On 4 March 2026, the European Commission formally adopted the EU Ports Strategy, alongside its companion Industrial Maritime Strategy. Weeks before that, the Brussels Sustainability Club circulated a pre-adoption draft stamped Sensitive: Until Adoption.[1] The distance between the two texts is instructive. What survived into the final version shows what Brussels chose to say in public. What disappeared shows what Brussels actually means in private.
What it means, in short, is COSCO. And COSCO means Piraeus, but it also means Zeebrugge, Rotterdam, Valencia, Hamburg, and Vado Ligure. The EU’s exposure to Chinese state capital in its port infrastructure is not a Greek problem with a Mediterranean accent. It runs the full length of the continent’s coastline, from the North Sea to the Adriatic. There is a certain institutional elegance to the way the European Commission constructs regulatory precedent. It identifies the most visible, most advanced, most politically uncomfortable case. It writes rules that describe that case with forensic precision — without naming it. Then it applies those rules uniformly across every comparable situation in the Union. Piraeus absorbed the political controversy. The regulatory framework will do the actual work.
The scope of the prize
The Port of Piraeus is the chief seaport of Athens and the largest port in Greece. Under a 2016 privatisation deal, COSCO Shipping bought a 51% stake in the Piraeus Port Authority for €280 million, later raising that holding to 67% in October 2021.
The throughput figures tell the commercial story without editorialising: from approximately 672,000 TEU in 2008 to a peak of 5.3 million in 2021, Piraeus grew at a pace that transformed its regional standing entirely. The 2024 figure of 4.8 million TEU reflects a temporary contraction driven by the Red Sea crisis and the rerouting of global shipping lanes. Piraeus today ranks as the fifth largest container port in Europe and one of the two largest in the Mediterranean. By any standard commercial metric, COSCO delivered.
According to the EU Ports Strategy , European ports are the backbone of the continent’s external trade, moving 74% of goods by volume — 3.4 billion tonnes annually — while serving nearly 395 million passengers and sustaining over 423,000 direct jobs. These are not abstract statistics. They describe the physical architecture through which European supply chains — civilian and military — flow. Control of that architecture, in whole or in part, is the actual subject of the EU Ports Strategy. The word “China” does not appear once in either the draft or the final text. It does not need to.
COSCO’s European footprint: the full map
Chinese state-owned COSCO and China Merchants Ports, alongside Hong Kong-based CK Hutchison, hold minority or majority stakes in around 30 EU port terminals, including Rotterdam, Antwerp–Bruges and Hamburg. Together, these positions constitute a de facto parallel logistics network inside the EU single market — state-owned, strategically coordinated, and present at every major gateway the continent possesses. The following table documents COSCO’s verified positions with their stakes and concession status:
| Port | Country | COSCO Stake | Terminal | Design Capacity (TEU) | Control Level |
|---|---|---|---|---|---|
| Piraeus | 🇬🇷 Greece | 67% (PPA) + 100% (PCT) | Piraeus Container Terminal (Piers II & III) | ~6.2M | ✅ Full operational control (Piers II & III) |
| Zeebrugge | 🇧🇪 Belgium | 85–90% | CSP Zeebrugge Terminal | ~1.3M | ✅ Effective full control (long-term concession to 2055) |
| Valencia | 🇪🇸 Spain | 51% | CSP Iberian Valencia Terminal | ~4.1M | ✅ Majority control (joint venture) |
| Bilbao | 🇪🇸 Spain | 39.5% | CSP Iberian Bilbao Terminal | ~1.0M | ⚠️ Significant minority |
| Antwerp | 🇧🇪 Belgium | 20% | Antwerp Gateway | ~3.7M | ⚠️ Minority |
| Rotterdam | 🇳🇱 Netherlands | ~17.85% (historically up to 35%) | Euromax Terminal | ~3.2M | ⚠️ Minority |
| Hamburg | 🇩🇪 Germany | 24.9% | CTT (HHLA) | ~1.8M | ⚠️ Minority (no veto rights) |
| Vado Ligure | 🇮🇹 Italy | 40% | Vado Container + Reefer Terminal | ~0.85M | ⚠️ Significant minority (operational influence) |
Notes
- Design capacity figures refer to installed terminal capacity, not actual throughput.
- Actual throughput is typically below installed capacity:
- Piraeus Container Terminal: ~3.97M TEU (2025)
- Euromax Rotterdam: ~2.37M TEU
Analytical note
COSCO holds full operational control only at Piraeus and Zeebrugge. Its positions in Northern Europe (Rotterdam, Hamburg, Antwerp) form a distributed network of minority stakes, enabling logistical integration and strategic presence without requiring full ownership. The significance lies in the systemic pattern of investments rather than any single asset.
