The Declaration of the Semicon Coalition marks a decisive moment in Europe’s ongoing effort to consolidate technological sovereignty within the global semiconductor ecosystem. Signed in Brussels on 29 September 2025 by ministers from twenty-seven Member States, the document calls for a “revised and forward-looking EU Chips Act”—a legal and strategic recalibration of the Union’s approach to a sector now recognized as essential for Europe’s economic security, competitiveness, and strategic autonomy.
From policy to legal architecture
The Coalition’s declaration situates semiconductors alongside aerospace and defence, urging the European Union to treat the industry as a strategic domain within the meaning of the EU’s Economic Security Strategy. This classification implies the potential activation of protective and interventionist instruments already available under EU law—such as the Foreign Direct Investment Screening Regulation (EU) 2019/452 and the evolving IPCEI framework—to safeguard critical technologies.
By invoking the need for a “second-phase Chips Act,” the Coalition implicitly acknowledges the legal and financial limitations of Regulation (EU) 2023/1781, which established the initial Chips Act. The first iteration focused primarily on coordination, crisis response, and limited funding mechanisms. The revised version, as envisioned by the signatories, would instead elevate the Chips Act to a more operational, industrial policy instrument, capable of directly steering investment, R&D, and infrastructure deployment.
Strategic objectives and legal coherence
The declaration articulates three overarching objectives—Prosperity, Indispensability, and Resilience—which collectively frame a new legal rationale for EU intervention:
- Prosperity, through a competitive and value-generating semiconductor ecosystem aligned with Article 173 TFEU on industrial policy;
- Indispensability, by ensuring European leadership in technological control points such as design, materials, and manufacturing—echoing the logic of “technological non-dependence” underpinning EU strategic autonomy;
- Resilience, by guaranteeing a secure and reliable supply of chips for critical sectors, a goal resonant with Article 122 TFEU on crisis management and supply chain security.
These objectives would require measurable targets subject to periodic review by the Commission and coordinated with Member States—an institutional mechanism reminiscent of the European Semester, but dedicated to industrial resilience.
Policy priorities and legal levers
The Coalition’s agenda identifies five policy pillars, each linked to specific legal and regulatory implications:
- A Complementary Ecosystem: A call for streamlined permitting, infrastructure facilitation, and emergency legislation to fast-track strategic investments—potentially invoking Article 114 TFEU as a harmonizing basis for cross-border industrial procedures.
- Financing and IPCEIs: A proposal for a fast-track Important Projects of Common European Interest mechanism, simplifying State aid approval and funding allocation. This would require an adjustment of the 2021 IPCEI Communication and a clearer interface with the Multiannual Financial Framework (MFF) 2028.
- Skills and Workforce Development: The establishment of a European Chips Skills Programme, extending the scope of existing Chips Competence Centres and creating legal grounds for transnational educational cooperation under Article 165 TFEU.
- Sustainability: Integrating environmental objectives—such as renewable energy use and hazardous substance substitution—within chip manufacturing aligns the proposed legal framework with the European Green Deal and the Sustainable Products Regulation.
- International Partnerships: The declaration embraces open strategic autonomy, inviting cooperation with “like-minded partners” while maintaining reciprocal access to R&D infrastructure. This approach reflects a nuanced balance between WTO-compatible openness and defensive industrial sovereignty.
A coordinated legal re-foundation
The Semicon Coalition’s initiative signals a transition from declaratory industrial policy to binding legal coordination. It seeks to consolidate Europe’s fragmented semiconductor landscape through an integrated legal framework that connects competition law, trade defence, research funding, and environmental compliance. The implicit goal is to construct a European Semiconductor Compact—an internal market instrument reinforced by external strategic partnerships.
In legal terms, this shift requires not merely the amendment of Regulation (EU) 2023/1781 but its transformation into a hybrid legislative architecture: one combining regulatory harmonization, conditional funding, and security-based derogations. If successful, the revised Chips Act could serve as a prototype for future EU legislation on critical technologies, where economic and security rationales converge.