REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EU) 2023/1525 of the European Parliament and of the Council of 20 July 2023 on supporting ammunition production (ASAP)
Date: 2024-07-08
Institutions: Directorate-General for Defence Industry and Space, European Commission
Subjects: EU aid, EU production, European arms policy, application of EU law, arms industry, arms supply, common security and defence policy, conventional weapon, production aid, security of supply

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   EUROPEAN COMMISSION  Brussels, 8.7.2024  COM(2024) 296 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EU) 2023/1525 of the European Parliament and of the Council of 20 July 2023 on supporting ammunition production (ASAP)  
 
 
Table of content 

1. 

Introduction ......................................................................................................... 3 

a.  Purpose and structure of the document .............................................................. 3 

b.  Methodology ...................................................................................................... 3 

2.  Background .......................................................................................................... 5 

a.  Context.............................................................................................................. 5 

b.  Preparation of the ASAP Regulation .................................................................. 5 

c.  Measures established by the ASAP Regulation ................................................... 6 

d.  Preliminary activities ......................................................................................... 8 

3.  Overall implementation logic of the ASAP Regulation ........................................... 9 

4.  Work Programme and calls preparation ............................................................. 10 

a.  Implementation ............................................................................................... 10 

b.  Lessons identified ............................................................................................ 11 

5.  Application process and support to applicants ..................................................... 12 

a.  Implementation ............................................................................................... 12 

b.  Lessons identified ............................................................................................ 12 

6.  Evaluations and results ....................................................................................... 13 

a.  Implementation ............................................................................................... 13 

b.  Lessons identified ............................................................................................ 14 

7.  Recommendations ............................................................................................... 15 

8.  Conclusion .......................................................................................................... 16 

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1.  Introduction 

a.   Purpose and structure of the document  

Article 23(1) of Regulation (EU) 2023/1525 of the European Parliament and of the Council of 
20 July 2023 on supporting ammunition production (ASAP Regulation1) provides that "[b]y 30 
June  2024,  the  Commission  shall  draw  up  a  report  evaluating  the  implementation  of  the 
measures set out in this Regulation and their results, as well as the opportunity to extend their 
applicability  and  provide  for  their  funding,  particularly  with  regard  to  the  evolution  of  the 
security context. The evaluation report shall build on consultations of the Member States and 
key stakeholders and be communicated to the European Parliament and to the Council”.  

It follows that the objective of the present ASAP Evaluation Report is to assess the performance 
of the implementation of the ASAP programme, and particularly its effectiveness in fulfilling 
the objectives set out in the Regulation at each stage of its implementation.  

Moreover,  this  report  represents  an  opportunity  to  inform  the  on-going  negotiations  on  the 
Commission proposal for a European Defence Industry Programme2 (EDIP) and notably the 
ASAP follow-up measures included in the proposal. Indeed, whereas the ASAP and EDIRPA3 
Regulations shall only apply until 2025, the EDIP Regulation is expected to be adopted in 2025 
notably to allow for the continuation and extension in time and scope of the action performed 
in the context of ASAP and EDIRPA Regulations. 

Structure of the document 

After presenting the methodology retained for the drafting of the report (1.b) and recalling some 
background information (2), this Report provides the overview of the overall implementation 
logic of the ASAP Regulation (3), assesses the rationale, organisation and timing of the ASAP 
Work  Programme  and  Calls’  preparation  (4),  of  the  application  process  and  support  to 
applicants (5), of the evaluation of the proposals received and of its results and the expected 
impacts of the funded actions (6). For each session, the main lessons learned  are  presented. 
Finally,  a  summary  of  the  overall  lessons  identified,  and  long-term  perspective  closes  this 
Evaluation Report (7) together with conclusions (8). 

b.  Methodology  

The methodology followed complies with the ‘Better Regulation’ guidelines and toolbox in a 
manner  commensurate  with  the  state  of  the  programme  implementation  and  the  preparation 
time available. The Better Regulation Toolbox (Tool 45, Box 3) allows for the flexibility of not 
necessarily having to fully apply the guidelines when evaluating performance at an early point 
in  the  implementation  of  an  intervention  and  when  information  on  the  longer-term  changes 
(results and impact) is not yet available.  

On these grounds and given the tight timeline to prepare the report, no external contractors were 
involved to support the evaluation exercise, no call for evidence was issued and the number of 
stakeholders consulted was kept limited.  

1 Regulation  (EU)  2023/1525  of  the  European  Parliament  and  of  the  Council  of  20  July  2023  on  supporting 
ammunition production (ASAP) (OJ L 185, 24/07/2023, p. 7–25) 
2 COM(2024) 150 final: Proposal for a Regulation of the European Parliament and of the Council establishing the 
European Defence Industry Programme and a framework of measures to ensure the timely availability and supply 
of defence products (‘EDIP’).  
3 Regulation (EU) 2023/2418 of the European Parliament and of the Council of 18 October 2023 on establishing 
an instrument for the reinforcement of the European defence industry through common procurement (EDIRPA) 
(OJ L, 2023/2418, 26.10.2023). 

