---
title: "EDPCIs, five perimeters: Italy is in four, and the door reopens in April 2027"
description: "Decision (EU) 2026/2221 identifies five European defence projects. Who takes part, what they are worth, and why the eligibility criteria reach subcontractors."
url: https://csidia.com/en/notes/edpci-cinque-progetti-italia-quattro-su-cinque/
lang: en
date: 2026-10-02
label: "Regulation"
publisher: CSIDIA S.r.l. (https://csidia.com/)
italiano: https://csidia.com/note-operative/edpci-cinque-progetti-italia-quattro-su-cinque/
---

# EDPCIs, five perimeters: Italy is in four, and the door reopens in April 2027

If in the past few months you have decided where to put the next production line, which non-European subcontractor to renew a framework contract with, or whom to let into your capital, those decisions now carry a price they did not carry before. As of today there are five perimeters inside which Europe will decide what it buys jointly and where it expands defence production capacity, on horizons running to 2045. The list of who is inside is fixed in a Council act, and getting in later takes the consent of everyone already there.

## What entered into force today

**Council Implementing Decision (EU) 2026/2221** of 28 September 2026 is in the Official Journal of the European Union, L series, of 1 October. Article 2: “This Decision shall enter into force on the day following that of its publication […]”. Today.

On 16 February 2026 the Commission had launched a call for expressions of interest; by 29 May Member States had submitted **nine** proposals; the Commission put **five** forward and the Council identified them; of the other four, no trace remains. In July we covered [the Commission’s proposal](https://csidia.com/en/notes/edip-difesa-europea), closing with “it is now up to the Council to formally establish them”. It is done: a proposal you comment on; an implementing act you either live with or get inside.

## Five perimeters, and the line where Italy is missing

The five European Defence Projects of Common Interest (EDPCIs) are **DECODER**, drones and counter-drone systems, with 28 participating countries; **IMSD**, maritime and seabed defence, 17; **SPACE**, 20; **EU-FIAMD**, integrated air and missile defence including early warning, 19; **EFW**, eastern flank watch, 17.

Italy appears in four lists out of five. It is missing from EFW, where the annex promises among other things “the expansion of relevant production capacity and facilities”. Two counts have to be made entry by entry, since nobody writes them down: **Ukraine is in all five** — in July, on the proposal, we counted it in four — and **Malta is in none**. The threshold in Article 35(2), point (e), of the EDIP Regulation — “they involve at least four Member States” — is comfortably cleared: the smallest has fifteen.

## The figures, and why they do not add up

The annex estimates each project on its own, in billions of euro: DECODER between 3.5 and 5 by 2033; IMSD between 43 and 72 by 2045; SPACE up to 24 by 2034; EU-FIAMD between 55 and 80 by 2040; EFW between 8.5 and 10 by 2032, plus a second line of up to 100 by 2036. This is the “estimated overall financial size of the EDPCI” called for by Article 35(6), point (c): a presumed size, not a budget appropriation. Six different horizons, two of them ceilings rather than ranges: the single total doing the rounds adds quantities that are not comparable.

One defect shows only in the Italian: in all five entries the figure, written out in full, carries the wrong unit — «Tra 3 500 000 000 e 5 000 000 000 miliardi di EUR entro il 2033», where *miliardi di EUR* reads *billions of EUR* and multiplies by a billion an amount already in euro. The second EFW line ends «entro il 2036», *by 2036*, with no unit after the digits at all. English and French write only “EUR”; the German has two English “to” left among the digits. Read the English.

## Who receives the money, and who watches it go past

Here a costly illusion is avoided. Article 35(13) is blunt: “Only Member States and associated countries, as well as SEAPs […], shall be eligible for funding under EDPCI activities”. No company is a direct recipient: they come in as suppliers and subcontractors, inside contracts somebody else signs, covering common procurement, production capacity and infrastructure.

The criteria, though, reach those contracts. Paragraph 9 of the same article obliges participating Member States to apply “criteria equivalent to those set out in Article 9” in contracts supported by Union funding, and for common procurement refers on to Article 11(6): the procurement agent applies those same criteria and must “require that those criteria are applied to subcontractors”. Article 9 is a questionnaire you must be able to fill in: establishment and executive management structures in the Union or in an associated country; facilities and resources used for the action located there **for the entire duration**; no control by a non-associated third country, save for guarantees approved under national procedures. [As in American defence contracts, the clause that decides is not the one in the tender notice](https://csidia.com/en/notes/contratti-ai-difesa-usa-clausole-non-leggibili).

Two thresholds. Article 10(3) caps at **35%** the cost of components originating outside the Union and associated countries against the estimated cost of the components of the end product; paragraph 4 extends the cap to products whose production capacity is increased with Union funding. Article 11(7) allows a non-European subcontractor allocated **between 15% and 35%** of the contract value, but only where the direct contractual relationship already existed before **30 December 2025**, when the Regulation entered into force.

## The paragraph that lands on your site

Paragraph 16 has the most physical consequences. The planning, construction and operation of production facilities related to an EDPCI “may be considered an imperative reason of overriding public interest” within the meaning of Article 6(4) and Article 16(1), point (c), of Habitats Directive 92/43/EEC and Article 4(7) of Water Framework Directive 2000/60/EC, “in the interests of defence” within the meaning of Article 2(3) of REACH Regulation (EC) No 1907/2006 and “in the interests of public health and safety” within the meaning of Article 9(1), point (a), of Birds Directive 2009/147/EC. With one reservation: “provided that the other conditions set out in those provisions are fulfilled”.

It is not an exemption: it is entry into the derogation branch of those directives, where the absence of alternatives and the compensatory measures must be demonstrated on the record. For a site next to a protected area or a water body, it is the difference between a procedure that never starts and one that does.

## The two doors, and the date to note

Anyone outside today has two routes. The first: paragraph 19 gives all Member States, associated countries and Ukraine the chance to join a project after its establishment, but “subject to the approval of all Member States participating in the EDPCI”. Unanimity among those already in.

The second is the next round. Recital 6 records that the Council agreed “with the understanding that the intent of the Commission is […] to launch a second call for expressions of interest before the end of April 2027”. It is not a legal obligation but a stated understanding — and the only temporal handhold in the act. Note the date.

The perimeter moves afterwards too: an annual joint report to the Commission (paragraph 17), and the Council’s power to amend the act “including by removing a project as an EDPCI” (paragraph 18). No consolidated version of the EDIP Regulation exists.

## Sources

- [Council Implementing Decision (EU) 2026/2221 of 28 September 2026 (EUR-Lex)](https://eur-lex.europa.eu/eli/dec_impl/2026/2221/oj/eng)
- [Regulation (EU) 2025/2643 — European Defence Industry Programme, Article 35 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2025/2643/oj/eng)

Note by CSIDIA S.r.l. (Vignola, MO, Italy): https://csidia.com/en/notes/edpci-cinque-progetti-italia-quattro-su-cinque/ · Who we are and what we do: https://csidia.com/en/at-a-glance/ · engagement@csidia.com