Sources: Seatrade Maritime, Offshore Energy, IntermodalNews, myKN/Lloyd’s List, COSCO Shipping Ports 2025 Annual Results, European Parliament Research Service
The geographic logic is not subtle. Having already bought stakes in Antwerp and Rotterdam, COSCO secured Zeebrugge as its main hub in the North Sea. Piraeus and Valencia cover the Mediterranean entry points. The result is a Chinese state-owned enterprise with operational presence at every major gateway into the European single market — both northern and southern approaches, simultaneously.
Five provisions written about Piraeus (without saying so)
The leaked draft contains five distinct mechanisms, each of which maps precisely onto the COSCO situation across the European network — and onto Piraeus in particular.
The 300 nautical mile rule. The draft introduces a competitiveness check for EU-funded investments in third-country ports within 300 nautical miles of EU facilities. This radius covers the entire Eastern Mediterranean, the Black Sea coast, and North Africa — precisely the zones where Chinese capital has advanced most aggressively. Any project that disadvantages a nearby EU port triggers review. Piraeus sits at the centre of that geometry.
The reciprocity clause. The draft calls for the exclusion from EU concessions and procurement of bidders from markets that deny access to EU operators. European companies cannot acquire strategic Chinese port infrastructure. COSCO has acquired strategic European port infrastructure in eight locations. This asymmetry was long acknowledged in private and consistently unaddressed in policy. The EU Ports Strategy now provides the framework to address it — prospectively, and on Brussels’ timetable.
High-risk suppliers and the equipment question. The draft demands risk assessments for foreign-owned operational systems and equipment in ports. ZPMC, the Chinese manufacturer that supplies a substantial share of loading cranes across European terminals, appears nowhere by name. The description, however, is exact. The United States Department of Defense has already raised concerns about embedded software in ZPMC cranes at American facilities. Brussels is now building the regulatory basis to ask the same question on European soil — with legal consequences attached.
FDI screening for TEN-T core ports. Piraeus sits within the TEN-T core network. The revised FDI Screening Regulation referenced in the EU Ports Strategy will require member states to screen foreign direct investments in these ports. The mechanism applies prospectively. It does not, on its face, retroactively unwind completed transactions. The draft, however, goes further — and here the language becomes consequential for every COSCO position in the table above.
The temporary public control provision. This is the most operationally significant element of the leaked draft, and the one that vanished most completely from the official press releases. The draft instructs member states to secure “the possibility of gaining temporary public control or right of use of strategic dual use infrastructure, assets or equipment under national law.” In direct terms: Greece, Belgium, Spain, the Netherlands, Italy, and Germany must each maintain a legal mechanism capable of re-asserting state control over COSCO-operated terminals in a crisis. The scenario the drafters had in mind requires no particular imagination. A serious geopolitical rupture between the EU and China — a prospect that seemed remote in 2016 and looks considerably less remote in 2026 — would place every terminal in the table above in a position of acute strategic tension simultaneously.
The regulatory precedent: Piraeus as template, Europe as target
This is where the architecture of the EU Ports Strategy reveals its full scope. Brussels did not write this framework for one port. It wrote it for thirty terminals, and used Piraeus to set the parameters. Whether by deliberate design or by the convergence of geopolitical necessity and available precedent, the effect is identical: a single regulatory framework that addresses the entire Chinese port footprint in the EU, using the most visible case to establish the rules that govern all the others.
China’s two dominant state-owned port operators spent two decades expanding across European terminals with minimal regulatory resistance. That era is now over. Brussels has placed both firmly under institutional scrutiny. Each of the five provisions above operates identically at Zeebrugge, Valencia, Rotterdam, and Vado Ligure. The 300-nautical-mile rule applies to Chinese-backed port development in Morocco and Tunisia, competing directly with COSCO’s own EU terminals. The reciprocity clause applies to every future concession tender in all 27 member states. The high-risk supplier assessment applies to every ZPMC crane across the entire European network. FDI screening applies to every TEN-T core port, and COSCO holds positions in several of them simultaneously.
The concession renewal mechanism is where the long-term leverage concentrates. Tighter FDI screening will constrain future Chinese acquisitions, but with few new terminal opportunities available and existing concessions running for decades, the immediate practical impact is limited. The real pressure point is renewal. Brussels is not seeking an immediate confrontation. It is building the regulatory architecture that makes every COSCO position across the European network progressively harder to maintain, renew, and expand, without ordering a single divestiture.
The Zeebrugge concession, extended to 2055 before the strategy was adopted, is the outlier that proves the rule. Brussels cannot easily unwind it. What Brussels can do is ensure that no equivalent arrangement is replicated elsewhere, and that when 2055 eventually arrives, the regulatory environment in which that renewal is negotiated bears no resemblance to the one in which the original agreement was signed.
