Eyes wide shut: How to read China’s playbook in the Western Balkans (Part two)

Summary

• The EU lacks a clear “China conditionality” in its enlargement policy with Western Balkan countries—that is, defining and implementing conditions for candidates to engage with China—and the topic of China remains largely absent from accession talks.
• The EU’s own hesitant China policy is in part to blame. The union’s official stance of balancing cooperation and rivalry no longer reflects EU actions in practice, which lean towards confrontation.
• As membership talks stall, China’s influence in the Western Balkans grows, raising fears that new member states could act as promoters of Chinese interests and veto actions against Beijing in the EU.
• The EU must clarify its China policy and embed it as a clear conditionality in the accession process.
• It also needs to establish a firm timeline for Western Balkan membership and strike a better balance between requirements and incentives to encourage progress.
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A patchwork of measures against Beijing

While the EU avoids explicitly defining and labelling its emerging approach to China, recent actions make the direction clear: it is moving towards decoupling. As competition expands and intensifies, the EU has rolled out a suite of legal instruments aimed at boosting its economic security and strategic autonomy:

• The Anti-Coercion Instrument (2023). This is probably the bloc’s most prominent tool to deter and respond to economic pressure from non-EU countries, such as trade restrictions and boycotts. Though not yet deployed, the EU has considered using it amid trade tensions with China and the US.
• The Foreign Subsidies Regulation (2023): This instrument targets distortions created by subsidies to non-EU entities operating in the bloc’s single market. Such distortions have granted unfair advantages to non-EU firms, especially Chinese ones, in acquisitions and public procurement contracts.
• The EU’s International Procurement Instrument (2022): This tool ensures reciprocity in access to international procurement markets, thereby addressing the difficulties EU companies have faced in China when competing in its expanding procurement market. It was used for the first time in June 2025, partially restricting Chinese medical-device manufacturers’ access to the EU’s €150bn market in response to barriers faced by EU firms in China.

As the EU expands its policy toolbox and uses its various legal provisions, trade with China has become increasingly complicated.

For example, the European Commission has initiated several proceedings against major Chinese online retailers. These include the Chinese marketplace AliExpress—for potentially breaching the bloc’s Digital Services Act and not doing enough to prevent the sale of counterfeit goods and unsafe products. But a final determination on whether to impose sanctions is still pending. The commission has also initiated an investigation into Chinese retailer Shein for potentially violating EU consumer protection linked to sale of illegal goods. And in October 2024, it opened formal proceedings against Temu, another major Chinese retail platform, for potential violations of the Digital Services Act. This involves examining whether Temu has sold non-compliant products, as well as its recommendation algorithm and the allegedly “addictive” design of the platform.

Other actions against China at the member-state level could have wider EU implications. Italy and Germany, for instance, have attempted to block the transfer of private data of EU citizens by DeepSeek, the Chinese AI-powered chatbot. This practice of individual EU member states adopting unilateral measures to address various aspects of China’s behaviour could expand in the future.

The China conditionality

The development of a “China conditionality”—that is, defining and implementing conditions for the Western Balkan candidates to engage with China—remains a work in progress.

Historically, accession conditions were negotiated between the EU, member states, institutions such as the European Commission and the European Parliament, and the candidate countries themselves. These conditions focused on political, economic and legal reforms, and were then monitored during the accession process to ensure alignment. While there is some leeway for adoption, their implementation by the prospective EU member state is deemed essential for integration into the EU. The ongoing accession processes with the Western Balkan countries are no exception.

Accession in the region is at markedly different stages, with, for example, Montenegro deep into the process while Kosovo lacks a clear path forward. However, one thing is certain: the process is advancing while any possible China conditionality is still in development. That gap stems mostly from the absence of a stable, EU-wide consensus on China. The EU’s policies are frequently reactive—it forms them in response to emerging tendencies and threats, as seen in the piecemeal rollout of the various investigations and instruments outlined above.

The China conditionality is thus a moving target, and such targets are especially difficult to institutionalise and enforce. Steps towards it continue to resemble a loose collection of principles rather than a well-defined and coherent structure of conditions, laws and practices expected from the Western Balkan countries.

It is important to note that the EU’s China conditionality would invariably involve external actors, such as the US, given their interests in the Western Balkans and the historically close alignment of American and EU foreign policies. Ideally, what should be in question is a wider “Western conditionality” that incorporates shared US and EU interests, albeit in a political rather than institutional context. This could cover areas such as export controls, investment screening and data security. The US and EU member states could also address this bilaterally and separately. But so far no structured dialogue has taken place between the EU and US to arrive at a common understanding on a China-related conditionality beyond some ad hoc considerations, for instance in the area of security. The same holds for the interaction between Washington and the respective capitals in the Western Balkans, which remain focused on regional stability and increased economic engagement. As things stand, the EU and the US are more likely to pursue the fulfilment of their conditions separately.

As with the EU, the US administration is also grappling with an unclear and evolving China policy. Export restrictions on chip manufacturing software, for example, have oscillated between security risk and negotiation card with Beijing. Likewise, export controls on Nvidia’s powerful H20 chip, vital for AI development, have been inconsistent. The US has also all but ceded green energy as an area of rivalry, given its dismissive approach to the sector. Considering all this, the current US administration does not have a structured China containment policy.

