EU: Consultation on First IPI Review Seeks Feedback by November 27

On September 10, 2026, the European Commission's Directorate-General for Trade and Economic Security launched a public consultation on the first review of the International Procurement Instrument (IPI), the EU reciprocity tool established by Regulation (EU) 2022/1031. The consultation, open from September 4 to November 27, 2026, invites EU producers, contracting authorities, traders, importers and other stakeholders to feed back on the instrument's scope, functioning and efficiency.

The review is not discretionary. Article 14 of the IPI Regulation obliges the Commission to assess how the instrument has worked and report its findings to the European Parliament and the Council. Because the IPI produced its first investigation and first measure only in the past 18 months, this review doubles as the first hard look at whether the thresholds, procedures and remedy design the Regulation set in 2022 actually fit the market-access problems EU bidders face abroad.

What does the consultation ask stakeholders to address?

The Commission seeks evidence and views across eight specific areas, each mapping to a live design choice in the Regulation. The consultation asks how well the instrument works in practice, not whether it should exist.

• the scope of application of the IPI, and whether it reaches the right procurement and the right third-country goods, services and works;
• the rules for determining the origin of goods, services and suppliers, a recurring friction point in procurement investigations;
• the efficiency of the online tool for filing complaints about procurement market barriers in non-EU countries;
• the conduct of IPI investigations and the consultations held with the non-EU countries concerned;
• the thresholds that trigger IPI measures, and whether they sit at a level that captures meaningful restrictions;
• the form and scope of IPI measures themselves;
• the obligations placed on successful tenderers once a measure applies; and
• the exceptions to IPI measures.

The Commission will also weigh the experience gained from the first IPI investigation and the first IPI measure, both concerning medical devices, to judge how contracting authorities, contracting entities and businesses have applied the Regulation in the field.

How does the China medical-devices measure shape this review?

The first measure is the reference case the review will interrogate. On April 24, 2024, the Commission opened an investigation on its own initiative under Article 5(1) into measures and practices of China that seriously and repeatedly restricted access for EU businesses and EU medical devices to China's public procurement market. After publishing its investigation report and finding no acceptable solution from Beijing, the Commission adopted the first IPI measure on June 19, 2025 through Implementing Regulation (EU) 2025/1197, which placed targeted restrictions on access to the EU public procurement market for medical devices and businesses originating in China.

On July 30, 2025, the Commission published a report on the application of the IPI Regulation, setting out the support tools, the China medical-devices investigation and the lessons drawn so far. That report is the factual baseline for the review now open. Stakeholders who dealt with the medical-devices measure, whether as contracting authorities running tenders or as firms excluded or affected, hold the most directly relevant evidence the Commission is asking for.

What could change, and who should respond?

For trade compliance and procurement teams, the stakes are latent but real. A review of this kind can widen the scope of covered procurement, lower the thresholds at which restrictions bite, streamline or toughen the investigation procedure, and reshape the obligations on winning tenderers. Firms that bid into EU public procurement from outside the bloc, and EU exporters that hit walls in third-country procurement markets, have the clearest interest in how those levers are calibrated.

The consultation is the formal channel to put evidence on the record before the Commission reports to Parliament and Council. Medical-device manufacturers, contracting authorities that have run tenders under the China measure, and trade associations with market-access data are the categories the Commission explicitly names as relevant contributors.

Continuous, per-jurisdiction monitoring surfaces a consultation like this the moment it publishes, letting compliance teams weigh in during the window rather than learn about it after the report lands.

Subscribe to the free newsletter

What to do next

For teams in scope, the steps are tight. Confirm whether your procurement footprint, exports or tendering activity touches the eight areas the consultation names, and submit evidence before November 27, 2026, individually or through a trade association. Brief tender and compliance leads on the China medical-devices measure and the July 2025 application report, since the review's outcome will shape how any future IPI measure is designed and applied. Obsidian tracks this dossier as it moves from consultation to Commission report.