This paper highlights the strategic importance of integrating subnational governments into the European Union’s de-risking policy towards China, focusing on their unique contributions to mitigating dependencies and enhancing resilience. While the EU has shifted from a decoupling strategy to de-risking—emphasising diversification and safeguarding critical sectors—the role of subnational entities such as cities and regions remains underutilised. Often at the forefront of international partnerships, these actors engage in sectors vulnerable to geopolitical, economic, and reputational risks, but also present opportunities to support the EU’s strategic objectives. The paper demonstrates how subnational governments can be instrumental in diversifying partnerships across Asia, advancing the EU’s Global Gateway initiative, and contributing to industrial policy, all within the de-risking framework. It proposes a structured, three-step model—recognition, mechanisms for input, and best-practice sharing—to enhance the engagement of subnational actors in EU policies. By leveraging their expertise and local networks, cities and regions can play an essential role in strengthening the EU’s resilience, reducing over-reliance on China, and linking local initiatives with the Union’s broader strategic goals. Through a comprehensive analysis of risks, opportunities, and actionable recommendations, this paper underlines the critical need for multilevel governance in addressing the complexities of EU-China relations, positioning subnational actors as essential contributors to the Union’s de-risking strategy.
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