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Consequently, this Evaluation Report is based on: 

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the feedback provided by external stakeholders based on questionnaires distributed to 
the ASAP Programme Committee members and to the applicants to the ASAP calls for 
proposals. 

a consultation with the European Defence Agency (EDA). 

the feedback from Commission staff involved in the upstream consultations with the 
industry and supply chains involved in the production of artillery ammunition and in the 
preparation  of  the  Work  Programme,  in  the  evaluation  and  in  the  assessment  of  the 
opportunity to implement the Ramp-up fund. 

-  quantitative elements (e.g. timing, statistics on received proposals and projects selected 

for funding). 

Fig 1: Feedback received from ASAP Programme Committee representatives 

Fig 2: Feedback received from ASAP applicants

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2.  Background  

a.  Context  

Russia’s war of aggression against Ukraine  and broader geopolitical  instability represents  a 
paradigm shift and some of the European Union’s greatest challenges to date in security and 
defence. These challenges are likely to persist and point to a clear need to spend more, better, 
together, and European to tackle these challenges in a spirit of solidarity.  

Russia’s war of aggression against Ukraine has put the European defence industry and defence 
equipment market to the test and exposed the urgent need of the Member States to secure the 
timely delivery of defence products and systems in sufficient quantity, such as ammunition and 
missiles,  considering  their  high  consumption  rate  during  a  high-intensity  conflict.  Since  24 
February 2022, the Union and its Member States have been steadily stepping up their efforts 
to  help  meet  Ukraine’s  pressing  defence  needs  and  they  committed  to  ‘bolster  European 
defence capabilities’, as well as to fill in their national stocks.  

b.  Preparation of the ASAP Regulation  

At the special meeting of the European Council of 9-10 February 2023, President Zelenskyy 
emphasised the urgent need for further military support, through the provision of ammunition.  

Pursuant  to  the  Joint  Communication  on  the  Defence  Investment  Gaps  Analysis  and  Way 
Forward4, on 6 March 2023, the Defence Joint Procurement Task Force (DJPTF) composed of 
the Commission, the European External Action Service and the European Defence Agency, 
shared with the EU Member States its findings on the 155mm production capacity in the EU. 
On  20  March  2023,  the  Council  agreed  to  respond  to  the  demand  for  artillery  ammunition 
through a three-track approach5. More specifically, the Council agreed to:  

1.  Urgently  deliver  ground-to-ground  and  artillery  ammunition  to  Ukraine  and,  if 

requested, missiles.  

2.  Call  on  Member  States  to  jointly  procure  155mm  ammunition  and  missiles,  if 
requested, to refill their stocks while enabling the continuation of support to Ukraine.  

3.  Support a massive rump-up of EU manufacturing capacities. 

The Council invited the Commission to present concrete proposals to  “urgently support the 
ramp-up of manufacturing capacities of the European defence industry, secure supply chains, 
facilitate  efficient  procurement  procedures,  address  shortfalls  in  production  capacities  and 
promote investments, including, where appropriate, mobilising the Union budget.”  

In  response  to  the  Council  request,  on  3  May  2023  the  Commission  proposed  to  the  co-
legislators a Regulation on supporting ammunition production (ASAP) providing concrete and 
targeted  measures  to  support  the  ramp-up  in  production  capacities,  to  identify  and  address 
bottlenecks and to ensure security of supply for ammunition.  

The Regulation was adopted in a record time by the co-legislators on 20 July 2023, published 
in  the  Official  Journal  of  the  European  Union  on  24  July  2023  and  entered  into  force 
immediately.  

4 https://commission.europa.eu/document/download/4bcf9a69-ed82-4a74-836f-
b85bb16725f6_en?filename=join_2022_24_2_en_act_part1_v3.pdf  
5 https://data.consilium.europa.eu/doc/document/ST-7632-2023-INIT/en/pdf  

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c.  Measures established by the ASAP Regulation  

The ASAP Regulation establishes a set of measures and lays down a budget aimed at urgently 
strengthening  the  responsiveness  and  ability  of  the  European  Defence  Technological  and 
Industrial Base (EDTIB) to ensure the timely availability and supply of ground-to-ground and 
artillery ammunition as well as missiles (‘relevant defence products’), in particular by means 
of the following: 

(a) an instrument financially supporting industrial reinforcement for the production of 
relevant defence products in the Union, including through the supply of their components 
(the ‘Instrument’); 

(b) the establishment of mechanisms, principles, and temporary rules to secure the timely 
and lasting availability of relevant defence products to their acquirers in the Union. 

The Instrument is coherent with existing collaborative Union defence-related initiatives such 
as  the  European  Defence  Fund  (EDF),  the  EDIRPA  Regulation  in  support  of  common 
procurement, and the European Peace Facility.  

Pursuant to Article 110 of the EU Financial Regulation, the ASAP instrument is implemented 
through a single Work Programme. The Work Programme6 shall set out the funding priorities 
considering the work of the Defence Joint Procurement Task Force.  