Including the China element in accession negotiations

The EU is showing limited signs of attempting to insert a China conditionality into accession negotiations with Western Balkan countries. Recent updates on membership talks with Serbia show very few chapters in which China is discussed. Even when such references do appear, they tend to be vague and lack explicit conditions and deadlines. For instance, chapter 30 (external relations) mentions Serbia’s FTA with China and contains  some notes on compatibility. But the text is brief and non-committal and lacks a timeline and an awareness of the consequences of this agreement.

In chapter 31 (foreign, security and defence policy), China’s deepening ties with Serbia are noted, and are even listed in some detail, but not as a point of conditionality. Chapter 5 (public procurement) similarly notes the practice of circumventing tenders through intergovernmental agreements, which has long been China’s preferred approach, but does not set out corrective measures.

Several accession chapters could address China-related issues. These include:

• Chapter 10 (digital transformation and media), which could incorporateChina’s penetration in 5G networks in the Western Balkans and the role of Chinese actors in the media;
• Chapter 19 (social policy and employment), which could address frequent violations of labour law by Chinese companies in Serbia;
• Chapter 31 (foreign, security and defence policy), which could tackle the growth of Western Balkan defence and security ties with Beijing, including the acquisition of weapons;
• Chapter 5 (public procurement), which could incorporate China’s status as one of the largest beneficiaries of non-tender procurement, such as through intergovernmental agreements. The issue is barely mentioned even in the Montenegro process.

Given this context, it is little surprise that instances of non-compliance with EU law are already emerging. For example, in the area of public procurement, Montenegro has signed and prepared numerous bilateral agreements which contain non-competitive clauses in relation to public tenders in different sectors. The case of the Bar-Boljare motorway, for example, simply appointed the China Road and Bridge Corporation as the executer of the project, bypassing competitive tender. Not only does this contradict EU law, but it also almost led to the bankruptcy of the country just a few years ago. As discussed, such clauses exist in agreements with the UAE (in tourism and real estate) and Hungary (in road and rail transport and infrastructure), and are being discussed in preliminary texts of similar agreements with Ukraine (in e-government, digital services and education) and France (energy, health care and defence).

This trend persists despite the fact that Montenegro has provisionally concluded chapter 5 negotiations with a general recommendation to reduce the number of non-competitive public tenders. Still, not only is the practice of bypassing tenders spreading to more sectors, but it is being codified in contracts with international entities.

Integration and political promiscuity

“EU accession is the only game in town”: this cliché from the late 1990s and early 2000s has proven resilient. It captured the unipolar order of that time, but no longer accurately reflects the reality on the ground. More than two decades since the prospect of EU membership was presented to the Western Balkan states, progress has stalled. The timeline continues to recede, negotiations become ever more complex—all while the geopolitical context shifts. Today, “hedging”, or the practice of interacting with many actors in order to obtain concessions from all of them, is the norm in the region. There are now many games in town.

China has emerged as an influential actor in this context, and is presently deploying a new playbook to consolidate its presence. Its central feature is a society-based approach to engagement. While Beijing historically focused on state institutions and political elites through large-scale, often non-transparent projects—particularly in infrastructure and energy—it is now increasingly engaging directly with societal groups across numerous areas, such as trade, defence, culture, academia, media and more.

China’s influence is also driven by acquisitions of local companies, assets and infrastructure. This approach is visible worldwide and is no different in the Western Balkans. Financial lending now goes beyond the Belt and Road Initiative and other state-led frameworks, with Chinese firms and banks deploying finance and direct investments in various sectors.

Meanwhile, the EU’s own China policy remains uncertain. Its longstanding three-element formula of cooperation, competition and rivalry no longer reflects the real dynamics of the EU-China relationship. While there are instances of cooperation, the dominant theme is competition, at times even confrontation. This transformation is still not fully embedded in the EU’s political discourse or formal policy statements, and there remains a lack of consensus among member states on how to define and approach relations with Beijing.

However, the reality is that the EU has been adopting a suite of legal instruments aimed at responding to Chinese practices. In recent years, there has been a marked increase in the use of these instruments, signalling a steady rise in a competitive logic of interaction. These instruments still resemble a patchwork, but they all point to increasing confrontation in numerous domains.

The China conditionality is in development at the same time as ongoing negotiations with Western Balkan states. While EU institutions are at the forefront of defining both processes, individual member states are also informing them. The European Parliament in particular has been regularly monitoring and adopting resolutions on Chinese actions in south-eastern Europe, and is often more critical than the European Commission.

In addition, the China conditionality is defined in a broader context with the participation of the US, both between Brussels and Washington and between the US and the countries of the Western Balkans. This process is presently complicated by the absence of clear American policy towards China, and the transactional tendency of the US administration which has sidelined security considerations.

These difficulties have led to an absence of China considerations in EU accession negotiations with the Western Balkan states. Given the wider geopolitical impasse, normalised illiberalism and plentiful opportunities for engagement with non-Western actors, elites in the region increasingly face a dilemma between political integration and promiscuity, with multiplying evidence pointing to a preference for the latter.