Rules

Four rulebooks cap the cost of components from outside a European set. Each counts a different set of countries. Rules checked 12 October 2026.

SAFE, Article 16(10)

Under Council Regulation (EU) 2025/1106 (SAFE), Article 16(10)10. The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product. For the purpose of procurements supported by the SAFE instrument, no component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States.Official text, as of 12 October 2026. ELI, components originating outside the Union, EEA EFTA States and Ukraine may cost at most 35 % of the estimated cost of the components of the end product.

Not yet expert reviewed.

The 35 % rule

The cap is on component cost, not on contract value. European here means the 27 Member States, Norway, Iceland, Liechtenstein and Ukraine; Switzerland, the United Kingdom and Canada are third countries. The second sentence bans components from a third country that contravenes the security and defence interests of the Union and its Member States; the act names no such country.

10. The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product. For the purpose of procurements supported by the SAFE instrument, no component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(10). Official text, as of 12 October 2026.

How it changed from the 2025 proposal

The Commission proposed a floor instead: European components at no less than 65 % of the estimated cost of the end product. The adopted text caps the other side and divides by component cost only. Commentaries that still speak of 65 % European content quote the proposal.

8. The cost of components originating in the Union, in EEA EFTA States or Ukraine shall not be lower than 65 % of the estimated cost of the end product. No component shall be sourced from another third country that contravenes the security and defence interests of the Union or its Member States.

Commission proposal COM(2025) 122 final, Article 16(8). Official text, as of 12 October 2026.

Establishment and control, Article 16(3)

Contractors and subcontractors involved in the common procurement must be established, and have their executive management structures, in the Union, an EEA EFTA State or Ukraine, and must not be controlled from outside.

3. Contractors and subcontractors involved in the common procurement shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine. They shall not be subject to control by a third country which is not an EEA EFTA State or Ukraine or by another third-country entity which is not established in the Union, in an EEA EFTA State or in Ukraine.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(3). Official text, as of 12 October 2026.

Screening or guarantees, Article 16(5) to 16(7)

An entity established in the Union but controlled from another third country may still take part if it went through investment screening under Regulation (EU) 2019/452, with mitigation where needed, or gives guarantees its Member State verifies. The contracting authority notifies the Commission.

5. By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established. The guarantees shall provide assurances that the involvement of the contractor or subcontractor in the common procurement does not contravene the security and defence interests of the Union and its Member States as established in the framework of the common foreign and security policy pursuant to Title V of the Treaty on European Union.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(5). Official text, as of 12 October 2026.

Subcontractors between 15 % and 35 %, Article 16(4)

A subcontractor outside the set may hold 15 % to 35 % of the contract value if it had a direct contract with the contractor before 29 May 2025, or if the contractor commits to study replacing its input within two years. Article 16(12) defines which subcontractors count.

4. By way of derogation from paragraph 3, in order to take into account industrial cooperation with non-EU partners, common procurements that involve a subcontractor which is allocated between 15 % and 35 % of the value of the contract, and that is not established or doesn’t have its executive management structures in the Union, EEA EFTA State or Ukraine, shall be eligible for support under the SAFE instrument providing that at least one of the following conditions are met: (a) a direct contractual relationship related to the defence product has been established between the contractor and that subcontractor prior to the date of entry into force of this Regulation; (b) the contractor commits to studying, within two years, the feasibility of replacing the input provided by that subcontractor with an alternative, restriction-free input originating in the Union, EEA EFTA States or Ukraine, and meeting technical and time requirements.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(4). Official text, as of 12 October 2026.

Design authority, Article 16(11), and drones

This applies to category two products only: air and missile defence, maritime capabilities, drones of NATO class 2 and 3 with their anti-drone systems, strategic enablers, space, artificial intelligence and electronic warfare. Small drones are category one.

SAFE places small drones (NATO class 1) and their anti-drone systems in category one, and larger drones (NATO class 2 and 3) and theirs in category two. Council Regulation (EU) 2025/1106 (SAFE), Article 1, second paragraph(a) category one: ammunition and missiles; artillery systems, including deep precision strike capabilities; ground combat capabilities and their support systems, including soldier equipment and infantry weapons; small drones (NATO class 1) and related anti-drone systems; critical infrastructure protection; cyber; and military mobility including counter-mobility; (b) category two: air and missile defence systems; maritime surface and underwater capabilities; drones other than small drones (NATO class 2 and 3) and related anti-drone systems; strategic enablers such as, but not limited to, strategic airlift, air-to-air refuelling, C4ISTAR systems as well as space assets and services; space assets protection; artificial intelligence and electronic warfare.Official text, as of 12 October 2026. ELI

11. For defence products related to category two as referred to in Article 1, second subparagraph, point (b), contractors shall have the ability to decide, without restrictions imposed by third countries or by third-country entities, on the definition, adaptation and evolution of the design of the defence product procured, including the legal authority to substitute or remove components that are subject to restrictions imposed by third countries or by third-country entities.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(11). Official text, as of 12 October 2026.

Single-country procurement deadline

Procurement by one Member State alone is supported only where the contract was signed no later than 30 May 2026. Common procurement by several countries continues.

3. By derogation from paragraph 1 of this Article, procurements carried out by one Member State shall be eligible for support under the SAFE instrument where a procurement contract was signed no later than 30 May 2026. Where a Member State includes such a procurement in the plan referred to in Article 7(2), it shall actively take all necessary steps to extend the benefit of the contract concerned to at least one additional Member State, one EEA EFTA State, or Ukraine, in addition to any interested acceding country, candidate country, potential candidate, or other third country with which the Union has entered a Security and Defence Partnership. Eligibility conditions established in Article 16(2) to (14) shall apply mutatis mutandis.

Council Regulation (EU) 2025/1106 (SAFE), Article 4(3). Official text, as of 12 October 2026.

The pending annulment action

The European Parliament has asked the Court of Justice to annul SAFE for its legal basis (Case C-560/25, brought on 20 August 2025) and to maintain its effects meanwhile. The case is open.

What each Member State asks as evidence

Each Member State agrees the documentary evidence with the Commission in operational arrangements under Council Regulation (EU) 2025/1106 (SAFE), Article 10(3)3. The operational arrangements shall set out the relationship between the implementation of a plan and the corresponding financial assistance, including a tentative schedule of disbursement of the loan instalments, with yearly ceilings as appropriate. In addition, these operational arrangements shall set out types of documentary evidence and control rules related to the fulfilment of the specific eligibility rules applied by the Member States in accordance with Article 16, and the detailed elements referred to in Article 14.Official text, as of 12 October 2026. ELI. They are not public. The evidence pack has a country annex for what a buyer asks.

