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The European Chips Act: Lessons learnt from 3 years of implementation
The European Chips Act Lessons learnt from three years of implementation
Alexandre Lotito, Ex-Post Evaluation Unit
Key findings
This briefing reviews the first three years of implementation of the European Chips Act and identifies how lessons learnt from its evaluation have been integrated into the legislative proposal to review the Act. Available evidence suggests the Chips Act delivered significant outputs, including the establishment of competence centres and five pilot lines, the foundation of a design platform, substantial public and private investment commitments in production facilities, and a coordination and crisis-response mechanism through the European Semiconductor Board. However, the lab-to-fab transition remains uncertain. While pilot lines have created important technological infrastructure, their contribution to industrial deployment and commercial production is still emerging. Investments in production capacity are significant, but most facilities will only enter production after long ramp-up periods. The evaluation also suggests the Chips Fund improved access to finance for semiconductor and quantum start-ups, and demonstrated strong demand for and uptake of the measure. However, evidence remains limited as to whether it has addressed the broader private capital gap. Key issues highlighted by stakeholders include persistent demand-side weaknesses, fragmented procurement, burdensome procedures for permitting and State aid, limited visibility across the full value chain and incomplete crisis-response mechanisms.
Purpose statement (this title will not be shown in the final layouts)
This briefing is one in a series of implementation appraisals produced by the European Parliamentary Research Service (EPRS) on the operation of existing EU legislation in practice. Each briefing focuses on a specific EU law that is announced to be amended or reviewed in the European Commission's annual work programme. Implementation appraisals aim at providing a succinct overview of publicly available material on the implementation, application and effectiveness to date of that specific EU law, drawing on input from EU institutions and bodies, as well as external organisations.
Background and existing EU policy framework
The European Chips Act
In her 2021 State of the Union address, European Commission President Ursula von der Leyen announced the intention to build a state-of-the-art European semiconductor ecosystem. The European Chips Act package followed the global semiconductor shortage which emerged during the COVID-19 period and disrupted production in key industrial sectors including automotive, energy, healthcare and consumer electronics.1 Supply chain disruptions in semiconductors highlighted their central role to the modern economy as well as the EU's structural vulnerabilities and dependencies on external suppliers. 2
The European Chips Act package was presented in February 2022, combining a communication, a proposal for the core Chips Act regulation, a proposal amending the Joint Undertaking framework introducing the Chips JU and a recommendation on a common Union toolbox to address semiconductor shortages and an EU mechanism for monitoring the semiconductor ecosystem. The legislative procedure on the core regulation concluded with the adoption of Regulation (EU) 2023/1781 on 13 September 2023, which entered into force on 21 September 2023.
At the time the proposal was being prepared, the Chips Act was not accompanied by a comprehensive impact assessment.3 However, the Commission identified a series of failures in its staff working document affecting the Union's technological sovereignty, economic resilience and capacity to support the green and digital transitions. The limited innovation capacity in the ecosystem, the difficult access to risk capital and financing and the persistent shortage of talent, which hindered the capacity of the sector to innovate, were among the failures to address. The semiconductor shortage also exposed vulnerabilities across the entire value chain, highlighting failures related to low investment in manufacturing capacity and supply dependencies. In this regard, the Commission emphasised an insufficient level of investment, which at the time of the proposal represented less than 4 % of global semiconductor capital expenditure (CAPEX) originating from EU-headquartered companies. The high costs, technological complexity and long investment cycles associated with semiconductor fabrication were considered barriers to private investment without public support mechanisms. Finally, the Commission identified coordination failures between national and Union action, which limited the EU's capacity to coordinate investment and crisis-management response.
The Chips Act aimed to reinforce the semiconductor ecosystem, ensuring the resilience of the supply chain and reducing external dependencies. The regulation outlined five strategic objectives:
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Strengthen European research and technological leadership,
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Build and reinforce innovation capacity in the design, manufacturing and packaging of advanced energy-efficient and secure chips,
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Address the skills shortage, attract new talent and support the emergence of a skilled workforce
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Increase production capacity by 2030, establishing a framework to foster security of supply and resilience of the Union's semiconductor ecosystem,
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Establish coordinated risk assessment mechanisms between Member States and the Commission to better anticipate developments of the global semiconductor supply chain.
