From narrative to rules: the institutionalisation of EU ‘de-risking’ towards China, 2022–2024

As the European Union (EU) has increasingly framed its China policy through the formula of “de-risking, not decoupling,” a central analytical question is how this language becomes institutionally embedded in governance arrangements. Drawing on Strategic Narrative Theory, a CDA-informed textual analysis, and process tracing, this article examines how de-risking-related strategic language was progressively stabilised and recontextualised across EU policy and legal texts during 2022–2024, using the Foreign Subsidies Regulation (FSR) as the principal case and the Anti-Coercion Instrument and critical raw materials Act as auxiliary comparators. It asks how selected narrative elements become rendered actionable through legal categories, procedural thresholds, and administrative enforcement routines; why China’s counter-narratives travel only partially within EU institutional settings; and how member-state heterogeneity conditions the scope and intensity of institutional embedding. The article develops a three-stage analytical pathway of narrative institutionalisation—discursive framing, institutional accommodation, and policy codification—as a mid-range heuristic for tracing how narrative claims acquire legal-bureaucratic form. Rather than claiming a direct clause-by-clause causal translation from discourse to law, the analysis argues that de-risking gains institutional traction insofar as economic-security concerns are rendered intelligible through ostensibly technical categories such as market distortion, fair competition, and supply vulnerability, thereby becoming reviewable and actionable within EU governance. China’s counter-narratives remain constrained by normative misalignment, limited procedural translatability, and field-level gatekeeping, while member-state variation affects the scope and intensity of embedding without preventing convergence at Union level. By specifying how strategic language is stabilised in legal text and administrative practice, the article extends Strategic Narrative Theory in a more explicitly institutional direction.