3. The operational arrangements shall set out the relationship between the implementation of a plan and the corresponding financial assistance, including a tentative schedule of disbursement of the loan instalments, with yearly ceilings as appropriate. In addition, these operational arrangements shall set out types of documentary evidence and control rules related to the fulfilment of the specific eligibility rules applied by the Member States in accordance with Article 16, and the detailed elements referred to in Article 14.

Council Regulation (EU) 2025/1106 (SAFE), Article 10(3). Official text, as of 12 October 2026.

EDIP, Articles 10(3) and 10(4)

For procurement under Articles 11, 13 and 35, components from outside the Union and associated countries may cost at most 35 % of the estimated cost of the components of the end product.

Not yet expert reviewed.

Procurement, Article 10(3)

Ukraine is outside the European set here. Norway, Iceland and Liechtenstein become associated countries once an EEA decision is in force; until then a result that rests on them needs review. The German text says Bestandteile here, where SAFE says Komponenten.

3. For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product. No component shall be sourced from third countries that contravene the security and defence interests of the Union and its Member States.

Regulation (EU) 2025/2643 (EDIP), Article 10(3). Official text, as of 12 October 2026.

Production capacity, Article 10(4)

For industrial reinforcement under Article 12, and for activities under Article 35 other than procurement, the cap is the same but the base is the product whose production capacity the Union funds, which can itself be a part such as a motor.

4. For actions carried out pursuant to Article 12 and activities carried out pursuant to Article 35 other than procurement activities, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the product the increase in production capacity of which is supported by Union funding. No component of the product the increase in production capacity of which is supported by Union funding shall be sourced from third countries that contravene the security and defence interests of the Union and its Member States.

Regulation (EU) 2025/2643 (EDIP), Article 10(4). Official text, as of 12 October 2026.

Countries that contravene EU security interests

Each paragraph adds its own sentence: no component may come from third countries that contravene the security and defence interests of the Union and its Member States. The act lists no country; the applicant assesses.

Design authority, Articles 10(5) and 12(4)

Recipients must be free to change the design and to replace restricted components, in every action. Only for ammunition and missiles may a binding commitment to gain that freedom by 31 December 2033 take its place.

5. Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.

Regulation (EU) 2025/2643 (EDIP), Article 10(5). Official text, as of 12 October 2026.

4. For the production of ammunition and missiles, recipients of Union funding or relevant governmental authorities of the Member States concerned shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence product concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities, or alternatively, by way of derogation from Article 10(5), shall have obtained a legally binding commitment from the non-associated third country or the non-associated third-country entity concerned that they will obtain such ability to decide within a reasonable timeframe commensurate with the complexity of the action concerned, and in any event no later than 31 December 2033.

Regulation (EU) 2025/2643 (EDIP), Article 12(4). Official text, as of 12 October 2026.

The call documents

Every EDIP call published so far allows two calculation methods, and meeting either is enough for the whole action. Method (a) counts procured tier-1 components; method (b) adds the manufacturing cost of sub-systems built in house. The base follows the action type. Ukraine Support Instrument calls count the EU and Ukraine.

Call (read on 7 October 2026)TopicsDeadline
EDF-EDIP-USI-2026-LS-IRAmissiles, ammunition and bombs10 November 2026
EDF-EDIP-P-2027-FNLC-CPAair and missile defence; C5ISR and space; ground and naval platforms16 February 2027
EDF-EDIP-P-2027-LS-IRAkey electronic components; platforms and end products16 February 2027
EDF-EDIP-USI-2027-LS-IRAunmanned and counter-unmanned systems16 February 2027

The component origin eligibility criterion will be considered met if either of the following two calculation methods are complied with: a) if the costs of tier 1 procured components originating outside the EU or EDIP associated countries divided by the estimated costs of all tier 1 procured components of the product whose production capacity is being increased, independently of their origin remains below or equal to 35% (i.e. only counting procured components) OR b) if the costs of tier-1 procured components originating outside the EU or EDIP associated countries divided by the cost of components of the defence product remains below or equal to 35% (i.e. also counting total manufacturing costs (TMC) at the level of subsystems built in-house together with the cost of the tier-1 procured components ready to be integrated directly in the product whose production capacity is being increased until (but excluding) the last manufacturing process ahead of the packaging and quality control) The condition must be complied with during the entire duration of the action.

EDIP call document EDF-EDIP-P-2026-LS-IRA, Version 1.2, component origin, page 10. Official text, as of 12 October 2026.

Who may receive funding, Article 9

Recipients must be established, and managed, in the Union or an associated country, and not controlled from a non-associated third country, unless guarantees accepted under national procedures reach the Commission.

1. Only legal entities established in the Union or in an associated country and having their executive management structures in the Union or in an associated country shall be eligible to be recipients of Union funding under this Regulation.

Regulation (EU) 2025/2643 (EDIP), Article 9(1). Official text, as of 12 October 2026.

6. By way of derogation from paragraph 5 of this Article, a legal entity established in the Union or in an associated country and controlled by a non-associated third country or by a non-associated third-country entity shall be eligible to be a recipient of Union funding if guarantees approved in accordance with the national procedures of a Member State or associated country in which it is established, such as adequate measures pursuant to screening, as defined in Article 2, point (3), of Regulation (EU) 2019/452 of the European Parliament and of the Council (39), are made available to the Commission.

Regulation (EU) 2025/2643 (EDIP), Article 9(6). Official text, as of 12 October 2026.

Budget

EUR 1.2 billion for the Programme and EUR 0.3 billion for the Ukraine Support Instrument, in current prices, from 30 December 2025 to 31 December 2027, plus any additional contributions (Article 3(1) and (2)).

EU-Canada agreement, Article 5(8)

The agreement counts Canadian components in their own group, neither European nor third-country, and sets three tests on one cost base: European components at least 20 %, third-country components not above the European ones, and third-country components at most 35 %.

Not yet expert reviewed.

The three tests

On the site, a Canada result shows one state: the weakest of the three tests. The three tests and their figures sit under "Why".