The European Chips Act is structured around three pillars:
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Pillar 1 establishes the 'Chips for Europe initiative' and supports large-scale technological capacity building and research and innovation activities through pilot lines, a cloud-based design platform, quantum chips activities, a network of competence centres and access to finance. Except for the Chips Fund, which is implemented through the European Innovation Council and InvestEU, the initiative is implemented mainly through the Chips JU and funded under Horizon Europe and the Digital Europe programme.
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Pillar 2 focuses on 'security of supply and resilience' by attracting investment and increasing production capacities. It sets a framework that defines integrating production facilities and open EU foundries for facilities qualifying as first-of-a-kind (FOAK).
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Pillar 3 introduces the monitoring and crisis-response mechanism, including coordinated information-gathering and possible priority-rated orders under defined conditions. It introduces the European Semiconductor Board (ESB) as the governance mechanism of the Chips Act.
In September 2024, the Draghi report on EU competitiveness confirmed the diagnosis underlying the Chips Act, but noted that, despite efforts, investment and public support for semiconductor production in the EU remained below that in the US. The report pointed to the lack of coordinated action by Member States, and to the need to fast-track important projects of common European interest (IPCEI). It also noted the need for shorter approval times for funded projects and the definition of chips procurement preferences for EU products as preconditions to develop a long-term EU strategy. It also recommended a permitting regime for chips across the EU through a simplified EU wide procedure.
The 2026 Commission work programme announced a Chips Act 2.0 for the first quarter of 2026. In March 2026, the Executive Vice-President for Technological Sovereignty, Security and Democracy, Henna Virkkunen, chaired the implementation dialogue on the Chips Act with industry representatives. The proposal was presented on 3 June 2026 as part of the 'sovereignty package'.
EU regulatory framework
The Chips Act is directly embedded in the 2020 Industrial strategy for Europe and its 2021 update, as well as the digital compass, which introduced the objective of reaching 20 % of world production in value for cutting-edge semiconductors by 2030. The Chips Act also operates alongside the IPCEI framework. In particular, two IPCEI were approved in 2018 and 2023 in the field of microelectronics and on microelectronics and communication technologies. The two IPCEI encompass 98 projects in 14 Member States, including €10 billion of State aid, and they aim to leverage €20.2 billion of additional private investment. The design support hub also identifies potential IPCEI candidates for advanced semiconductor technologies.
The competitiveness compass presented in January 2025 linked semiconductors to the Union's agenda on reducing excessive dependencies and refers to the broader economic-security toolkit. The Critical Raw Materials Act, which entered into force in 2024, complements the Chips Act by addressing upstream vulnerabilities in materials needed for digital, clean and defence technologies. In December 2025, the joint communication on strengthening EU economic security highlighted the role of the Chips Act in strengthening supply-chain resilience and counteracting high-risk dependencies in mainstream semiconductors. The communication sets out a non-exhaustive list of tools for economic security, in line with the 2023 European economic security strategy.
Commission proposal to revise the Chips Act
On 3 June 2026, the Commission submitted a proposal for a regulation on a framework of measures for strengthening Europe's semiconductor ecosystem repealing Regulation (EU)2023/1781 on the Chips Act. The initiative is accompanied by an evaluation and an impact assessment.
The proposal's explanatory memorandum states that the Chips Act delivered significant outputs, including the establishment of competence centres and five pilot lines, the foundation of a design platform, substantial public and private investment commitments in production facilities, and a coordination and crisis-response mechanism through the ESB. It also notes that clear capability gaps remain, including the EU's overdependence on third countries for semiconductor design and manufacturing and insufficient crisis-preparedness capabilities.
The memorandum highlights a series of proposed improvements stemming from the findings of the Chips Act's evaluation and the lessons learnt from its early implementation, particularly lab-to-fab industrialisation, demand-side measures, broader value-chain coverage and crisis preparedness:
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First, a series of changes focusing on addressing the lab-to-fab gap challenges, moving from research capacity-building and innovation generation to industrial deployment and scaling up of production:
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The need to broaden the operational objectives for the Chips for Europe initiative to support industrial uptake, scaling and deployment beyond research and innovation (R&I) generation (Article 5),
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The need to support transfer and uptake of technologies developed under the Chips for Europe initiative, including technology maturation, qualification, prototyping, demonstration and first industrial deployment and transfer into production environment (Article 7 on grand challenges).
