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particular, economic security, Russia's war against Ukraine, health threats, and cyber threats. It does not purport to provide an exhaustive overview of developments.
This regular update expands from the previous Jones Day COVID-19 Key EU Developments – Policy & Regulatory Update (last issue No. 99) and EU Emergency Response Update (last issue No. 115)
LATEST KEY DEVELOPMENTS
Competition & State Aid
- European Commission approves €623 million in German State aid to support two first-of-akind chips factories in Germany
- European Commission approves schemes under Clean Industrial Deal State Aid Framework (CISAF)
Trade / Export Controls
- CBAM (Carbon Border Adjustment Mechanism) – Fully operational as of 1 January 2026
- European Commission publishes Joint Communication on Strengthening EU Economic Security
- Council of the European Union extends sanctions against Russia
Medicines and Medical Devices
European Commission publishes proposed Regulation to strengthen EU biotechnology and biomanufacturing sectors (Biotech Act)
Cybersecurity, Privacy & Data Protection
- European Commission launches EU Data Act Legal Helpdesk
- EU AI Act – Recent developments
| COMPETITION & STATE AID | |
| European Commission approves €623 million in German State aid to support two firstof-a-kind chips factories in Germany (see here) |
On 11 December 2025, the Commission announced the approval of a total of €623 million in German State aid to support the construction of two first-of-akind semiconductor factories in Germany, comprising: (i) a €495 million direct grant to GlobalFoundries to support the establishment of new 300 mm wafer manufacturing capacity by adjusting and expanding the company's existing site in Dresden. The technologies produced at the facility are developed under the IPCEI (Important Project of Common European Interest)* for microelectronics and communication technologies, which had approved up to €8.1 billion in Member State support (see Jones Day EU Emergency Response Update No. 103 of 23 June 2023). Now, these technologies will be adapted for dual-use purposes, specifically targeting the aerospace, defense, and critical infrastructure markets; and (ii) a €128 million direct grant to X-FAB for building a new open foundry facility at its existing site in Erfurt. The new facility will aim to combine existing capabilities (so-called micro-electromechanical systems (MEMS)) with innovative packaging and integration processes. These chip technologies are crucial for applications in the automotive, AI, and medical sectors. Basis. The Commission's assessments of both above-referred projects were based on Article 107(3)(c) TFEU (which enables Member States to grant aid to facilitate the development of certain economic activities subject to certain conditions) and on the principles set out in the European Chips Act, which entered into force on 21 September 2023 (Regulation (EU) 2023/1781 of 13 September 2023 establishing a framework of measures for strengthening Europe's semiconductor ecosystem). To recall, the Chips Act is part of the Commission's package of measures released in 2022 (see here) aimed at ensuring the EU's security of supply and technological leadership in the field of semiconductors. (Micro-) chips or semiconductors are key building blocks for digital products, e.g., smartphones, computers, and medical equipment (see also Jones Day EU Emergency Response Update No. 107 of 29 September 2023). Assessment. According to the Commission's assessments of both measures, the State aid to GlobalFoundries and X-FAB will contribute to increasing the EU's autonomy and technological leadership in semiconductor technologies. In particular, the Commission deemed the facilities as: − first-of-a-kind, by offering manufacturing services currently not present in Europe; and − contributing to security of supply in Europe (e.g., by committing to comply with priority-rated orders to produce in Europe in case of a supply shortage; and by helping to halt overreliance on open foundries located outside of Europe). Body of approved measures. These State aid approvals are the Commission's tenth and eleventh decisions based on the principles of the Chips Act. Past approved measures account for cumulative State aid of some €13.2 billion, provided by different Member States, and supporting the manufacturing of different semiconductor technologies and applications (e.g., in 23 November 2025, the Commission announced the approval of a €450 million Czech State aid measure to support US chipmaker Onsemi in building |
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