The financial envelope for the implementation of ASAP for the period 25 July 2023 to 30 June 
2025 is EUR 500 million in current prices. The Instrument finances up to 35 % of the eligible 
costs of an eligible action related to the production capacities of relevant defence products, and 
up to 40 % to produce components and raw materials intended to produce relevant defence 
products.  

Actions  under  ASAP  shall  be  eligible  for  increased  funding  rates  when  those  fulfil  certain 
conditions.  The  Bonus  requirements  of  the  Instrument  differ  from  those  of  the  European 
Defence Fund (EDF). In both EU programmes, actions can be eligible for an increased funding 
rate (of +10% for ASAP and up to +15% for the EDF) where beneficiaries or most beneficiaries 
are mid-caps or SMEs. However, while bonuses are granted for EDF actions that are developed 
in the context of PESCO, ASAP allocates a bonus of +10% points when applicants demonstrate 
the creation of new cross border cooperation or commit to prioritising for the duration of the 
action, orders stemming from the joint procurement of relevant defence products. 97% of the 
retained proposals claimed one or more bonuses (all the different eligible bonuses were used) 
with a strong focus on the SME and mid-cap bonus: two thirds of the beneficiaries claimed to 
be SMEs or mid-caps.  

Eligible  actions  (Article  8(3)  of  the  ASAP  Regulation)  shall  relate  to  one  or  more  of  the 
following activities:  

(a)  the optimisation, expansion, modernisation,  upgrading  or repurposing  of existing, or 

the establishment of new, production capacities; 

(b) the establishment of cross-border industrial partnerships;  

(c)  the  building-up  and  making  available  of  reserved  surge  manufacturing  capacities  of 

relevant defence products; 

6 Annex to the  Commission  Implementing  Decision C(2023) 7320 final of 18.10.2023 on the financing of the 
instrument  on  supporting  ammunition  production  (ASAP)  established  by  Regulation  (EU)  2023/1525  of  the 
European Parliament and of the Council and the adoption of the work programme for 2023-2025. 

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(d) the testing, including the necessary infrastructure, and as appropriate, reconditioning 

certification; 

(e)  the training, reskilling, or upskilling of personnel; 

(f)  the improvement of the access to finance. 

The  mandatory  activities  under  each  call  for  proposals  (see  table  below)  are  eligibility 
conditions.  

Call 
EDF-ASAP-2023-LS-XPL 
EDF-ASAP-2023-LS-POW 
EDF-ASAP-2023-LS-SHL 
EDF-ASAP-2023-LS-MIS 
EDF-ASAP-2023-LS-TRC 

Mandatory activity 
(a) 
(a) 
(a) 
(a) 
(d) 

Optional activities 
(b) to (f) 
(b) to (f) 
(b) to (f) 
(b) to (f) 
(a) to (c) and (e) to (f) 

The activities were most focussed on the obligatory activities under each call, mainly activity 
(a), and activity (d) in the case of testing and recertification. Activity (f) was barely used in any 
of the retained proposals. 

The  ASAP  Regulation  (Article  7(2))  allows  retroactivity  therefore  permitting  actions  that 
started prior to the date of the submission of the proposal to be covered by ASAP grants as 
long as they did not start before 20 March 2023, and they were not completed before signature 
of grant agreement. Ten projects will use the retroactivity clause and start the activities before 
the signature of the grant agreement. In the cases where they have not yet started, they rely on 
parallel projects, normally fully nationally funded, to start. 

Moreover, there are actions or parts thereof of the ASAP that are not eligible for funding if they 
are already fully financed from other public or private sources. No such proposal was received. 

Entities participating in ASAP are (a) beneficiaries, i.e., members of the consortium/signatories 
of the Grant Agreement, (b) affiliated entities, namely third parties with a link to beneficiaries 
that can implement part of the action in their own name, (c) other entities such as subcontractors 
and associated partners. To be eligible, these entities, whether public or privately owned, shall 
be established and have their executive management structures in the Union or in an associated 
country and not be subject to control by a non-associated third country or entity. Alternatively, 
entities can be subject to FDI screening, a new possibility if compared to existing collaborative 
Union defence-related initiatives such as the EDF.  

Each proposal submitted by an applicant shall be assessed based on six award criteria (Article 
11 of the ASAP Regulation), namely: 

(a)  Ramp-up (increase in production capacity of the Union) 

(b) Speed-up (reduction of lead production time) 

(c)  Elimination of sourcing and production bottlenecks 

(d) Strengthen resilience through cross-border cooperation (including SMEs)  

(e)  Support to joint procurement (at least 3 Member States) 

(f)  Quality of the implementation plan of the action 

Through the submission template provided, all proposals were directed to address all the award 
criteria evaluated for the particular topic. 