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Second, a series of measures to improve market uptake, introducing a shift from a mainly supply-driven Chips Act to a stronger demand-side approach. The evaluation found that demand-side weaknesses, fragmented markets, low volumes and limited procurement coordination undermine resilience of the supply chain, potentially leaving new capacity under-used:
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The need to address weak demand aggregation and limited procurement coordination to ensure viability of European production (Article 8 on demand accelerators, Article 9 on demand forum, Article 10 on chip innovation procurement),
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The need to address security of supply and embed demand-side and resilience logic through public procurement (Articles 30-32 on resilience of the supply chain).
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Third, the broadening of criteria for first-of-a-kind facilities to cover the wider semiconductor value chain beyond front-end fabrication, as well as the need to reduce administrative burden related to permitting and investment timelines:
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The clarification of FOAK criteria to include chip design, speciality materials, manufacturing equipment, printed circuit boards, advanced packaging and assembly (Article 2 on definition),
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Measures to address long permitting and investment timelines, including faster permit-granting procedures, one-stop-shops, and single applications (Articles 21-25 on permit-granting procedures).
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Fourth, a series of improvements addressing capacity gaps in terms of mechanisms and tools to assess disruption in a timely and coordinated manner, to ensure crisis preparedness and system-level intelligence:
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The need to address limited insights into the semiconductor supply chains through a more integrated monitoring approach covering the entire value chain (Article 35 on monitoring and anticipation),
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Measure to enable timely risk detection and coordinated responses (Articles 37-38 on preventive action and preventive information gathering).
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European Commission evaluation report and consultations in preparation for the revision
Call for evidence and public consultation
The Commission published a call for evidence in the context of the evaluation and impact assessment of the European Chips Act in September 2025, with the initial intention of publishing the results of the consultation in the first quarter of 2026 together with the proposal for the revised Chips Act 2.0. The call for evidence covers the parallel, or 'back-to-back' exercise of the evaluation of the Chips Act regulation and the impact assessment4 for its revision.
The evaluation aims to take stock of all actions stemming from the Chips Act from June 2023 onwards. The call for evidence identifies several hindering factors, including the lack of manufacturing capacity in the EU of advanced semiconductor nodes (below 10nm) and the limited demand from strategic sectors for such chips, which often does not justify potential large-scale investments for rather low volumes. It highlights growing pressure on the market, where the EU presents a competitive edge on mainstream/essential semiconductors (power electronics, microcontrollers, photonics, sensors), marked by non-market policies and practices in third countries. In terms of implementation, the call for evidence mentions the potential for burden reduction and simplification in the application process for State aid measures related to FOAK under pillar 2 of the Chips Act, as well as shortcomings related to insufficient insights into the current supply chain and EU ecosystem (including monitoring across materials, equipment, design tools and downstream users).
The call for evidence was open for12 weeks, from September to November 2025, and received 209 responses, with the most coming from companies and business organisations (32 %), followed by research institutions (27 %), business associations (15 %) and EU citizens (12 %). The geographical spread of respondents corresponds to major semiconductor hubs in Europe, in Germany (20 %), France (15 %), Belgium (10 %), Spain (10 %), Italy (8 %) and the Netherlands (5 %). The public consultation was carried out in parallel and received 103 survey responses and 39 position papers. The questionnaire had both a backward-looking perspective, on the implementation of the Chips Act, and a forward-looking one, on possible future steps under a potential Chips Act 2.0.
Implementation dialogue on the Chips Act
The implementation dialogue on the Chips Act, chaired by Executive Vice-President Henna Virkkunen in March 2026, brought together stakeholders and industry representatives from across the semiconductor value chain. It aimed to discuss its implementation and identify potential improvements, additions and simplification measures. The dialogue built upon a report developed by the Industry Advisory Group, a working group of the Industrial Alliance on Processors and Semiconductors. The assessment of the implementation of the Chips Act highlights the meaningful results and impact delivered across the chips value chain as well as several structural shortcomings. Across pillars 1 and 2, the analysis notes complex and resource-intensive application and approval procedures, which hamper Europe's positioning in a competitive and agile international environment. Permitting and State aid approval procedures are perceived as lengthy and fragmented between European Commission departments and between different national frameworks. It also identified structural weaknesses under pillar 3 related to governance and a lack of industry involvement in strategic ESB discussions.
