Fan Zhang Participates in Proposal Review at Third ICC Working Group Meeting on EU Foreign Subsidies Regulation

On March 31, 2025, the International Chamber of Commerce (ICC) convened the third meeting of its Working Group on the EU Foreign Subsidies Regulation (FSR).
The session focused on the collective review and refinement of a regulatory proposal drafted by the Working Group, addressing practical challenges encountered in the early application of Regulation (EU) 2022/2560.

Lawyer Fan Zhang, Director of the Foreign Legal Affairs Department at JINGSH Chengdu, participated in the meeting as the member of the Working Group, actively contributing to discussions on improving regulatory clarity and compliance feasibility.

Review of the Working Group Proposal

The proposal under review consolidates key concerns raised by Working Group members regarding:

  • The classification and disclosure of financial contributions (FFCs), including tax exemptions and subsidies;
  • The interpretation of measures of general applicationversus selective advantages for specific sectors, regions, or undertakings;
  • Proportionality principles in notification thresholdsand enforcement practices to avoid imposing undue burdens on non-targeted businesses.

The draft aimed to provide structured feedback to the European Commission, advocating for clearer guidelines and a more balanced regulatory framework to support international business compliance.

Ongoing Contribution to Global Compliance Dialogue


“Clear and proportionate rules are essential to fostering trust and stability in international markets.”said Lawyer Fan Zhang.

Through her active role within the ICC Working Group, Fan Zhang continues to contribute to the shaping of global regulatory standards, strengthening JINGSH Chengdu’s leadership in cross-border compliance and international legal advisory.