The military clause that moved addresses
In the leaked draft, the Military Mobility Regulation sat inside the Ports Strategy itself, with explicit provisions on dual-use infrastructure, state override mechanisms, and defence readiness. In the final published package, this material migrated — without announcement — into the Industrial Maritime Strategy, under a pillar labelled “Secure and Protect.” That pillar explicitly covers naval, underwater, dual-use and military mobility capabilities.
This is a deliberate editorial choice. A ports strategy that explicitly contemplates temporary seizure of privately operated infrastructure generates uncomfortable questions from investors, shipping companies, and member states with liberal economic traditions — including, conspicuously, Germany and the Netherlands, both of which host COSCO terminals. The same provision, placed in a maritime industrial strategy, attracts considerably less scrutiny from the financial press.
For Greece, Belgium, Spain, Italy, and the Netherlands, the substance is identical regardless of which document carries it. The southern and northern flanks of NATO depend on the free movement of military assets and equipment through European ports. That operational reality and COSCO’s control of terminals in Piraeus, Zeebrugge, Valencia, Rotterdam, and Vado Ligure do not sit comfortably together — simultaneously, across five countries.
Hamburg as method, Piraeus as warning
Hamburg capped COSCO’s position at a sub-25% non-controlling stake in a single terminal, then restructured governance further by bringing MSC in as a strategic partner, with the city retaining 50.1% of HHLA. The Hamburg model — structured dilution, governance reform, western anchor investor, public control retained — is now the implicit template that the EU Ports Strategy promotes without naming it. The effect of that model, intentional or not, is to set a standard against which every other member state’s arrangements will eventually be measured.
In October 2021, Greece’s privatisation agency completed the transfer of an additional 16% stake in the Piraeus Port Authority to COSCO, even though COSCO had concluded only one third of its mandatory investment commitments at the time. The Hamburg playbook was available. Greece chose to deepen the existing arrangement instead. Athens will now implement a framework designed, in significant part, to contain what its own government approved.
Piraeus embodies the first era. Hamburg embodies the second. The EU Ports Strategy adopted on 4 March 2026 is the instrument that generalises Hamburg’s approach across the entire European network, terminal by terminal, concession by concession, renewal by renewal.
Hamburg shows the model. Piraeus shows the cost of not using it.
Greece’s impossible position
Greece occupies a position of genuine structural discomfort in this architecture. It is a member state obliged to implement the EU Ports Strategy. It is simultaneously the member state with the deepest Chinese port presence in the Union.
COSCO delivered results. It created jobs, increased throughput, and built Piraeus into a genuine regional hub. The Greek state received investment it could not have generated domestically. These are facts, and they deserve acknowledgment without qualification.
They do not, however, resolve the structural problem. Every new regulatory instrument in the EU Ports Strategy — FDI screening, high-risk supplier assessments, reciprocity clauses, dual-use infrastructure reviews, runs directly through Piraeus. Greece cannot implement this strategy without confronting its own arrangement with COSCO. And it cannot ignore the strategy without confronting Brussels.
The diplomatic option of managing both relationships simultaneously and indefinitely is becoming harder to sustain. The leaked draft made clear that the Commission understands this perfectly well. The official text makes the same point with considerably better manners.
The document Brussels didn’t want you to read too carefully
The gap between the leaked draft and the EU Ports Strategy press release is, in the end, a gap between candour and communication strategy. The substance is largely the same. The tone is markedly different.
The draft uses the language of geopolitical risk management because that is what it is. The official announcement uses the language of competitiveness and sustainability because that is what plays well across twenty-seven member states. Both documents arrive at the same destination: European ports where Chinese state capital exercises operational control represent a category of strategic exposure that the EU can no longer manage by looking elsewhere.
No single provision forces divestiture. No mechanism triggers automatic reversal. What the framework does instead is make every operational decision, every infrastructure investment, every equipment procurement, and every concession extension subject to a level of regulatory scrutiny that did not apply when the original deals were concluded. Over time, under compounding compliance costs and governance constraints, the commercial calculus of maintaining a 67% stake — or an 85% stake, or a 35% stake — in a European port changes. Not because Brussels ordered it. Because Brussels made the alternative progressively more expensive.
Piraeus is not mentioned once in either document. It does not need to be. Every paragraph of the leaked draft, and most of the official EU Ports Strategy, was written with full knowledge of what stands at the end of the E94. All thirty terminals are on the list. The addresses are known. The timetable is set. The question is no longer whether the framework applies. Only when.
The bill has not yet arrived. But it has been drafted, initialled, and placed in envelopes. The one addressed to Athens carries the heaviest postage — because Athens was first, went furthest, and has the furthest still to travel.
[1] Editorial note: geo-trends.eu has obtained and reviewed a pre-adoption draft of the European Ports Strategy, circulated by the Brussels Sustainability Club and marked “Sensitive: Until Adoption.” The document is not published for legal reasons. Its authenticity has been verified through direct comparison with the officially adopted text of 4 March 2026. All references correspond to specific provisions in the draft as reviewed by the editors.