Evaluation of the Chips Act
The Chips Act regulation obliges the Commission to submit a report on the evaluation and review of this regulation under Article 40 by 20 September 2026. In the absence of an impact assessment presented for the original 2022 proposal of the Chips Act, and given the lack of evaluation of the 2013 EU strategy for microchips, the evaluation of the regulation is all the more important to assess whether it is achieving its objectives, as was also noted by the European Court of Auditors (ECA).5 The evaluation report on the Chips Act covers the period from its entry into force on 21 September 2023 until the end of November 2025. It is based on an external study which complemented the open public consultation.6 It covers all three pillars of intervention and cross-pillar elements and the five better regulation criteria of effectiveness, efficiency, relevance, coherence and EU added value. The evaluation uses a credible mixed-method, theory-based approach, drawing on desk research, public consultation and targeted stakeholder consultations, case studies, cost-benefit analysis and targeted consultations. The evaluation reconstructs a strong intervention logic for the Chips Act, including socio-economic impacts and impacts on the governance framework. The evaluation is presented as an ex-post evaluation, while, in methodological terms, it is primarily a mid-term evaluation.
In this regard, the observation period of two years is too short to assess several of the evaluation questions. While the report acknowledges this limitation and is transparent in stating that most observable achievements are outputs rather than outcomes and impacts,7 it characterises the limitation as 'rather marginal'. However, it is a central methodological constraint, as it prevents robust assessment of industrial technology transfer, manufacturing output, reduced dependencies, crisis mitigation and long-term competitiveness. The evaluation states that the limitation was mitigated partly by combining stakeholder expectations with their prospective assessment of the Chips Act 2.0 policy options. This approach risks mixing retrospective evidence of the first Chips Act with stakeholder expectations about future impacts and ex-ante modelling supporting the new proposal.
The evaluation finds that Pillar 1, the Chips for Europe initiative, has significantly reinforced the Union's semiconductor research and innovation base. In the open public consultation, 89 % of respondents considered that Pillar I was partially or fully meeting its research and innovation objectives. It should be noted that the assessment is preliminary for some instruments. The design platform had not started onboarding users during the evaluation period and was expected to become operational only in the second half of 2026. The evaluation identifies the lab-to-fab gap as one of the central challenges facing the European semiconductor ecosystem. Some early technology transfer is reported and the pilot lines have encouraged cooperation between research organisations and industrial companies. Stakeholder evidence is rather positive, with some 59 % of public consultation respondents considering that the pilot lines partially or fully supported the transition from laboratory research to fabrication. This share increases to 77 % among research and technology organisations surveyed. Workshops also emphasised the need to move from establishing pilot lines towards their industrialisation, supported by sustained funding, clearer State aid rules and greater involvement of end users in setting technological priorities.
Under Pillar 2, the evaluation finds that the Chips Act contributed to a substantial increase in announced semiconductor manufacturing investment. Before the Act, EU semiconductor capital expenditure represented approximately 4 % of the global total and had remained broadly stagnant for more than a decade. Under the first-of-a-kind framework, the Commission had approved State aid for 11 projects representing more than €32 billion in combined public and private investment. According to the evaluation, annual semiconductor investment was approximately five times higher than in the pre-Chips Act period. The evaluation nonetheless concludes that progress towards greater strategic autonomy remains limited. The facilities have long construction and ramp-up periods, meaning that most had not entered production during the evaluation period. Although modelling cited in the report projects a 38 % increase in EU manufacturing capacity by 2030, global capacity is expected to expand at a similar rate, leaving the European share at approximately 8 %.
The evaluation finds that the Chips Fund improved access to finance for semiconductor and quantum start-ups. The €300 million thematic EIC Accelerator allocation was fully used within two years, while the InvestEU component had supported 31 companies with €116 million in equity investment. The exhaustion of the Chips Fund budget indicates demand and programme uptake. The evaluation does not examine whether beneficiaries raised more private capital, scaled more rapidly, remained in Europe or achieved better commercial results than comparable unsuccessful applicants. Nor does it provide a quantified estimate of the overall financing gap.
