Brussels is preparing three instruments against weaponised trade, two of them promised for December. Both treat the dependencies Europe can exit and the ones it cannot as if they were the same problem.

In December the European Commission plans to put a new arsenal on the table. A rapid-response instrument would let it restrict, and if needed sever, a trading partner’s access to the single market. A diversification instrument, DiversifyEU, would push companies to cut strategic dependencies on single-country suppliers. A solidarity package, von der Leyen told Parliament on 21 October, would ensure that no member state faces the economic pressure that follows alone. China is named in none of the documents published so far. Every line was written with Beijing in mind.

The politics behind the package are real. On 5 October Chancellor Friedrich Merz and President Emmanuel Macron wrote to Ursula von der Leyen asking for “powerful measures up to an immediate cut-off from the internal market if needed”, activated by reversed qualified majority so that no single capital could stall them. Ten days later the European Council asked the Commission to “urgently enhance the EU toolbox with new instruments”, and von der Leyen promised a tool to limit market access “fast and immediately”. The DiversifyEU call for evidence closed on 27 October, and on 23 October Šefčovič told trade ministers in Dublin that it and the new trade defence tool will travel together in a December legislative package. None of the three yet exists as a legislative proposal, and each will need the Council and the Parliament to become law.

The instinct is sound. The flaw sits in the design. The package folds two different kinds of strategic dependencies into a single toolbox, and the weapon it describes works against only one of them.

The Case Paris and Berlin Have Made

The argument for harder instruments deserves to be stated at full strength. The Union ran a goods deficit with China of roughly €360 billion last year, according to Eurostat, and von der Leyen now puts the gap at €1 billion a day. In 2025 Beijing restricted rare earth exports and, during the Nexperia dispute with the Netherlands, interrupted the flow of chips to European car plants. The existing answer, the Anti-Coercion Instrument, has never been used against China, even after leaders described the rare earth restrictions as coercion.

Germany’s change of position is the strongest signal of all. Two years ago Berlin voted against duties on Chinese electric vehicles. It now co-signs a letter asking for a cut-off power. When the member state most exposed to Chinese retaliation concludes that the current toolbox is too slow, the burden of proof shifts to those who would leave it unchanged.

Trade Commissioner Maroš Šefčovič adds a historical argument. Europe’s exit from Russian gas, he has said, was unpopular because the alternatives cost more, and it looked wise only in hindsight. Diversification has a price, and insecurity costs more.

Two Strategic Dependencies the Package Treats as One

The weakness lies in what the instruments assume about supply. Europe’s strategic dependencies on China come in two kinds, and they call for opposite treatment.

The first is overcapacity: sectors where Chinese output floods a market that European producers still serve. Chemicals, machinery, steel, and hybrid vehicles belong here. Leaders discussed extending safeguards to chemicals and machinery in October, and Šefčovič has since named plastics as a possible next candidate. The hybrid understanding he reached in Beijing caps imports at 350,000 vehicles in its first year, a cap von der Leyen says will cut Chinese exports by around 45 per cent against projected volumes. In these sectors a cut-off threat is credible because Europe has its own factories to fall back on. Closing the door hurts the exporter more than the buyer.

The second is chokepoints, the strategic dependencies for which no second supplier exists at scale. Here the Commission’s own figures leave little room for optimism. A Commission factsheet accompanying its RESourceEU Action Plan of December 2025 records single-country dependence of 100 per cent for rare earth processing and recycling, 90 per cent for permanent magnets, and 89 per cent for lithium. Even with every planned project delivered, it projects 60 per cent for rare earth processing and 80 per cent for magnets in 2030. A threat to cut off access in these goods is a threat Europe would aim at its own assembly lines.

Beijing understands the distinction exactly. Its 2025 export controls struck at chokepoints rather than at overcapacity goods, because that is where the asymmetry runs in its favour. A European instrument that is strong in the first category and unusable in the second invites China to answer every overcapacity measure with a chokepoint response. Its Ministry of Commerce has already warned Paris and Berlin against what it calls the pan-securitisation of trade.

The test arrives before the package does. China’s suspension of its October 2025 rare earth controls, including the rule reaching foreign products in which Chinese rare earths make up as little as 0.1 per cent of the value, expires on 10 November. Beijing has promised Brussels a fast track for licences, not freedom from them. A month before the Commission unveils its cut-off power, Europe’s magnet supply will rest on permissions granted case by case in Beijing.

The Cost Lands on the Buyer

DiversifyEU compounds the problem. Its logic is to make strategic dependencies expensive for the companies that hold them. Options under discussion include tariffs on buyers who source above a set threshold from one country, and preferences in public contracts and subsidies for those who do not. Šefčovič set out the principle in June: for critical supplies, companies “have to have three different suppliers”. The call for evidence concedes that exposed firms will face short-term adjustment costs and judges them worth paying.

Industry’s replies to that consultation describe the constraint differently. The carmakers’ association ACEA warned that diversification fails when it is “mandated against a supply base that does not yet exist”. The Federation of German Industries, which has backed the tougher China line, opposed binding mandates and called tariffs the wrong tool for the purpose. Ikea, among the largest buyers in Europe, said its pace is set not by price signals but by the years and capital needed to build qualified alternatives.

That is where Šefčovič’s gas analogy turns against him. Europe left Russian gas because liquefied natural gas already existed on a world market supplied by the United States, Qatar, and Norway, and public money built the terminals to receive it. There is no Qatar for rare earth separation. Where the Commission’s own table records 100 per cent dependence, a rule demanding three suppliers asks companies to buy from firms that do not exist. A mandate to buy elsewhere, applied where elsewhere does not exist, diversifies nothing. It raises European costs and leaves the strategic dependencies where they were.

The solidarity mechanism gives the game away. The Commission is designing support for the victims of the retaliation its new tools will provoke before it has funded alternative suppliers at the scale its own figures require. RESourceEU committed up to €3 billion over twelve months to short-term alternatives, and the same plan still projects 80 per cent single-country dependence for magnets in 2030. Europe is pricing the damage of a fight it has not yet equipped itself to win.

What the December Package Should Contain

None of this argues for leaving the toolbox as it stands. It argues for a different order and a sharper scope.

First, the rapid-response instrument should be written for overcapacity, where Europe holds the stronger hand, and its legal text should say so. Reversed qualified majority is a sensible answer to the veto problem. Applied without sectoral discipline, it would also let a majority impose costs on the member states whose industries sit closest to the chokepoints.

Second, DiversifyEU should be judged by its money rather than its mandates. For chokepoint goods, the measure that reduces strategic dependencies is the one that pays for second sources: offtake guarantees, joint purchasing, stockpiles, and equity in processing capacity outside China. A diversification law whose financing line is smaller than its compliance burden is a tax on European manufacturers.

Third, the Commission should show that it can use the instrument it already has. An Anti-Coercion Instrument never once turned on Beijing does not become credible because a stronger one is drafted beside it. Deterrence rests on demonstrated willingness, not on the length of the statute.

The October consensus is genuine and overdue. Paris and Berlin are aligned, the Council has asked for new tools, and the Commission has a date. The risk is that Europe confronts its strategic dependencies in December with a weapon designed for one front and announced for both, and learns at the first delayed licence from Beijing that the kill switch works only where it was least needed.