8. The cost of components originating in Canada may exceed 35 % of the estimated cost of the components of the end product. The cost of components originating either in the Union, an EEA EFTA State or Ukraine must not be lower than 20 % of the estimated cost of the components of the end product. The cost of the components from third countries must not exceed the cost of components originating in the Union, an EEA EFTA State, or Ukraine, and in any case may not exceed 35 % of the cost of the components of the end product.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8). Official text, as of 12 October 2026.

Establishment, management and control

Canadian entities must be established in Canada, with management in Canada, the Union, an EEA EFTA State or Ukraine, and not controlled from a third country. A controlled entity takes part only with a guarantee on the Commission template, checked by a participating Member State. There is no screening route.

2. Canadian legal entities must be established in Canada and have their executive management structures in Canada, in the Union, in an EEA EFTA State, or in Ukraine. They must not be subject to control by a third country or by an entity which is established in a third country, or which is established in the Union, in an EEA EFTA State, in Ukraine or in Canada and has its executive management structures in a third country.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(2). Official text, as of 12 October 2026.

3. By way of derogation from paragraph 2 of this Article, a Canadian legal entity controlled by a third country or by an entity which is established in a third country, or which is established in the Union, in an EEA EFTA State, in Ukraine, or in Canada and has its executive management structures in a third country may participate in a procurement supported by the SAFE Instrument if it provides a guarantee to be verified by at least one Member State participating in that procurement. The guarantee must provide assurances that the involvement of the contractor or subcontractor in that procurement does not contravene the security and defence interests of the Union and its Member States as established in the framework of the common foreign and security policy pursuant to Title V of the Treaty on European Union.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(3). Official text, as of 12 October 2026.

Canada's contribution

Canada, not the companies, pays 15 % of the value of Canadian content, and nothing for contracts where more than 65 % of content value is European. Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Annex, Article 2(3)3. From 2027, the annual Canadian participation contribution shall be determined by the Union as follows: (a) for contracts where more than 65 % of the total value of the content originates either in the Union, an EEA EFTA State or Ukraine, the participation contribution is zero; (b) for contracts where 65 % or less of the total value of the content originates either in the Union, an EEA EFTA State or Ukraine, the participation contribution is equal to 15 % of the sum of the total value of: (i) contracts supported by the SAFE Instrument awarded to Canadian legal entities minus the value subcontracted to non-Canadian legal entities; and (ii) contracts subcontracted to Canadian legal entities in contracts awarded to non-Canadian entities; (c) the Union shall deduct from the amount determined under paragraph 3, points (a) and (b), of this Article any remaining value of the initial instalment referred to in paragraph 5, point (a), of Article 6 of this Agreement: (i) if the result of this calculation is a negative number, the equivalent positive amount shall be the yearly participation contribution to be paid; or (ii) if the result of this calculation is a positive number, this amount constitutes the remaining value of the initial instalment for the next annual review, and the participation contribution for that year is zero.Official text, as of 12 October 2026. ELI

4. The participation contribution referred to in paragraph 2, point (b), is 15 % of the value of Canadian content in contracts that are based on the conditions set out in this Agreement.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 6(4). Official text, as of 12 October 2026.

3. From 2027, the annual Canadian participation contribution shall be determined by the Union as follows: (a) for contracts where more than 65 % of the total value of the content originates either in the Union, an EEA EFTA State or Ukraine, the participation contribution is zero; (b) for contracts where 65 % or less of the total value of the content originates either in the Union, an EEA EFTA State or Ukraine, the participation contribution is equal to 15 % of the sum of the total value of: (i) contracts supported by the SAFE Instrument awarded to Canadian legal entities minus the value subcontracted to non-Canadian legal entities; and (ii) contracts subcontracted to Canadian legal entities in contracts awarded to non-Canadian entities; (c) the Union shall deduct from the amount determined under paragraph 3, points (a) and (b), of this Article any remaining value of the initial instalment referred to in paragraph 5, point (a), of Article 6 of this Agreement: (i) if the result of this calculation is a negative number, the equivalent positive amount shall be the yearly participation contribution to be paid; or (ii) if the result of this calculation is a positive number, this amount constitutes the remaining value of the initial instalment for the next annual review, and the participation contribution for that year is zero.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Annex, Article 2(3). Official text, as of 12 October 2026.

Subcontractors

The control rules reach a subcontractor only when it provides critical inputs, holds at least 15 % of the contract value and needs access to classified information.

(h) ‘subcontractors involved in a procurement supported by the SAFE Instrument’ means any legal entity which provides critical inputs that possess unique attributes essential for the functioning of a product, which is allocated at least 15 % of the value of the contract, and which needs access to classified information for the performance of the contract.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 2(h). Official text, as of 12 October 2026.

When the agreement applies instead of SAFE Article 16(10)

Lodemark's reading (interpretation A2-28): you state whether the contract is based on the agreement. If you do not, and a Canadian component exists, both results are shown, because under SAFE Article 16(10) alone Canadian components are third-country.

Dates

Signed on 14 February 2026, applied provisionally from 13 April 2026, in force since 1 August 2026.

Ukraine Support Loan, Article 13(4)(g)

Components from outside the Union, EEA EFTA States and Ukraine may cost at most 35 % of the estimated cost of the components of the defence product, unless a derogation sets the rule aside.

Not yet expert reviewed.

The loan

Up to EUR 90 billion for Ukraine, available until 31 December 2027, under Regulation (EU) 2026/467.

1. The Ukraine Support Loan shall be for a maximum amount of EUR 90 000 000 000. That amount shall be made available to Ukraine in accordance with Ukraine’s financing needs, as provided for in the Ukrainian Financing Strategy approved in accordance with Article 8. 2. The Ukraine Support Loan shall be available until 31 December 2027. It shall be made available by the Commission in instalments, which may be disbursed to Ukraine in one or more tranches. The disbursement of all such tranches shall take place by 31 December 2028.

Regulation (EU) 2026/467 (Ukraine Support Loan), Article 4(1) and (2). Official text, as of 12 October 2026.

The 35 % rule, Article 13(4)(g)

The arithmetic matches SAFE Article 16(10), but the base is the defence product, the noun this act uses. Its French security sentence reads differently from the SAFE one.

(g) the cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the defence product. No component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States;

Regulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(g). Official text, as of 12 October 2026.