Finally, the ASAP Regulation contains specific provisions on:  

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(a)  the  Security  of  Information  (Article  17)  regarding  the  protection  of  classified 

information in relation to the implementation of the ASAP Regulation;  

(b) a Ramp-up Fund (Article 15), in the form of a blending facility offering debt solutions, 
to  leverage,  de-risk  and  speed-up  investments  needed  to  increase  manufacturing 
capacities;  

(c)  the security of supply (Articles 13 and 14) concerning (1) the acceleration of the permit-
granting process for the timely availability and supply of relevant defence products and 
(2) the facilitation of common procurement during the ammunition supply crisis. It is 
however too soon to measure the impact of these provisions on the security of supply. 

d.  Preliminary activities 

While Article 12 of the ASAP Regulation states that the Work Programme shall set out the 
funding priorities considering the work of the Defence Joint Procurement Task Force (DJPTF), 
this  DJTPF  worked  both  on  the  demand  side  assessing  what  are  the  most  needed  defence 
products and in which quantity and on the supply side, mapping the industrial actors relevant 
for urgent joint procurement needs and their associated production capacities. To address the 
ASAP objectives, the work of the DJPTF had to be complemented by activities on the supply 
side to further determine the capacity of the industry production for artillery ammunition in 
meeting the demand in the short and longer term. 

Between 15 March and 9 May 2023, Commissioner Breton visited 28 key manufacturing sites 
related to artillery ammunition and missiles’ production in 13 EU Member States (BG, CZ, DE, 
ES, EL, FR, HR, IT, PL, RO, SE, SI, SK) and the Commission conducted follow-up technical 
discussions with 36 industrial players from the EU and Norway. In addition, the Commission 
collected  information  on  the  production  capacity,  industrial  value  chain  and  potential 
bottlenecks and engaged with main actors on the type of support needed to unlock the industrial 
ramp-up of 155mm artillery ammunition.  

Exchanges with industry confirmed that the EU has substantial own production capacity (twice 
the size of the U.S. at that time)  for 155mm ammunition production within several  existing 
industrial sites. Moreover, the production capacity in the EU and Norway in 2023 was already 
significant  and  could  achieve  1  million  shells  in  2024.  However,  this  would  have  required 
targeted support and additional resources given the current observed lead time. 

The main obstacle to producing propellent powder in sufficient quantities was linked to the 
limited availability of components (energetic nitrocellulose and nitro-glycerine) and the current 
production tools capacity (mixing, extruding, packaging, etc.) as well as the limited access to 
high  explosives  to  fill  artillery  rounds.  In  addition,  the  defence  sector's  limited  access  to 
funding,  the  limited  availability  of  skilled  workers  and  regulatory  aspects,  in  particular 
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) requirements 
and local legislation on authorisations for the defence industry, were also highlighted. 

Considering  these  findings,  the  implementation  of  the  ASAP  Regulation  focuses  on  key 
identified bottlenecks that have the potential to achieve most impact on ammunition production 
across the EU, namely: 

-  High Explosives production; 

-  Propelling powders and charges production; 

-  Shells filling and manufacturing. 

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3.  Overall implementation logic of the ASAP Regulation 

The preparation of the overall ASAP programme implementation started in early July 2023, 
before  the  ASAP  Regulation  was  formally  adopted.  This  allowed  to  clarify  internally  the 
expected implementation drivers and timeline and to set-up a suitable organisation to support 
the implementation, from the Work Programme preparation, the publication and management 
of  the  calls  for  proposals,  to  the  evaluation  of  the  proposals,  and  the  preparation  and 
management of the grant agreements. 

Clearly the timeline of the ASAP implementation was the main driver, with the objective to 
have  the  Work  Programme  adopted  by  end  of  September  2023  and  the  outcomes  of  the 
evaluation announced by February 2024, while also setting up a security framework responding 
to the sensitivity of the calls. This led the Commission to make the following choices from the 
outset: 

-  The  Work  Programme  preparation  built  on  most  relevant  available  information, 
especially the findings of the Commissioner’s tour of Europe of artillery ammunition 
manufacturers and subsequent technical interactions with the industry7 (see section 2.d 
above).  These  elements  allowed  to  understand  the  state-of-play  and  dynamic  of  the 
European industrial production capacity for artillery ammunition, including the supply 
chains involved, and to identify and quantify the bottlenecks.  

-  ASAP  on-boarded,  in  record  time,  on  the  Commission  corporate  IT  tool  supporting 
funding instruments (eGrants), using the EDF set-up as the reference framework8. Even 
though the submission of the proposals was partially performed outside eGrants (due 
to  the  security  classification  level  imposed  to  some  parts  of  the  proposals),  such  an 
approach avoided to resort extensively to manual treatment of the information. 

-  Considering the heavy workload stemming from the implementation of the European 
Defence Fund, an ad hoc Task Force (TF) of Commission and its executive agencies 
staff members (following the publication of a call for interest in August), was set up for 
a duration of 6 months in order to support the evaluation process of the proposals. The 
TF  was  hosted  by  the  Commission  in  a  secured  environment  compliant  with  the 
handling of RESTREINT UE/EU RESTRICTED information.  

-  Based  on  the  experience  gained  from  the  implementation  of  the  European  Defence 
Fund, ASAP followed an optimised evaluation workflow allowing for late checks on 
some complex eligibility conditions (i.e., in-depth assessment of control ownership or 
of  some  cost  items  only  after  announcement  of  the  list  of  proposals  selected  for 
funding). 

