Level Playing Field

China dominates almost the entire solar value chain and accounted for more than 95% of the EU’s solar panel imports by value in 2024. State subsidies, cheap financing and massive overcapacity allow Chinese producers to sell in Europe below their sustainable production cost – since August 2024, module prices have stayed around 30% below that level. European manufacturers are not asking to be shielded from competition. But competition must be fair.

A level playing field cannot be restored with a single tool. It requires the EU to use all of its instruments together – trade policy, industrial policy and economic security policy.

Our position

• Diversify EU: make solar PV a priority sector, with binding diversification targets, monitoring of upstream dependencies and requirements on the trustworthiness of suppliers.
• Trade defence: use anti-dumping and anti-subsidy instruments earlier and across the whole value chain, staff the Commission’s trade defence services properly and develop a new, WTO-compliant instrument against state-induced overcapacity.
• Foreign Subsidies Regulation: apply it strategically to patterns of non-market behaviour, not only to individual transactions.
• Market rules: Made in Europe requirements in the Industrial Accelerator Act and strictly enforced resilience criteria under the NZIA, so that public money supports European value creation.
• Responsible products: consistent enforcement of the Forced Labour Regulation and of sustainability requirements, so that products made under unacceptable conditions cannot undercut European producers.
• Visibility: a European campaign promoting Made in Europe products.

ESMC has joined 22 other European industry associations – from steel and chemicals to glass and aluminium – in a joint call for more ambition in EU trade defence, and has submitted eight recommendations to the Commission’s Diversify EU initiative.