Makers and subcontractors, Article 13(4)(a) to (e)

Manufacturers and subcontractors must be established and managed in the Union, an EEA EFTA State or Ukraine and not controlled from elsewhere, with a screening or guarantee route; screening is open only to entities established in the Union, as under SAFE. A subcontractor's direct contract must date from before 28 May 2025 (under SAFE, before 29 May 2025), so a contract signed on 28 May 2025 is in time under SAFE and too late under the loan.

(a) manufacturers and subcontractors involved in the production of the defence products shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine. They shall not be subject to control by a third country which is not an EEA EFTA State or Ukraine or by another third-country entity which is not established in the Union, in an EEA EFTA State or in Ukraine;

Regulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(a). Official text, as of 12 October 2026.

Derogations, Article 13(5)

Two grounds: no equivalent product meeting the conditions, or a much shorter delivery time. Each derogation is a Commission implementing decision on one of Ukraine's product schedules. Seven so far, two of them for small drones.

DecisionDateProducts namedGroundSet aside
(EU) 2026/8151 April 2026not named(a)component cost
(EU) 2026/179316 July 2026not named(a)component cost
(EU) 2026/206711 September 2026missiles and ammunition; air and missile defence(a) and (b)makers, sites and components
(EU) 2026/207111 September 2026small drones(a)component cost
(EU) 2026/207311 September 2026small drones(a)component cost
(EU) 2026/208111 September 2026electronic warfare(b)component cost
(EU) 2026/208211 September 2026air defence missiles(a)makers, sites and components

5. By way of derogation from paragraphs 2 and 4 and in full respect of paragraph 3, where there is an urgent need for the delivery of a given defence product stemming from Russia’s war of aggression against Ukraine, the procurement of a defence product which does not comply with one or more of the conditions set out in paragraphs 2 and 4 shall be eligible for financial assistance under this Chapter provided that: (a) there is no equivalent product that responds to that urgent need which complies with the conditions set out in paragraphs 2 and 4 or it is not available at the required scale and whose delivery lead time is commensurate with the urgency of the situation and Ukraine’s immediate operational needs; or (b) the delivery lead time for such defence product is significantly shorter than for a defence product which would comply with the conditions set out in paragraphs 2 and 4 of this Article, even if that defence product was subject to a priority-rated request as referred to in Article 19. In such a case, Ukraine shall provide the information reasonably available to it demonstrating that the conditions for the application of this derogation are met. That information shall be checked by the Commission after consultation with the Expert Group referred to in Article 15 without undue delay. The procurement of defence products from manufacturers established in third countries other than EEA EFTA States and Ukraine shall be made only where there are no other alternatives available in the Union, EEA EFTA States and Ukraine under the conditions set out in the first subparagraph, points (a) and (b). In the context of the first subparagraph, points (a) and (b), that information shall include a legal commitment on compliance with the delivery lead time. The Commission shall approve the derogations referred to in this paragraph by means of implementing acts, acting in accordance with the examination procedure referred to in Article 27(3).

Regulation (EU) 2026/467 (Ukraine Support Loan), Article 13(5). Official text, as of 12 October 2026.

What Lodemark cannot see

The product schedules are classified. Lodemark can say that a derogation exists for a schedule, never that it covers your product: ask the buyer.

The method

Origin is the customs origin of each component you buy (tier 1), not your suppliers’ parts. In a pilot, AI reads the documents and proposes values, by default a person checks each one, and the rules engine computes. Every line gets a grade for the evidence behind it.

Not yet expert reviewed.

How strong the evidence is

GradeWhat stands behind the origin
AAn official document, such as a customs declaration
BA supplier declaration with a supporting document
CA statement only
DUnknown: no origin basis, or two documents that disagree

The six result states

We never say eligible: only the contracting authority or funding body decides that. Each rule gets one state.

StateWhen
Meets the threshold on the data enteredat or below the limit even with every unknown counted outside, and every condition answered in a way the rulebook accepts
Above the threshold on the data enteredabove the limit even with every unknown counted inside
Below the minimum on the data enteredEU-Canada agreement: under the 20 % minimum even with every unknown counted inside
A condition is not met on the data entereda condition answered No, or one of your tender conditions broken
Needs reviewthe answer depends on missing data, an unanswered condition or an open question
Not assessednothing to compute

A missing origin never helps you

A component of unknown origin counts as outside the European set when testing Meets, and as inside when testing Above. Between the two, the state is Needs review, with the reason shown. If a part comes from more than one source, the least favourable one counts.

The cost base of each rule

Each rule divides the cost of components from outside its European set by its own cost base. Only procured components count. Raw materials, services and final assembly stay out.

What is left out of the share

Raw materials, services, tooling, freight and final assembly. Leaving them out can only raise the share, except for imported raw materials, so the pack also prints the share with raw materials counted. Under SAFE, the Ukraine loan and the Canada agreement, a difference turns Meets into Needs review.

A worked example

A small fictional drone shows the arithmetic under SAFE. One radio has no known origin, so the share is a range: the state is Above only because even the low end exceeds 35 %.

Fictional drone, cost per drone in EUR, estimated
ComponentOriginCostSAFE European set
FrameFinland120.00Inside
Flight controllerGermany90.00Inside
Motor (4 x 35)China140.00Outside
Battery packPoland160.00Inside
CameraChina110.00Outside
RadioUnknown60.00Unknown
Propeller (4 x 5)China20.00Outside
Cable setCzechia20.00Inside
Carbon plate raw stockChina40.00Left out: raw material
Cost base (components only)720.00
Outside the European set270.00
Unknown origin60.00
Share with unknown counted inside37.5 %
Share with unknown counted outside45.8 %
SAFE Article 16(10)Above the threshold on the data entered

Dated, versioned rulebooks

Each rulebook is a dated configuration taken from the Official Journal. Every result carries its version and the date its texts were current, and every rule stays marked as not yet expert reviewed until a named reviewer signs.

Each rule text is copied from the Official Journal, fingerprinted with SHA-256 and dated. The texts are rechecked every month and whenever an act or call changes. No rule has had an outside legal review yet.

What Lodemark does not decide

Eligibility, control and design authority. For those, Lodemark asks questions with the article next to each and lists your answers as statements you sign.

Control and ownership

Every rulebook bars control from outside its own set, and each offers a different way back in. Lodemark records the answers and the documents behind them. It does not decide control.

Not yet expert reviewed.