-  All grants under the ASAP programme are implemented in the form of lump sums (i.e. 
fixed grant amount following in-depth assessment of the estimated costs of the action), 
thus simplifying the execution and management of the grant agreements. 

This preparation work, that built upon the EDF experience, was instrumental in the ability of 
the  Commission  to  deliver  swiftly,  at  each  stage  of  the  implementation  of  the  ASAP 
programme, despite limited resources. 

7 These activities addressing the supply were complementary to the activities performed within the Joint Defence 
Procurement Task Force (JDPTF) that addressed the demand side.  
8 All call documentation and templates for the implementation of the ASAP programme were adapted from the 
existing EDF ones. This was possible thanks to many similar provisions or features regarding eligibility conditions 
or funding rates (baseline funding rate + bonus). 

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4.  Work Programme and calls preparation 

a.  Implementation 

The drafting of the first  version of the ASAP  Work Programme started  in the beginning of 
August 2023 with, as the main input, the findings of the Commission regarding the bottlenecks 
in the supply chains involved in the production of heavy artillery ammunition. These findings 
followed by a series of technical meetings between the Commission and the industry9 allowed 
to identify that the main bottlenecks preventing the ramp-up of 155mm artillery ammunition 
were High Explosives and Powders mainly and, to a lower extent, Shells assembly. 

The  first  draft  Work  Programme  was  shared  with  the  newly  established  ASAP  Programme 
Committee consisting of representatives by the EU Member States and Norway (which was 
formally associated to the programme) on 18 August 2023, together with an explanatory note 
substantiating the findings of the Commission and the proposed structure and budget allocation 
for the ASAP Work Programme, in line with the identified bottlenecks in the production of 
artillery ammunitions, while also considering missiles. 

In  total,  five  Programme  Committee  meetings,  taking  place  from  31  August  to  16  October 
202310, were needed to negotiate, finalise, and endorse unanimously the Work Programme.  
The implementing act11 was adopted by the Commission on 18 October 2023. On the same day, 
the  calls  for  proposals  were  published  on  the  Funding  &  Tender  portal  and  opened  for 
submission, all call documentation and templates being available. The deadline for submission 
of proposals was set to 13 December 2023 17.00 CET. 

The main discussion points within the ASAP Programme Committee were: 

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the  structure  of  the  Work  Programme,  and  in  particular  the  number  of  topics  per 
identified bottleneck and their grouping in calls (1 call per identified bottleneck vs 1 
call per targeted type of activities); 

the  interpretation  of  the  eligible  types  of  actions  and  activities  (Article  8  of  ASAP 
Regulation), and in particular: 

o  activity  type  (a),  considering  Commission’s  initial  proposal  to  make  a 
distinction  between  topics  addressing  the  ‘establishment  of  new  production 
capacities’  (i.e.  new  green  field  infrastructure)  and  topics  addressing  the 
‘extension or upgrade of existing capacities;  

o  activity  type  (b)  on  cross-border  partnerships  and  the  link  with  the  award 
criterion (d) on cross-border cooperation (Article 11(d) of ASAP Regulation) or 
with  the  increased  funding  rate  on  creation  of  new  cross-border  cooperation 
(Article 9(2)(a) of ASAP Regulation); 

9 Tour of Europe and technical discussions with more than 36 manufacturers throughout the EU and Norway, 
complemented with a large consultation of the industry and supply chains via requests for information on current 
and future production capacities as well as surge capacities.  
10 The  interservice  consultation  took  place  from  Thursday  5  October  to  Tuesday  10  October.  The  final  draft 
implementing act was submitted to the ASAP Programme Committee on Wednesday 11 October for their scrutiny. 
The ASAP Programme Committee gave a positive opinion (consensus) on the act on the 16 October 2023. 
11 Commission implementing decision C(2023)7320 on the financing of the instrument on supporting ammunition 
production (ASAP) established by Regulation (EU) 2023/1525 of the European Parliament and of the Council 
and the adoption of the work programme for 2023-2025. 

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- 

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- 

the interpretation and proposed weighting for the different award criteria in the different 
calls and topics, which led to several adjustments in the iterative versions of the Work 
Programme; 

the interpretation and eligibility conditions for Article 9(2) of ASAP Regulation on the 
increased funding rates; 

the budget allocation for the different topics and proposed maximum EU contribution 
per project (to finance several projects per topic), as well as the proposed simplified 
approach for the baseline funding rate (35% vs 40%). 

If Article 15 of the ASAP Regulation provided for the possibility of creating a Ramp-up Fund, 
the Commission was not able to identify a fully suitable option to implement such Fund in line 
with  the  ASAP  objectives  and  its  urgent  timeline.  Indeed,  it  would  have  implied  indirect 
management  by  an  entrusted  implementing  partner  under  InvestEU12 able  to  operate  in  the 
entire Union, such as the European Investment Fund and European Investment Bank, but their 
exclusion  policies  on  ammunition  unfortunately  preclude  them  as  potential  candidates.  In 
addition, the Ramp-up Fund appeared unattractive for implementing partners due to the limited 
budget (very high administrative burden) and narrow scope of the product (limited ecosystem 
of ammunition producers and suppliers). 

b.  Lessons identified  

If the Programme Committee members largely appreciated their level of involvement in the 
drafting and approval of the ASAP work programme, several members recognised the highly 
demanding work that it required. The Programme Committee members also largely welcomed 
the  level  of  responsiveness  and  information  provided  by  the  Commission  during  the  entire 
process. 