The evaluation concludes that the first Chips Act was predominantly focused on the supply side and did not sufficiently address the market conditions required to sustain European production. Workshops and interviews supported measures such as demand aggregation, coordinated procurement and stronger engagement between chip producers and industrial users. The industrial-user survey received only seven responses, and the evaluation does not provide a systematic assessment of expected European demand by application, technology node or sector.
Finally, the evaluation concludes that the European Semiconductor Board has improved coordination between the Commission and Member States. It provides a permanent forum for exchanges on semiconductor strategies, major investments, IPCEI, economic-security risks and cross-border supply-chain developments. The Board also supported the development of strategic mapping, early-warning indicators and the SCAN monitoring system. In the consultation, 88 % of respondents considered that dispersed national strategies required EU-level coordination. The evaluation finds that Pillar III has provided only partial system-level visibility. Monitoring remains focused mainly on manufacturers and customs-based product dependencies, while important information on materials, equipment, design tools, distributors and downstream users remains fragmented.
European Parliament position and oversight activities
Parliamentary resolutions under the 10th legislative term
In March 2025, 54 MEPs co-signed a letter sent to Executive Vice-President Henna Virkkunen urging the European Commission to launch an ambitious Chips Act 2.0, and calling for a long-term chip strategy. The letter calls for greater European investment in AI chips and other semiconductors that were 'not adequately covered under the initial proposal'.
In its resolution of January 2026 on European technology sovereignty and digital infrastructure, Parliament called for a 'comprehensive European industrial policy for the digital ecosystem' to reduce harmful dependencies, strengthen domestic value chains and ensure a secure, trustworthy and innovation-driven digital ecosystem. According to Parliament, the EU's industrial technology ambitions should focus on key strategic technologies for the future, such as semiconductors, and integrate all relevant policy domains, including market access, standardisation, research and development (R&D), investment, trade and international cooperation. Parliament stressed the urgency for action to boost EU domestic semiconductor manufacturing to improve supply chain resilience. This includes an effort to support manufacturing within the EU of both legacy semiconductors widely used in important economic sectors (e.g. automotive) and advanced chips. In this regard, Parliament called on the Commission to place advanced AI chips at the forefront of the revision of the European Chips Act, including their design and production.
Selection of parliamentary questions
Several parliamentary questions from the current term related to the progress made by the Chips Act in support of production capacity, including the results of the review carried out by the ECA. In its answer, the Commission emphasised the achievements under pillar 1 and 2 of the Chips Act, breaking down the €43 billion of investment that had been announced. While recognising that it remains challenging to achieve the digital decade target of 20 % of global semiconductor production by 2030, it highlighted that the EU's production is projected to more than double by 2030 following current market trends.
Regarding export control measures, several parliamentary questions enquired about US restrictions on AI chip exports to EU Member States, as well as the recent case to impose restrictions on Nexperia by the Dutch government and the impact of China's export rules on rare earth elements. In its answer, the Commission reaffirmed its commitment 'to the integrity of the Single Market and ensuring that trade restrictions do not undermine its functioning or the EU's legitimate technological ambitions in the field of AI'. It also suggested recommendations to enhance 'the coordination of national control lists and has also proposed to make the update of the EU list of dual-use controls more flexible and reactive to technological and geopolitical developments'. The Commission also recognised the need to remain vigilant regarding China's export licensing requirements on the rare earth elements (REE) export rules and its impact on specific industries (e.g. defence). It reaffirmed its commitment to reduce dependencies related to critical raw materials (CRMs) by adopting the RESourceEU action plan in December 2025.
Views of the European Council and the Council
In June 2025, the Council adopted its conclusions on the ECA's special report 12/2025 on 'the EU's strategy for microchips'. It stressed the importance of finalising the 'operationalisation of the Chips for Europe initiative, completing the establishment of the crisis response mechanisms and ensuring the timely approval of State aid for first-of-a-kind facilities for semiconductor manufacturing and IPCEI'.