Who must not be controlled, and the way back in

RulebookWho must not be controlledFrom whereThe way back in
SAFEcontractors and subcontractors involved in the procurementoutside the Union, EEA EFTA States and Ukrainescreening or verified guarantees, for entities established in the Union
EDIPrecipients of Union fundinga non-associated third countryguarantees under national procedures
EU-CanadaCanadian legal entitiesa third countrya guarantee on the Commission template
Ukraine Support Loanmanufacturers and subcontractorsoutside the Union, EEA EFTA States and Ukrainescreening or guarantees, for entities established in the Union

What control means

EDIP defines control as the ability to exercise decisive influence over a legal entity, directly or through intermediate entities. Regulation (EU) 2025/2643 (EDIP), Article 2(8)‘control’ means the ability to exercise decisive influence over a legal entity directly, or indirectly through one or more intermediate legal entities;Official text, as of 12 October 2026. ELI

SAFE has no definition; recital (16) uses the same words, and a recital does not bind. Council Regulation (EU) 2025/1106 (SAFE), recital (16)In that context, control should be understood as the ability to exercise a decisive influence over a legal entity, directly or indirectly, through one or more intermediate legal entities.Official text, as of 12 October 2026. ELI

The evidence that answers it

Trade register extracts, beneficial ownership and group structure charts, shareholder agreements, investment screening decisions and verified guarantees.

Official terms

Terms from the official language versions of the acts, never our translation. S: SAFE, E: EDIP, U: Ukraine loan, C: EU-Canada agreement.

Not yet expert reviewed.