Regarding the effectiveness of the Work Programme design to meet the objectives of the ASAP 
Regulation,  some  Member  States  contested  the  baseline  for  the  structure  of  the  Work 
Programme (based on Commission’s findings from a mapping exercise to which they consider 
not  to  have  been  associated),  thus  preventing  to  address  a  wider  scope  of  defence  products 
beyond  the  bottlenecks  identified  for  155mm  artillery  ammunition  and  missiles.  On  the 
contrary, several other Member States and the European Defence Agency recognised that the 
structure  proposed  for  the  Work  Programme  was  relevant  and  effective  in  meeting  the 
objectives of the ASAP Regulation – even though the results of projects selected for funding 
are not yet available –, and that it also allowed to accelerate some investment decisions, keeping 
also  in  mind  the  possible  retroactivity  of  ASAP  funding.  Besides,  while  the  limited  budget 
available under ASAP called for focused investments on well identified bottlenecks to produce 
a  real  impact,  targeting  Powders  and  Explosives  was  considered  to  have  positive  spillover 
effects on other types of ground-to-ground and artillery ammunition.  

Overall, the balanced design of the final Work Programme resulted from the best possible way 
to  meet  the  ambitious  objectives  set  out  in  the  ASAP  Regulation  while  considering  the 
emergency  nature  and  limited  budget  of  the  instrument.  This  allowed  in  the  end  for  the 
unanimously endorsement of the Work Programme by the Member States.  

12 Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the 
InvestEU Programme and amending Regulation (EU) 2015/1017 (OJ L 107, 26.3.2021, p. 30). 

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5.  Application process and support to applicants 

a.  Implementation  

Following the publication and the opening of the ASAP Calls for proposals on the EU Funding 
and Tenders Portal, the Commission advertised broadly the information via several channels, 
notably  the  ASAP  Programme  Committee,  information  events  organised  by  national 
authorities,  including  Sweden  and  Bulgaria,  defence  industry  expert  groups,  industry 
associations, Commission’s website13 and social media. 

The Commission received 174 questions in total and replied within 3 working days on average 
as necessary through the Q&A section of the ASAP calls for proposals accessible to all through 
the Funding and Tenders Portal to ensure transparency and equality of treatment. 

A few days after the opening of the calls, the Commission services recorded and published 
online14 an Information session explaining the background and the structure of the ASAP Work 
Programme  as  well  as  the  conditions  to  apply,  the  funding  principles  and  the  submission 
process. This was advertised via social media as well as on the Funding and Tenders Portal. 
This material was available throughout the entire submission time frame. 

The calls were open for submission from 18 October 2023 until 13 December 2023 17.00 CET, 
leaving a total of eight weeks for the applicants to prepare and submit their proposals. 

b.  Lessons identified 

Applicants and national authorities were to a very large extent satisfied with the information 
and support provided on the content of the ASAP calls for proposals.  The information  was 
broadly  acknowledged  as  clear  and  concise,  and  several  applicants  welcomed  the 
responsiveness  of  the  Commission  in  replying  to  the  questions  asked.  However,  some 
applicants  regretted that  it was not  possible to  organise  online or live  consultation  with  the 
Commission  to  clarify  some  specific  points.  The  elements  that  proved  to  be  the  most 
challenging for some of the applicants were how to describe the different cost elements and 
how to deal with security issues, in particular how to secure sensitive and classified information. 

The information package made available online, and in particular the recorded info session, 
was very well received by applicants. One of the highlighted benefits of the recorded session 
was that it gave applicants the opportunity to revert to specific sections of interest several times 
and  when  they  had  reached  that  specific  step  in  their  submission  process.  However,  some 
reported that some of the information provided was not detailed enough, especially regarding 
costs and security issues. A few applicants reported that they were not aware of the availability 
of the recorded info session but were still able to submit a proposal. Finally, several applicants 
regretted the absence of any networking and matchmaking event organised by the Commission 
(which could not be offered in the given timeframe). The Commission participated however, 
in a few information events organised by national authorities. 

One  point  outlined  by  several  parties  was  the  limited  time  applicants  had  to  prepare  their 
proposal. Even though most were fully aware that ASAP was an emergency instrument, the 
limited  application  time  of  eight  weeks  made  it  challenging  to  clarify  the  more  complex 

13 Act in Support of Ammunition Production (ASAP) (europa.eu) 
14 Slides and recording were made available on 24 October. 

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questions,  and  to  prepare  and  submit  their  proposals,  given  that  many  applicants  were  not 
familiar with applications to EU grants15. 

