 May 2025, the European Union launched a public consultation on potential countermeasures in response to U.S. automotive tariffs and the potential imposition of a 20% “reciprocal” tariff on EU-origin goods—covering around €379 billion of EU exports to the U.S.  In particular, the EU is considering imposing tariffs on U.S. imports worth approximately €95 billion, covering a wide range of industrial and agricultural products.  The Commission is also evaluating possible restrictions on EU exports to the U.S., principally steel scrap and certain chemical products, valued at €4.4 billion.  If implemented, the export restrictions could take the form of export duties, quantitative restrictions such as quotas or licensing requirements, additional administrative charges, or a combination of these measures.  No specific tariff rates have been proposed at this stage and the consultation is open until 10 June.  Notably, the EU has not thus far targeted U.S. services as part of its retaliatory measures.

These countermeasures could be activated if ongoing EU-U.S. negotiations fail to deliver a mutually acceptable resolution, and the U.S. tariffs remain in place.  While the U.S. currently imposes a 10% global reciprocal tariff on most imports, the negotiations follow a decision by President Trump to pause higher, country-specific tariff rates that were scheduled to come into effect on April 9 and would have increased the reciprocal tariff rate on U.S. imports from the EU to 20%.  Those higher tariffs are paused for 90-days, or until 9 July 2025, absent an extension.  EU exports of autos and auto parts to the U.S. are also subject to 25% tariffs, while the U.S. is also considering imposing additional sector-specific tariffs on—among other sectors—imports of pharmaceuticals and related ingredients; semiconductors and semiconductor manufacturing equipment and their derivative products; critical minerals and their derivative products; as well as commercial aircraft, jet engines, and related parts.  Should it proceed with any of these measures, the EU is likely to increase the scope of its proposed response.

If adopted, the EU countermeasures would supplement the existing EU “Rebalancing Tariffs” previously introduced—and suspended until 14 July—in response to increased U.S. steel and aluminum duties.  Most of the products covered by the Rebalancing Tariffs would be subject to a 25% ad valorem duty, with some facing a reduced rate of 10%.  The Rebalancing Tariffs would apply to U.S. goods exports worth up to €26 billion.

The Enforcement Regulation and the Anti-Coercion Instrument

In preparing for a scenario in which negotiations with the U.S. fail to bring tariff relief, the EU has several legal instruments at its disposal to take responsive countermeasures, most notably the Enforcement Regulation and the Anti-Coercion Instrument (ACI), with some overlapping and some distinguishing features.

A. Intended Use of the Two Instruments

The Enforcement Regulation is a long-standing mechanism designed to enforce the EU’s rights under international trade agreements, including under World Trade Organization (WTO) agreements.  Initially adopted in 2014 and amended in 2021, it empowers the EU to respond to breaches of trade obligations—particularly when a trading partner withdraws concessions granted under WTO agreements or fails to implement a ruling adopted by the WTO Dispute Settlement Body.  Crucially, the amended Regulation now allows the EU to act unilaterally when multilateral adjudication is not possible, including in the absence of a functioning WTO Appellate Body (which has lacked the necessary quorum since late 2019, following a U.S. refusal to appoint additional members to the body).

Continue Reading EU Consults on New Tariffs on €95 Billion of U.S. Imports