The terms in English, French and German

ConceptEnglishFrançaisDeutschWhere
componentcomponent(s)composant(s)SAFE: Komponente(n). EDIP: Bestandteil(e)Council Regulation (EU) 2025/1106 (SAFE), Article 16(10)The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026., Council Regulation (EU) 2025/1106 (SAFE), Article 16(11)For defence products related to category two as referred to in Article 1, second subparagraph, point (b), contractors shall have the ability to decide, without restrictions imposed by third countries or by third-country entities, on the definition, adaptation and evolution of the design of the defence product procured, including the legal authority to substitute or remove components that are subject to restrictions imposed by third countries or by third-country entities.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(4)For actions carried out pursuant to Article 12 and activities carried out pursuant to Article 35 other than procurement activities, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the product the increase in production capacity of which is supported by Union funding.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(5)Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.Official text, as of 12 October 2026.
end productend productproduit finalEndproduktCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(10)The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.
cost of componentscost of componentscoût des composantsS: Kosten der Komponenten. E: Kosten für Bestandteile (10(3)), Kosten von Bestandteilen (10(4))Council Regulation (EU) 2025/1106 (SAFE), Article 16(10)The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(4)For actions carried out pursuant to Article 12 and activities carried out pursuant to Article 35 other than procurement activities, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the product the increase in production capacity of which is supported by Union funding.Official text, as of 12 October 2026.
estimated costestimated costcoût estimégeschätzte KostenCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(10)The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(4)For actions carried out pursuant to Article 12 and activities carried out pursuant to Article 35 other than procurement activities, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the product the increase in production capacity of which is supported by Union funding.Official text, as of 12 October 2026.
not higher than 35 %shall not be higher than 35 %S: n'est pas supérieur à 35 %. E: ne dépasse pas 35 %S: dürfen 35 % ... nicht übersteigen. E: dürfen ... nicht höher als 35 % ... seinCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(10)The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(4)For actions carried out pursuant to Article 12 and activities carried out pursuant to Article 35 other than procurement activities, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the product the increase in production capacity of which is supported by Union funding.Official text, as of 12 October 2026.
originating outsideoriginating outsidedont l'origine est extérieure àmit Ursprung außerhalbCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(10)The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(4)For actions carried out pursuant to Article 12 and activities carried out pursuant to Article 35 other than procurement activities, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the product the increase in production capacity of which is supported by Union funding.Official text, as of 12 October 2026.
originating inoriginating inoriginaire(s) demit Ursprung inCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(4)(b) the contractor commits to studying, within two years, the feasibility of replacing the input provided by that subcontractor with an alternative, restriction-free input originating in the Union, EEA EFTA States or Ukraine, and meeting technical and time requirements.Official text, as of 12 October 2026., 17(2)(c)
third countrythird countrypays tiersDrittlandCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(3)They shall not be subject to control by a third country which is not an EEA EFTA State or Ukraine or by another third-country entity which is not established in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026., Council Regulation (EU) 2025/1106 (SAFE), Article 16(10)For the purpose of procurements supported by the SAFE instrument, no component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States.Official text, as of 12 October 2026.
other third countryanother third countryun autre pays tiersein sonstiges DrittlandCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026.
third-country entitythird-country entityentité de pays tiersRechtsträger eines DrittlandsCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(3)They shall not be subject to control by a third country which is not an EEA EFTA State or Ukraine or by another third-country entity which is not established in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026., 16(6)(b), Council Regulation (EU) 2025/1106 (SAFE), Article 16(11)11. For defence products related to category two as referred to in Article 1, second subparagraph, point (b), contractors shall have the ability to decide, without restrictions imposed by third countries or by third-country entities, on the definition, adaptation and evolution of the design of the defence product procured, including the legal authority to substitute or remove components that are subject to restrictions imposed by third countries or by third-country entities.Official text, as of 12 October 2026.
non-associated third-country entitynon-associated third-country entityentité de pays tiers non associéRechtsträger eines nicht assoziierten DrittlandsE 2(20), Regulation (EU) 2025/2643 (EDIP), Article 10(5)5. Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.Official text, as of 12 October 2026.
associated countriesassociated countriespays associésassoziierte LänderRegulation (EU) 2025/2643 (EDIP), Article 2(3)‘associated countries’ means members of the European Free Trade Association which are members of the European Economic Area that apply this Regulation in accordance with the Agreement on the European Economic Area;Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(3)For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.
EEA EFTA StatesEEA EFTA StatesÉtats de l'AELE membres de l'EEEdem EWR angehörende EFTA-StaatenS 2(3), Council Regulation (EU) 2025/1106 (SAFE), Article 16(3)3. Contractors and subcontractors involved in the common procurement shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine. They shall not be subject to control by a third country which is not an EEA EFTA State or Ukraine or by another third-country entity which is not established in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026.
controlcontrolcontrôleKontrolleCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(3)They shall not be subject to control by a third country which is not an EEA EFTA State or Ukraine or by another third-country entity which is not established in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026., 16(6)(a); Regulation (EU) 2025/2643 (EDIP), Article 2(8)‘control’ means the ability to exercise decisive influence over a legal entity directly, or indirectly through one or more intermediate legal entities;Official text, as of 12 October 2026.
controlled bycontrolled bycontrôlée parkontrolliert (von)Council Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026.
establishedestablishedétabli(s)S 16(3): "ihren Sitz ... haben" and "niedergelassen"; S 16(5): niedergelassenCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(3)Contractors and subcontractors involved in the common procurement shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026., Council Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026.
executive management structuresexecutive management structuresstructures exécutives de gestionLeitungs- und VerwaltungsstrukturenCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(3)Contractors and subcontractors involved in the common procurement shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026.; E 2(13)
design authority (concept; not a defined term)ability to decide ... on the definition, adaptation and evolution of the designcapacité de décider ... de la définition, de l'adaptation et de l'évolution de la conceptionS: über die Definition, Anpassung und Entwicklung der Konstruktion ... entscheiden. E 10(5): Festlegung, Anpassung und Entwicklung der Gestaltung. E 12(4): Definition, Anpassung und Entwicklung der GestaltungCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(11)11. For defence products related to category two as referred to in Article 1, second subparagraph, point (b), contractors shall have the ability to decide, without restrictions imposed by third countries or by third-country entities, on the definition, adaptation and evolution of the design of the defence product procured, including the legal authority to substitute or remove components that are subject to restrictions imposed by third countries or by third-country entities.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(5)5. Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 12(4)4. For the production of ammunition and missiles, recipients of Union funding or relevant governmental authorities of the Member States concerned shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence product concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities, or alternatively, by way of derogation from Article 10(5), shall have obtained a legally binding commitment from the non-associated third country or the non-associated third-country entity concerned that they will obtain such ability to decide within a reasonable timeframe commensurate with the complexity of the action concerned, and in any event no later than 31 December 2033.Official text, as of 12 October 2026.
legally binding commitmentlegally binding commitmentengagement juridiquement contraignantrechtsverbindliche ZusageRegulation (EU) 2025/2643 (EDIP), Article 12(4)For the production of ammunition and missiles, recipients of Union funding or relevant governmental authorities of the Member States concerned shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence product concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities, or alternatively, by way of derogation from Article 10(5), shall have obtained a legally binding commitment from the non-associated third country or the non-associated third-country entity concerned that they will obtain such ability to decide within a reasonable timeframe commensurate with the complexity of the action concerned, and in any event no later than 31 December 2033.Official text, as of 12 October 2026.
security of supplysecurity of supplysécurité d'approvisionnementSicherheit der VersorgungS 17(3)(c)
security and defence interestssecurity and defence interests of the Union and its Member Statesintérêts de l'Union et de ses États membres en matière de sécurité et de défenseSicherheits- und Verteidigungsinteressen der Union und ihrer MitgliedstaatenCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(5)The guarantees shall provide assurances that the involvement of the contractor or subcontractor in the common procurement does not contravene the security and defence interests of the Union and its Member States as established in the framework of the common foreign and security policy pursuant to Title V of the Treaty on European Union.Official text, as of 12 October 2026., Council Regulation (EU) 2025/1106 (SAFE), Article 16(10)For the purpose of procurements supported by the SAFE instrument, no component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States.Official text, as of 12 October 2026.; Regulation (EU) 2025/2643 (EDIP), Article 10(3)No component shall be sourced from third countries that contravene the security and defence interests of the Union and its Member States.Official text, as of 12 October 2026., Regulation (EU) 2025/2643 (EDIP), Article 10(4)No component of the product the increase in production capacity of which is supported by Union funding shall be sourced from third countries that contravene the security and defence interests of the Union and its Member States.Official text, as of 12 October 2026.
contractorcontractorcontractantAuftragnehmerS 16(2)-(11); Regulation (EU) 2025/2643 (EDIP), Article 10(5)Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.Official text, as of 12 October 2026.
subcontractorsubcontractorsous-traitantUnterauftragnehmerCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(2)Common procurement procedures and contracts of defence products shall include the participation requirements for contractors and subcontractors involved in the common procurement set out in paragraphs 3 to 13 and 15 of this Article, without prejudice to any conditions set out in the agreements referred to in Article 17.Official text, as of 12 October 2026., Council Regulation (EU) 2025/1106 (SAFE), Article 16(12)For the purposes of this Article, ‘subcontractors involved in the common procurement’ means any legal entity which provides critical inputs that possess unique attributes essential for the functioning of a product, which is allocated at least 15 % of the value of the contract, and which needs access to classified information for the performance of the contract.Official text, as of 12 October 2026.; E 2(31), 11(7)
suppliersupplierfournisseurLieferantE 2(31)
critical inputscritical inputsintrants critiqueswichtiges Vorprodukt ("critical input")Council Regulation (EU) 2025/1106 (SAFE), Article 16(12)For the purposes of this Article, ‘subcontractors involved in the common procurement’ means any legal entity which provides critical inputs that possess unique attributes essential for the functioning of a product, which is allocated at least 15 % of the value of the contract, and which needs access to classified information for the performance of the contract.Official text, as of 12 October 2026.