Overall, the participants and national authorities were satisfied with the support given during 
the submission period. The involvement of national authorities during the preparation of the 
Work Programme ensured that they also could support their industry in the preparation of their 
proposals and coordinate the necessary national contribution. The main challenges highlighted 
were the complexity of the application process, the level of coordination between applicants 
and national authorities and the very short time to submit a proposal. 

6.  Evaluations and results 

a.  Implementation 

Timing 

The evaluation process started immediately after the call closure on 13 December 2023. The 
evaluations were finalised by a positive vote of the ASAP Programme Committee on 13 March 
2024. The results of the evaluations were published on 15 March 2024 through a Commission 
press release and through the Commission website16. 

Organisation of the evaluation process 

The first step was to open the submission files of the proposals. Each proposal had two parts:  

- 

- 

the first part  contained the administrative information  as  well as the detailed budget 
table and other annexes that were not classified. This part was submitted through the 
Funding  and  Tenders  Portal  using  the  standard  forms  provided.  This  part  also 
generated the metadata needed to follow the proposal throughout the process as well as 
to register it as submitted into the corporate “eGrants” suite used for most of the EU-
funded programmes by the Commission.  

the  second  part  consisted  of  the  technical  annex,  classified  at  RESTREINT  UE/EU 
RESTRICTED  level.  It  was  submitted  either  as  an  encrypted  file  in  the  submission 
package through the portal or separately through registered mail at the latest on the day 
of the deadline, 13 December 2023. 

By the call deadline, 82 proposals were found to have been submitted across all calls. All calls 
and topics received proposals. In the call Explosives, the sum of the amounts requested by the 
proposals submitted did not exhaust the full call budget amount, meaning that there was an 
undersubscription  to  that  call.  The  remaining  budget  not  used  under  one  call,  in  this  case 
Explosives, was redistributed across other calls, Powder and Missiles. 

In a second step, the requisite admissibility and eligibility checks were performed.  

The admissibility check consisted of verifying the completeness of the proposal, and that all 
necessary and obligatory documents had been submitted on time and according to instructions. 
No late submissions could be accepted.  

15 It is to be noted that the industry community engaged in ASAP is not completely the same as the community 
participating in the European Defence Fund. 
16 The Regulation in Support of Ammunition Production (ASAP) aims at reinforcing and ramping up 
ammunition production across Europe. (europa.eu) 

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The eligibility  checks included the assessment  that the proposal  is  eligible according to  the 
requirements of the regulation, such as that the proposal was within the scope of the call. The 
scope of the call was defined in the call text published on the Funding and Tenders Portal. 

In  a  third  step,  the  proposals  that  had  passed  the  admissibility  and  eligibility  checks  were 
evaluated against the six award criteria as specified in the ASAP Regulation (Article 11).  

The proposals received a score per award criterion and the total score determined the ranking 
of the proposal. The ranking list as well as the evaluation summary reports were prepared by 
an Evaluation Committee.  

In accordance with the double comitology process set out in ASAP Regulation, the Programme 
Committee was consulted both on the draft ASAP Work Programme and on the draft award 
decision. 

The  Programme  Committee  convened  on  13  March  2024  to  vote  on  the  results  of  the 
evaluations. Due to the handling of RESTREINT UE/EU RESTRICTED material, the meeting 
was also kept at RESTREINT UE/EU RESTRICTED level. The Programme Committee gave 
a unanimous positive opinion in support of the results. 31 proposals were retained for funding 
as the result of the call evaluations. Following the positive opinion obtained on 13 March 2024, 
the applicants were informed and the results were published online on 15 March.  

ASAP  focuses  on  powder  and  explosives,  which  are  bottlenecks  for  ammunition  shell 
production. The programme will support projects increasing the annual production capacity by 
more than 10 000 tons of powder, and by more than 4 300 tons of explosives. For this purpose, 
The  Union  will  invest  EUR  248  million  in  powder  manufacturing  capacity  and  EUR  124 
million in explosives manufacturing capacity. 

There are projects that were not selected for funding (including those in the reserve list) that 
would  request  increase  of  the  ASAP  envelope  with  EUR  240  million.  These  projects, 
representing a total investment of EUR 660 million, could have added about 40% of powder 
production, more than 100% of shells and shell body production, and a substantial additional 
amount of production capacity for different missile systems. 

b.  Lessons identified 

The nature of the regulation and the scope of the calls required the submission of fully detailed 
proposals from the start. Technical proposals of (up to) 70 pages technical proposals take time 
to  process.  The  time  constraints  imposed  by  the  emergency  from  which  the  instrument 
proceeded put a significant strain throughout the process on the limited resources available.  

The  number  of  award  criteria  is  relatively  high.  Although  the  number  ensure  adherence  to 
dedicated policy objectives, it may lead applicants to lose focus on the main impact sought for 
the regulation. An alternative to many award criteria could be a clearer described scope of the 
call, and by that achieving the same policy objectives. The classified nature of the programme 
required the physical availability of staff on a quasi-permanent basis. Thanks to all Member 
States demonstrating this commitment, the final scrutiny was made possible in the timeframe 
set. 

