EC088 - ETNO Expert Contribution on Community Framework for State aid for Research and Development and Innovation

ETNO thinks the framework requires some important adjustments. Focusing on smaller players may lead to the exclusion of whole sectors of the European economy. In particular ICT major actors could a priori not be allowed to benefit from state aid. Given the application of stringent ex ante rules for dominant players, we consider that the existence of a general interest and a market failure are necessary and sufficient conditions for granting state aid.

ETNO thinks the framework requires some important adjustments. Focusing on smaller players may lead to the exclusion of whole sectors of the European economy. In particular ICT major actors could a priori not be allowed to benefit from state aid. Given the application of stringent ex ante rules for dominant players, we consider that the existence of a general interest and a market failure are necessary and sufficient conditions for granting state aid.


ETNO generally welcomes the proposed framework but thinks it requires some important adjustments to create legal certainty and be compatible with the Action Plan objectives. Focusing on smaller players may lead to the consequence that whole sectors of the European economy, in particular the most strategic ones such as ICT, could a priori not be allowed to benefit from state aid. The proposal oversees the safeguard that dominant market leaders are subject to stringent ex ante rules, preventing them from enforcing their dominance. The Commission should use the tool of state aid to maximise the specific activity of RD&I and prefer other ex post competition law tools to correct eventual anti-competitive behaviour.  Given the application of stringent ex ante rules, we consider that the existence of a general interest and a market failure are necessary and sufficient conditions for granting state aid.