On Sept 29, China's Ministry of Commerce responded to reports that some EU member states are pushing the European Commission to build a "European 301 tool". Germany and France are finalizing a joint document to lower the activation threshold of the EU's Anti-Coercion Instrument — potentially able to exclude Chinese products from the EU market within 24 hours. MOFCOM called the tool typical protectionism and said China will respond firmly if discriminatory measures are adopted, with counter-tools including anti-discrimination and supply-chain security investigations.
For European SMEs this is a concrete two-way risk alert: if China-EU trade friction escalates, your sourcing costs, customs clearance and market access on both sides could be affected. Still, the new tool would not be ready until next year at the earliest — the window remains open. Put a "China+1" supply-chain backup plan on the agenda and watch the China-EU trade consultation mechanism, without panic adjustments.