It should also be noted that although some proposals scored above threshold, they could not be 
funded due the limited size of the available budget. The existence of such proposals, which had 
to be placed on the reserve list, shows that the programme also achieved its competitive nature. 

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These proposals received the Seal of Excellence, demonstrating that despite not being funded 
under ASAP, the project itself would have been funded had additional budget been available. 

7.  Recommendations  

Based  on  the  lessons  identified  during  the  implementation  process,  the  following 
recommendations could be made for the future: 

Drafting of the regulation 

•  Strive for clear links between policy objectives and planned activities in the regulation. 
Any action in the ASAP Regulation should be utilised to obtain the main objectives, 
and all potential applicants should be able to quickly understand how to write a proposal 
against the award criteria and what are the funding options, including bonus awards.  

•  Simplicity should guide and, to all possible extent, govern the drafting of the regulation, 
notably in terms of number of award criteria and complexity of the funding mechanisms 
(several funding rates and several possible bonuses tend to increase the challenge of 
appropriating the regulation and submitting top quality proposals). 

•  Double comitology requirements should be carefully reconsidered, taking into account 
the  potential  delay  on  the  adoption  of  both  the  Work  Programme  and  the  award 
decision, as well as the corresponding administrative burden compared to their added 
value and alternative means of coordination. 

Work Programme and calls preparation 

•  Preliminary in-depth fact-finding, and thorough knowledge of the industrial production 
capacity for a given defence product is instrumental to the identification of the most 
adequate  structure  the  Work  Programme  to  enable  the  most  efficient  focus  of  the 
investments sought on bottlenecks where the impact will be the highest. However, the 
active, upfront involvement of Member States and associated countries in the definition 
of the methodology to be used for knowledge collection and for the prioritisation of the 
defence products would be needed.  

• 

In emergency situations an expedited elaboration of work programmes is feasible but 
comes  as  a  challenge  to  the  Member  States  in  terms  of  the  time  available  for  the 
Programme Committee to scrutinise the iterative versions of the documents. 

•  Tailoring the selection and weighting of the award criteria to the different call topics is 
challenging and time consuming. This applies as well for the budget per call and topic, 
and, if any defined, the maximum EU contribution per project.  

•  Retroactivity can be useful to serve policy objectives. However, this creates extra need 
for clarifications17 and add to the complexity of the implementation, thus potentially 
resulting in additional time spent on that issue in the Programme Committee.  

Application process and support to applicants 

•  For emergency measures there is a need to strike a balance between the time used to 
elaborate  a  work  programme  and  the  time  available  for  applicants  to  prepare  their 
proposals. Consideration should also be given to the level of experience the potential 
applicants have with EU funding opportunities. 

17 Many discussions took place to clarify how retroactivity would not contradict the impossibility to fund an action 
that is already partially or entirely funded. 

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• 

Identify the most complex elements of the application file, such as financial or security 
aspects,  can  help  providing  the  requisite  level  of  guidance  on  those  elements,  for 
example in the form of recorded tutorials. 

•  Networking and matchmaking possibilities like the one offered by the annual EDF Info 
days appears to be a frequent request and can offer a combination of information given 
on work programme, application procedures and the opportunity to establish contact 
with potential partner for a proposal. 

•  Communicate via all available channels on any available guidance material to ensure 
that both work programme and application procedures are known and understood. 

Evaluations and Results 

•  Although  budget  limitations  do  not  allow  to  fund  all  proposals  evaluated  above 
threshold, the Seal of Excellence does provide a good option to certify the proposal for 
any alternative funding. 

8.  Conclusion 

The  ASAP  implementation  has  demonstrated  that  an  emergency  instrument  in  the  field  of 
industrial defence works, and that competitive calls for specific industrial needs can be put in 
place with a full publication of calls for proposals and including the regular comitology process 
as used in other similar programmes.  

The targeted industrial community, within the artillery ammunition sector, was able to respond 
on time with full proposals, and also making use of all the options in the Regulation and Work 
Programme, such as the bonus system, the different eligible activities and the retroactivity. The 
31 projects retained for ASAP funding provide for a good basis to drive towards the policy 
goals of the Regulation, and more importantly, substantially increase the production capacity 
of artillery shells and missiles, and their respective supply chains. 

In  addition,  the  sensitivity  of  the  subject  matter,  requiring  in  part  a  classification  of  the 
documents  and  processes,  can  be  used  in  this  expedited  form  of  implementation.  There  are 
nonetheless some constraints, mainly on timing and the delays given to both decision makers 
and to applicants. The implementation of ASAP has demonstrated that these constraints can be 
respected by streamlining the processes and using adequate, robust communication channels 
for communication and interaction with stakeholder, notably through the Fundings and Tenders 
Portal.  The  recommendations  contained  in  its  support  will  enable  to  improve  the 
implementation of emergency measures in future EU industrial defence programmes to secure 
industrial defence readiness and respond to a fast-evolving security paradigm in Europe. 

The ASAP Regulation is a very good demonstration of the Commission’s ability to act urgently 
and in full compliance of the legal framework. 

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