derogationby way of derogation frompar dérogation àabweichend von / in Abweichung vonCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(4)By way of derogation from paragraph 3, in order to take into account industrial cooperation with non-EU partners, common procurements that involve a subcontractor which is allocated between 15 % and 35 % of the value of the contract, and that is not established or doesn’t have its executive management structures in the Union, EEA EFTA State or Ukraine, shall be eligible for support under the SAFE instrument providing that at least one of the following conditions are met:Official text, as of 12 October 2026., Council Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026.; E 11(7), Regulation (EU) 2025/2643 (EDIP), Article 12(4)For the production of ammunition and missiles, recipients of Union funding or relevant governmental authorities of the Member States concerned shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence product concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities, or alternatively, by way of derogation from Article 10(5), shall have obtained a legally binding commitment from the non-associated third country or the non-associated third-country entity concerned that they will obtain such ability to decide within a reasonable timeframe commensurate with the complexity of the action concerned, and in any event no later than 31 December 2033.Official text, as of 12 October 2026.
guaranteesguaranteesgarantiesGarantienCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026., 16(6)
screeningscreeningfiltrageÜberprüfungCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026.
mitigation measuresmitigation measuresmesures d'atténuationRisikominderungsmaßnahmenCouncil Regulation (EU) 2025/1106 (SAFE), Article 16(5)By way of derogation from paragraph 3, a legal entity established in the Union and controlled by another third country or by another third-country entity may participate in the common procurement if it has been subject to screening within the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate mitigation measures, or if it provides guarantees verified by the Member State in which the contractor or subcontractor involved in the common procurement is established.Official text, as of 12 October 2026., 16(7)
standardised templatestandardised templatemodèle normaliséstandardisierte VorlageS 16(6)
tender specificationstender specificationscahier des chargesLeistungsbeschreibungS 16(6)
contracting authoritycontracting authoritypouvoir adjudicateuröffentlicher AuftraggeberS 16(7)
infrastructure, facilities, assets and resourcesinfrastructure, facilities, assets and resourcesinfrastructures, installations, biens et ressourcesInfrastrukturen, Einrichtungen, Mittel und RessourcenS 16(8)
classified informationclassified informationinformations classifiéesVerschlusssachenS 16(6)(b), Council Regulation (EU) 2025/1106 (SAFE), Article 16(12)For the purposes of this Article, ‘subcontractors involved in the common procurement’ means any legal entity which provides critical inputs that possess unique attributes essential for the functioning of a product, which is allocated at least 15 % of the value of the contract, and which needs access to classified information for the performance of the contract.Official text, as of 12 October 2026.
national security clearancenational security clearancehabilitation de sécurité nationaleSicherheitsüberprüfungsbescheinigungS 16(6)(b)
eligibility conditionseligibility conditionsconditions d'éligibilitéFörderfähigkeitsbedingungenS 16(1)
eligible actionseligible actionsactions éligiblesförderfähige MaßnahmenE Art 10 title
common procurementcommon procurementacquisition conjointegemeinsame BeschaffungS 2(3), 16
common procurement actionscommon procurement actionsactions d'acquisition conjointegemeinsame BeschaffungsmaßnahmenE 10(1)(a)
defence productdefence product(s)produits de défenseS: Verteidigungsgut. E: VerteidigungsgüterS 2(1); E 2(11)
other products for defence purposesother products for defence purposesautres produits destinés à des fins de défensesonstige Güter für VerteidigungszweckeS 2(2)
recipients of Union fundingrecipients of Union fundingdestinataires d'un financement de l'UnionEmpfänger von UnionsmittelnRegulation (EU) 2025/2643 (EDIP), Article 10(5)Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.Official text, as of 12 October 2026.
the loanUkraine Support Loanprêt de soutien à l’UkraineUnterstützungsdarlehen für die Ukraine (title: „des Unterstützungsdarlehens für die Ukraine“)U title
manufacturersmanufacturersfabricantsHerstellerRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(a)(a) manufacturers and subcontractors involved in the production of the defence products shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine.Official text, as of 12 October 2026.
defence product (USL)defence productproduit de défenseVerteidigungsgutRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(g)(g) the cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the defence product.Official text, as of 12 October 2026.
denominator (USL)estimated cost of the components of the defence productcoût estimé des composants du produit de défensegeschätzten Kosten der Komponenten des VerteidigungsgutsRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(g)(g) the cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the defence product.Official text, as of 12 October 2026.
subcontractor (USL)subcontractors involved in the production of the defence productssous-traitants participant à la production des produits de défensean der Herstellung der Verteidigungsgüter beteiligter UnterauftragnehmerU 13(4) second subparagraph
urgent needurgent needbesoin urgentdringender BedarfRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(5)By way of derogation from paragraphs 2 and 4 and in full respect of paragraph 3, where there is an urgent need for the delivery of a given defence product stemming from Russia’s war of aggression against Ukraine, the procurement of a defence product which does not comply with one or more of the conditions set out in paragraphs 2 and 4 shall be eligible for financial assistance under this Chapter provided that:Official text, as of 12 October 2026.
delivery lead timedelivery lead timedélai d’exécution pour la livraisonLieferfristRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(5)(a) there is no equivalent product that responds to that urgent need which complies with the conditions set out in paragraphs 2 and 4 or it is not available at the required scale and whose delivery lead time is commensurate with the urgency of the situation and Ukraine’s immediate operational needs; or (b) the delivery lead time for such defence product is significantly shorter than for a defence product which would comply with the conditions set out in paragraphs 2 and 4 of this Article, even if that defence product was subject to a priority-rated request as referred to in Article 19.Official text, as of 12 October 2026.
priority-rated requestpriority-rated requestdemande prioritaireVorranganfrageRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(5)(a) there is no equivalent product that responds to that urgent need which complies with the conditions set out in paragraphs 2 and 4 or it is not available at the required scale and whose delivery lead time is commensurate with the urgency of the situation and Ukraine’s immediate operational needs; or (b) the delivery lead time for such defence product is significantly shorter than for a defence product which would comply with the conditions set out in paragraphs 2 and 4 of this Article, even if that defence product was subject to a priority-rated request as referred to in Article 19.Official text, as of 12 October 2026.
implementing actsimplementing actsactes d’exécutionDurchführungsrechtsakteRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(5)The Commission shall approve the derogations referred to in this paragraph by means of implementing acts, acting in accordance with the examination procedure referred to in Article 27(3).Official text, as of 12 October 2026.
Expert GroupExpert Groupgroupe d’expertsSachverständigengruppeRegulation (EU) 2026/467 (Ukraine Support Loan), Article 13(5)That information shall be checked by the Commission after consultation with the Expert Group referred to in Article 15 without undue delay.Official text, as of 12 October 2026.
end product (Canada)end productproduit finalEndproduktAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8)The cost of components originating in Canada may exceed 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.
floormust not be lower than 20 %ne doit pas être inférieur à 20 %dürfen nicht unter 20 % ... betragenAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8)The cost of components originating either in the Union, an EEA EFTA State or Ukraine must not be lower than 20 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.
Canadian sharemay exceed 35 %peut dépasser 35 %dürfen 35 % ... übersteigenAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8)The cost of components originating in Canada may exceed 35 % of the estimated cost of the components of the end product.Official text, as of 12 October 2026.
third-country components (Canada)components from third countriescomposants en provenance de pays tiersKomponenten aus DrittländernAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8)The cost of the components from third countries must not exceed the cost of components originating in the Union, an EEA EFTA State, or Ukraine, and in any case may not exceed 35 % of the cost of the components of the end product.Official text, as of 12 October 2026.
in any casein any caseen tout état de causein keinem FallAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8)The cost of the components from third countries must not exceed the cost of components originating in the Union, an EEA EFTA State, or Ukraine, and in any case may not exceed 35 % of the cost of the components of the end product.Official text, as of 12 October 2026.
declaration by the contracting authorityjustified declaration of compliancedéclaration de conformité motivéebegründete KonformitätserklärungAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(9)The contracting authority conducting the procurement supported by the SAFE Instrument shall provide a justified declaration of compliance to the Member States participating in the procurement establishing that no component is sourced from a third country that contravenes these interests.Official text, as of 12 October 2026.
guarantee (Canada)guaranteegarantieGarantieAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(3)By way of derogation from paragraph 2 of this Article, a Canadian legal entity controlled by a third country or by an entity which is established in a third country, or which is established in the Union, in an EEA EFTA State, in Ukraine, or in Canada and has its executive management structures in a third country may participate in a procurement supported by the SAFE Instrument if it provides a guarantee to be verified by at least one Member State participating in that procurement.Official text, as of 12 October 2026.
financial contributionfinancial contributioncontribution financièreFinanzbeitragC 6(1)
participation contributionparticipation contributioncontribution de participationTeilnahmebeitragC 6(2)(b), Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 6(4)The participation contribution referred to in paragraph 2, point (b), is 15 % of the value of Canadian content in contracts that are based on the conditions set out in this Agreement.Official text, as of 12 October 2026.
value of Canadian contentvalue of Canadian contentvaleur du contenu canadienWert des kanadischen InhaltsAgreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 6(4)The participation contribution referred to in paragraph 2, point (b), is 15 % of the value of Canadian content in contracts that are based on the conditions set out in this Agreement.Official text, as of 12 October 2026.
categoriescategory one; category twopremière catégorie; deuxième catégorieKategorie eins; Kategorie zweiCouncil Regulation (EU) 2025/1106 (SAFE), Article 1, first paragraphThis Regulation establishes the Security Action For Europe (SAFE) through the Reinforcement of the European Defence Industry Instrument (the ‘SAFE instrument’) providing financial assistance to Member States, enabling them to carry out urgent and major public investments in support of the European defence industry in response to the current crisis situation.Official text, as of 12 October 2026.
small dronessmall drones (NATO class 1)petits drones (classe 1 de l’OTAN)kleine Drohnen (NATO-Klasse 1)Council Regulation (EU) 2025/1106 (SAFE), Article 1, first paragraphThis Regulation establishes the Security Action For Europe (SAFE) through the Reinforcement of the European Defence Industry Instrument (the ‘SAFE instrument’) providing financial assistance to Member States, enabling them to carry out urgent and major public investments in support of the European defence industry in response to the current crisis situation.Official text, as of 12 October 2026.
operational arrangementsoperational arrangementsarrangements opérationnelsoperative ModalitätenS 10
documentary evidencetypes of documentary evidencetypes de preuves documentairesArten von NachweisenCouncil Regulation (EU) 2025/1106 (SAFE), Article 10(3)In addition, these operational arrangements shall set out types of documentary evidence and control rules related to the fulfilment of the specific eligibility rules applied by the Member States in accordance with Article 16, and the detailed elements referred to in Article 14.Official text, as of 12 October 2026.
industrial reinforcement actionsindustrial reinforcement actionsactions de renforcement de l’industrieMaßnahmen zur Stärkung der IndustrieE 12
raw materialsraw materialsmatières premièresRohstoffeE 12(1)
mid-capmiddle-capitalisation company; mid-capentreprise à moyenne capitalisationUnternehmen mit mittlerer Kapitalisierung; Midcap-UnternehmenE 2(19)

