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On 24 July 2020, the European Commission appointed Mr Denis Redonnet as the first Chief Trade Enforcement Officer (CTEO). The CTEO is a new post created by the Commission to strengthen the enforcement of EU trade agreements. The CTEO will be in charge of implementing and enforcing EU trade agreements, both within the EU and outside the EU, under direct guidance of the Commissioner for Trade.

The appointment of the CTEO reflects the high emphasis placed by the von der Leyen Commission on better enforcing compliance with existing and future trade agreements. This is likely to result in some of the existing EU concessions (duty relief) being removed, and possibly in the imposition of rebalancing duties against the EU’s trade partners, especially those countries with a less ambitious climate agenda. This is something that non-EU companies trading with the EU are advised to follow closely.

Creating the new post of CTEO

The Chief Trade Enforcement Officer (CTEO) is a new post created by the European Commission (Commission) to strengthen the enforcement of European Union (EU) trade agreements. In July 2019, Ursula von der Leyen, then President-nominee of the Commission, proposed a new role within the Commission to monitor the implementation of EU trade agreements,1 which was a long-standing demand from French President Emmanuel Macron. When announcing an ambitious climate policy, the so-called “European Green Deal”, in December 2019 to make Europe the first climate-neutral continent in the world by 2050, President von der Leyen confirmed that the EU’s efforts to enforce the sustainable development commitments of EU trade agreements would be further enhanced with the appointment of a CTEO. The Commission officially created the post of CTEO on 12 December 2019,2 but it took some time to complete the selection procedure for this position and to adjust the organisational structure of the Directorate-General for Trade (DG TRADE) accordingly.

Appointing the first CTEO and restructuring DG TRADE

On 24 July 2020, the Commission appointed as the first CTEO Mr Denis Redonnet,3 who also serves as one of the three Deputy Director-Generals in DG TRADE. Just before the appointment, Mr Redonnet, a French national, was the Director for WTO Affairs, Legal Affairs and Trade in Goods in DG TRADE. Mr Redonnet has been promoted to a Deputy Director-General. As the first CTEO, Mr Redonnet will lead DG TRADE’s Directorates F (Enforcement Market Access, SMEs, Legal Affairs, Technology and Security) and G (Trade Defence).

Before appointing the CTEO, the Commission restructured the organisation of DG TRADE so that a number of directorates could assist the CTEO in performing his enforcement functions. Interestingly, the Commission merged former directorates F (WTO Affairs, Legal Affairs and Trade in Goods) and G (Trade Strategy and Market Access) into one new Directorate F (Enforcement Market Access, SMEs, Legal Affairs, Technology and Security) and maintained a Directorate for trade defence without any changes.4 Both new directorates now fall under the CTEO, who will be in charge of World Trade Organization (WTO) litigation, other multilateral legal projects (e.g., multilateral investment court), foreign direct investment (FDI) screening and trade defence investigations.

The following directorates and units in DG TRADE will assist the CTEO:

CTEO (Deputy Director-General)