CDS position statement on the European Commission’s call for evidence for an evaluation and impact assessment on the EU Chips Act 2

This contribution builds upon the CDS’ engagement with regulation, innovation competition, and industrial policies, and digital markets.

On 5th September 2025, the European Commission published a Call for Evidence for an Evaluation and Impact Assessment concerning the review of the EU Chips Act (Chips Act 2). The initiative is aimed at strengthening the EU’s resilience and technological sovereignty in semiconductor technologies and applications, in particular by:

• Reducing the EU’s dependency on other parts of the world for leading-edge chips, notably by increasing the EU’s manufacturing capacity in advanced semiconductors for critical sectors, and

• Increasing systemic insight into the resilience of key market actors, supply chains, and the overall EU semiconductor ecosystem to enable more effective monitoring and crisis preparedness.

The Centre for a Digital Society (CDS) at the European University Institute (EUI) welcomes the opportunity to contribute to this consultation. The submission addresses the three issues highlighted in the Call for Evidence:

• The EU’s persistent dependence on non-EU suppliers for sub-10 nm chips;

• The erosion of Europe’s competitive edge in essential and mainstream semiconductors;

• The limited visibility over the resilience and vulnerabilities of the semiconductor ecosystem.

Our analysis aims to support a forward-looking policy debate by identifying institutional, economic, and governance gaps that hinder the effective implementation of the Chips Act and by outlining evidence-based options to strengthen the framework. In evaluating the Commission’s policy options, the CDS identifies targeted amendments to the Chips Act (Option 2) as the more effective and strategically coherent avenue for addressing Europe’s structural vulnerabilities.

In its conclusions, the CDS recommends:

• Designing targeted instruments to secure EU’s access to leading edge chips for strategic sectors and participation in their manufacturing while safeguarding competition and innovation;

• Reinforcing long-term support for Europe’s competitive strengths in essential and mainstream semiconductors;

• Establishing a structured, proportionate, and enforceable EU-level data gathering framework, integrated with Member State and selected firm-level reporting to improve ecosystem mapping and risk assessment