Where the language versions differ

ProvisionHow the language versions differ
SAFE 16(10), sentence 2EN "no component shall be sourced from a third country"; DE "aus einem Drittland"; FR "aucun composant ne provient d'un autre pays tiers" (another third country). FR also says "Aux fins des acquisitions conjointes" (common procurements) where EN says "procurements".
SAFE 16(12)EN "essential for the functioning of a product"; DE "eines Verteidigungsguts" (a defence product). FR uses the plural "qui ont besoin" for the access-to-classified-information limb.
SAFE 16(4)FR is phrased restrictively ("ne sont admissibles ... qu'à condition que"); EN and DE are phrased permissively ("shall be eligible ... providing that"; "kommt ... in Betracht, sofern").
SAFE vs EDIP GermanSAFE uses "Komponenten" and "Konstruktion"; EDIP uses "Bestandteile" and "Gestaltung" for the same concepts.
EDIP 11(6)FR omits the words corresponding to "to its procurement procedures and contracts with contractors" (EN and DE include them).
EDIP 2(13)DE adds "(bzw. Generaldirektor oder Geschäftsführer)" after "Vorstandsvorsitzenden".
USL 13(5), third subparagraph(added 2026-10-07): EN and DE require the legal commitment on the delivery lead time for "points (a) and (b)" („Buchstaben a und b“); FR says « point b) » only. Never translate this sentence from FR.
USL 13(4)(g), second sentenceFR « d’un pays tiers » (a third country), unlike SAFE 16(10) FR « d’un autre pays tiers ».
USL 13(4), second subparagraphEN and FR "of this paragraph"; DE „dieses Artikels“ (of this Article).
USL 13(4)(b)EN "non-EU partners", DE „Nicht-EU-Partnern“, FR « partenaires issus de pays tiers » (partners from third countries).
Canada 5(8)limbs 2 and 3 say "components from third countries" (FR « en provenance de », DE „aus“) where the Canadian and European sets are "originating"; limb 3 drops "estimated" in all three languages (A2-17).
EDIP 9(1)FR « structures de gestion exécutive », while FR 2(13) defines « structure exécutive de gestion ». Same concept; the FR page uses the 2(13) form and notes the variant.

Source of the rule texts

Rule texts: © European Union, 1998-2026, reproduced from EUR-Lex (eur-lex.europa.eu) and the Funding and Tenders Portal under Commission Decision 2011/833/EU on the reuse of Commission documents. Only the texts published in the Official Journal of the European Union are authentic. The texts are quoted unchanged; the date shown is the date Lodemark last checked them.

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