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France says EU’s ‘Made in Europe’ law should not include the UK

France is leading a push to exclude the UK from the EU’s “Made in Europe” policy that could result in British companies losing out in the race to supply European countries with low-carbon technologies and electric cars.

The plans were raised by Andy Burnham when he met the European Commission president, Ursula von der Leyen, on the sidelines of the UN general assembly earlier this week.

The policy, still under negotiation, aims to protect European companies from intense and “unfair” state-subsidised competition from China. But the government fears British companies risk being collateral damage and resolving the issue has become one of Burnham’s top priorities for the EU-UK relationship.

One key EU proposal is the Industrial Accelerator Act (IAA), which would require authorities spending public money – awarding subsidies or public contracts – to favour European products in sectors such as renewable technologies and electric cars.

But there is an intense debate inside the EU on how to define “made in Europe” and how far to include countries such as the UK, Canada and Japan.

At a meeting of EU industry ministers in Brussels on Thursday, France pushed for a narrow definition, starting with the EU27.

“European taxpayers’ money should support [European] workers and European factories,” the French industry minister, Sébastien Martin, told reporters.

Asked about the UK, he said: “The United Kingdom made a choice a few years ago to leave the European Union.

“That doesn’t mean that we don’t discuss things or that we don’t trade, it doesn’t mean that there can’t be agreements in certain sectors, but fundamentally there are those who have chosen the European project and those who have decided to leave.”

France’s Europe minister, Benjamin Haddad, speaking in London, had few assurances to offer the Burnham government either.

Asked about the risks of pushing the EU’s like-minded trading partners away, Haddad said: “At the end of the day, if you are not part of the internal market and if you are not contributing to the financial capacity of the internal market, you don’t get the same kind of protection.”

Germany wants a broader “Made with Europe” policy that would include the UK and other allies. Germany’s economic affairs minister, Katherina Reiche, told her counterparts: “We must reduce unilateral and critical dependencies, but we must not isolate ourselves from the rest of the world. This means that partner countries must be included in the union-origin principle, in general and on the condition of reciprocity.”

This position gets broad support from Nordic countries, which traditionally favour open trade.

Sweden’s outgoing deputy prime minister, Ebba Busch, who leads on business policy, said “we always miss the Brits”. Sweden wanted “a good solution where there is balance, given that some European countries are not members of the European Union but still completely essential for a functioning European market”, she added.

The charged internal EU27 debate on Made in Europe raises questions about the timing of the EU-UK reset summit, which was postponed when Keir Starmer stood down as prime minister. Since Burnham took office, no date has been fixed for the talks which are meant to happen in 2026.

British officials expect the summit will take place in November, although an earlier 6 November date has been scratched out. By December the EU is expected to be embroiled in deeply difficult internal negotiations on the bloc’s next seven-year budget, which are likely to consume the political bandwidth of EU leaders.

EU insiders believe that a Made in Europe agreement is a top priority for the UK, but have cautioned this cannot happen before the union has finalised its own position.

One EU diplomat said it was a “big risk” if the UK government were to insist on a deal at an autumn summit. “It puts [the UK] in a corner, because this [Made in Europe criteria] is a process that is very difficult for the EU27 [to agree internally].”

The Republic of Ireland, which is chairing EU ministerial negotiations, hopes for an agreement in December on the IAA, including the Made in Europe provisions, between the EU Council and the European parliament. “There are a divergence of views on the Industrial Accelerator Act, on European preference, on working with trusted partners and third countries,” said Ireland’s enterprise minister, Peter Burke. “It is difficult, but we have a pathway in sight.”

Poland’s economic development minister, Michał Baranowski, said it was too early to say whether countries such as Switzerland, the UK, Japan, Australia and Canada would be in or out, adding: “All these countries are in the mix of the discussion.”

The UK, he said, should have clarity on its status when the EU act is passed, he said, adding: “We are in the last stretch, but this last stretch might take a while.”

A UK government spokesperson said: “The UK is a close and trusted European partner, committed to our shared security and economic cooperation.

“We will continue to engage with the EU on Made in Europe and work together, as like-minded partners, to boost growth and open up trade.”