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The Bulgarian Ministry of Transport and Communications launched an open call for tenders on 4 September 2023 for 20 zero-emission electric push-pull trains capable of 200 km/h with at least 300 seats each, plus a 15-year maintenance contract and staff training — total estimated value EUR 613,765,903.66. The procedure was declared unsuccessful on 3 January 2024 after failing to attract qualifying bids through the open procedure; a negotiated procedure followed under which CRRC Qingdao Sifang Locomotive Co. Ltd. submitted a complete notification to the Commission on 22 January 2024 pursuant to Article 28 of the FSR (mandatory notification threshold for public procurement above EUR 250 million involving third-country financial contributions above EUR 4 million).
The Commission determined on 16 February 2024 that there were "sufficient indications that the company had been granted foreign subsidies that distort the internal market" within the meaning of Article 10(3)(d) of Regulation (EU) 2022/2560, thereby opening the first-ever Phase II in-depth investigation. Under FSR procedural rules the Commission had 110 working days from opening — until 2 July 2024 — to take a final decision.
Foreign subsidies identified at opening: The Commission's preliminary assessment identified approximately EUR 1.745 billion in total foreign financial contributions, approximately five times CRRC Qingdao Sifang's bid value. The primary categories were:
On 26 March 2024 CRRC Qingdao Sifang withdrew its tender from the Bulgarian procurement procedure. The Commission, under Article 13(2) of the FSR, closed the investigation following the withdrawal; no formal adverse finding, remedies, or prohibition were issued. Commissioner Thierry Breton's statement framed the outcome as a vindication of the FSR enforcement model: the credible threat of an in-depth investigation and full disclosure of subsidy volumes was sufficient to deter the bid.
The Bulgarian Ministry of Transport subsequently relaunched the procurement with Spanish manufacturer Talgo remaining as the only qualifying tenderer.
This case established the operational template for all subsequent FSR public-procurement enforcement actions:
1. Notification trigger: Chinese SOE mandatory notification under Article 28 after open procedure fails → negotiated procedure. 2. Preliminary review → Phase II: Commission used the 20-working-day preliminary review to identify sufficient indications, then escalated to Phase II in-depth. 3. Disclosure leverage: Full publication of subsidy volumes in the OJ summary notice (C/2024/1913) created reputational and competitive pressure beyond the case itself. 4. Withdrawal mechanism: No final decision required when the notifying party withdraws — case FSP.100147 established this procedural path as a de facto deterrence instrument.
Subsequent FSR public-procurement cases (LONGi/Shanghai Electric solar PV April 2024) replicated this playbook. Ex officio track investigations (Nuctech December 2025, Goldwind February 2026) followed a structurally distinct — proactively initiated — path.