In September 2025, the Semiconductor Coalition, composed of the 27 Member States, issued a declaration on the upcoming revision of the Chips Act, calling for an 'ambitious semiconductor industry agenda'. The declaration highlighted the need for 'a bold and coordinated agenda, aligning national and regional strategies with EU level initiatives' to respond to the current geopolitical, technological and environmental challenges. Building on the conclusions of the ECA's report, it views the current 20 % market share targets as 'unrealistic and too broad, lacking clear strategic direction on where and why Europe should lead in the semiconductor value chain'. Therefore, the declaration proposed three strategic directions: 1) prosperity through a competitive semiconductor ecosystem, 2) indispensability to secure Europe's leadership in critical control points of the global value chain, and 3) resilience for a secure and reliable supply of semiconductors in critical sectors.
Views of the European Court of Auditors
In its special report 12/2025 on the EU's strategy for microchips, the ECA concluded that the Chips Act had strengthened EU action in the semiconductor sector. The court noted reasonable progress in the implementation of the Chips Act, but, given the current level of investment, it concluded that 'the strategy is very unlikely to be sufficient to achieve by 2030 the very ambitious Digital Decade target of a 20 % EU share in the global market value chain by revenue'.
Moreover, the Court found weaknesses in the preparation of the strategy. The urgency of developing the Chips Act led to several gaps in the design, planning and monitoring of the initiative. The lack of evaluation of the previous 2013 strategy did not allow for a full analysis of why it 'fell short of its goals and the resultant failure to draw lessons from the experience could mean that the Chips Act is susceptible to precisely the same problem'. Moreover, the absence of a full impact assessment or public consultation on the proposed Chips Act did not allow for an analysis of the potential trade-offs involved, alternative solutions and their potential impact. In this regard, the Court highlighted that 'European industry's current demand may not be sufficiently considered in the Chips act'.
In terms of implementation, the ECA found that important progress had been made but that it was too slow to meet the overarching objective. In this regard, the Chips for Europe initiative under Pillar I has been progressing well but has suffered some delays. Implementation began after the adoption of the regulation, following intensive preparatory work. While the four pilot lines were expected to reach full capacity by the end of 2026 at the time of the audit, other components such as the design platform or the network of competence centres were still underway. The Court also highlighted that FOAK take-up under Pillar II has been slow, and is 'unlikely to contribute significantly, or in good time, to the Digital Decade 20 % target'. At the time of the audit, out of a potential 13 FOAK facilities, four had received approval and six had entered into negotiations. Even if some progress had been made in terms of monitoring, the ECA concluded that 'crisis response mechanisms are not yet ready for deployment' under Pillar III. This specifically relates to priority-rated orders to ensure supply to critical sectors, for which approval processes were under way at the time of the audit for six companies.
Following the report's publication, the ECA recommended that the Commission 'carry out an urgent reality check on the strategy', including assessing whether its objectives and ambitions remain realistic with regard to the available resources and other external factors that might influence it. It also called on the Commission to 'start preparing the next semiconductor strategy'. The Commission accepted both recommendations, specifying that it could not commit to carrying out the reality check before the end of 2025.
Views of EU advisory bodies and agencies
The European Economic and Social Committee (EESC) adopted an opinion on strategic technologies as a driver for European sovereignty and resilience in December 2023. The opinion concludes that strengthening the EU's capacity in strategic and critical technologies and sectors requires 'intensive research and innovation, the development of skills and competences, secure and affordable access to the right mix of raw materials and energy, proper infrastructure, access to finance, clear and fit-for-purpose regulations, and efficient permitting procedures'. It also highlights the need to define an approach allowing the reinforcement both of entire ecosystems and of sector-specific measures. Moreover, it stresses the need for more coordination between European and national levels, ensuring the integrity of the single market, especially when loosening State aid rules.
Expert and stakeholder views
This section aims to provide an overview of the debate, and is not an exhaustive account of all the different views. It considers some of the public contributions by stakeholders to the Commission's call for evidence for the review of the Chips Act, in order to identify the main arguments put forward by stakeholders in the context of the evaluation. This analysis accounted for input from companies, academic and research institutions, and business associations.
Under Pillar 1, stakeholders broadly recognise the contribution of the Chips Act to build upon Europe's competitive advantage in terms of R&D and the advanced position of leading RTOs in the semiconductor sector. Fraunhofer IZM considers that the Chips Act contributed to establishing the technological groundwork, but emphasises that the next stage should focus on translating these investments into broader industrial impacts. The question of industrialisation of existing pilot lines remains a core priority for several stakeholders. SEMI proposes 'industrial' pilot lines building on existing investments, pooling projects from large companies, SMEs and start-ups to reduce access costs and accelerate commercialisation.
Similarly, CEA calls for supporting industrial transfer of pilot-line innovation to either existing industrial sites or establishment of FOAK plants. Siemens also stresses that Pillar I should more systematically involve end-users from strategic sectors such as automotive, robotics, aerospace, defence, life sciences and energy, so that pilot-line activities are driven by industrial needs and scalability requirements. In addition, stakeholders raised concerns regarding access to pilot-line capacities. CEA calls for continued exploitation of pilot-line investments beyond the initial R&D programmes and suggests complementary funding mechanisms to facilitate access for academic actors beyond lead organisations.
Fraunhofer calls to deepen the involvement of industrial stakeholders and create faster, more effective pathways from research to application. SEMI argues that current pilot lines remain primarily 'research' pilot lines with output that is not directly ready for industrial use. Companies must therefore bear the cost of development and adapting the technologies to their own equipment and processes to qualify for industrial use. Regarding workforce development, SEMI highlights that skills-related initiatives have tended to operate in silos, with limited synergies between the Chips JU, Horizon Europe, Digital Europe and instruments such as Erasmus+. Eindhoven University stresses the role of universities as pipelines for graduate and PhD-level talent, arguing that students should be exposed early on to industrially relevant skills.
Under Pillar 2, stakeholders' feedback generally considers that the current FOAK approach has supported the objective of developing new semiconductor capacity in Europe. However, they often questioned the scope of FOAK eligibility criteria and the administrative burden associated with the procedures. Both SEMI and ESIA argued that FOAK criteria under the current framework had prioritised front-end manufacturing but excluded other strategically important parts of the value chain, including chip design, design tools, equipment, materials and component suppliers. They call for a broader definition of FOAK projects. Siemens added that Pillar II should be extended to design centres and 'fabless' companies, including support for access to advanced EDA tools and foundry services for prototyping and small-volume production.
Stakeholders such as SEMI also identify insufficient support to consolidate existing European manufacturing capacity, including on legacy chips, which might in turn leave important segments of the European value chain exposed, even where Europe has competitive strengths. Fast-tracking Pillar II processes is also seen as essential by industry representatives. SEMI reports that FOAK, Integrated Production Facility and Open EU Foundry procedures have created significant burdens for companies, with overlapping EU and national processes. ESIA similarly argues that long permitting and approval times are a competitive disadvantage compared with other regions, particularly in a sector characterised by short innovation cycles.
Under Pillar 3, stakeholders focus on the effectiveness of coordination and the limits of the current crisis-management framework. ESIA argues that the European Semiconductor Board has not yet fully met expectations. It considers that the advisory role of the Industrial Alliance for Processors and Semiconductor Technologies has therefore remained weak. Siemens also calls for greater transparency and regular engagement between the European Semiconductor Board, industry and end-users. Moreover, Airbus and Air Liquide call for a more comprehensive monitoring and mapping of the semiconductor value chain, highlighting choke points, which are not limited to chip shortages.
Main references
- European Commission, A Chips Act for Europe, staff working document, May 2022.
- European Commission, Call for evidence for an evaluation and impact assessment on the European Chips Act, October 2025.
- European Commission, A framework of measures for strengthening the Union's semiconductor ecosystem (Chips Act 2.0), staff working document, June 2026.
- European Commission, Impact Assessment Report (Part 3), staff working document, June 2026.
- Draghi, M., The future of European competitiveness a competitiveness strategy for Europe, Annex B, European Commission, September 2024.
- Bonnet, P., Ciani, A., Molnar, J. and Nardo, M., EU's strengths and weaknesses in the global semiconductor sector, JRC, March 2025.
- European Court of Auditors, The EU strategy for microchips, Special report 12/2025, December 2025.
- Van Wieringen, K., Strengthening EU chip capabilities, EPRS, European Parliament, July 2022.
- Ragonnaud, G., The EU chips act: Securing Europe's supply of semiconductors, EPRS, European Parliament, June 2023.
- Ragonnaud, G. with Brévière, E., Chips Act 2.0, EPRS, European Parliament, May 2026.
Endnotes
Classification
Policy areas: Evaluation of Law and Policy in Practice | Research Policy | Industry | Digital
Committees: Industry, Research and Energy (ITRE)
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