Christina Renner

A further focus of her practice is on EU cross-border trade issues, including EU sanctions, export control, and tariffs. This includes assisting companies to navigate restrictions to trade within the EU’s internal market that affect the sale of their products or the supply or end of life of their products and services.

With over 20 years of practice in Brussels, Christina also has an established EU regulatory practice that spans from traditional to virtual networks across a variety of industries, including energy, telecommunications, transportation, retail and ecommerce.

In the telecoms and digital space, she regularly advises on key EU legislation that is equivalent, foreshadowing, or reacting to US or global legislation, such as EU 5G, EU Cybersecurity (EU Cybersecurity Act, NIS 2 Directive, EU Cyber Resilience Act), EU Data Management rules (EU Data Act, DMA, DSA, Data Governance Act), and EU tech and digital regulation (EU AI Act, EU Chips Act).

Her energy and environmental, social, and governance, (ESG) practice encompasses key EU legislation addressing issues common to both sides of the Atlantic and other jurisdictions, such as the key pieces of the EU’s Green Deal: the EU’s Emissions Trading scheme (ETS), Voluntary Carbon Emission Mechanisms (VCMs), carbon emission offsets, the EU’s Cross Border Adjustment Mechanism or CBAM (the World’s first carbon border tax), the EU’s Critical Raw Materials Act, and the EU Battery Regulation. EU ESG rules covered by her practice are notably the EU’s Supply Chain Directive (CSDDD), the EU’s Forced Labour Act and the EU Deforestation Regulation, as well as EU funding instruments, such as the EU’s Net Zero Industry Act (NZIA) or the EU’s International Projects of Common European Interest (IPCEIs).

Before joining Morgan Lewis, Christina was a partner in and head of the Brussels office of a French boutique law firm. She is fluent in German, English, French, Spanish, and Italian, with a working knowledge of Dutch.

Mergers and Acquisitions

• Representing Apollo in merger and FDI proceedings related to the sale of advanced magnetic solutions provider and producer of rare-earth permanent magnets Vacuumschmelze to ARA Partners
• Representing Apollo in multijurisdictional merger and FDI proceedings related to its majority stake acquisition in the Chapter 11 restructuring of enterprise communications provider Avaya 
• Represented a British multinational pharmaceutical company in the French FDI filing related to the acquisition of a portfolio of generic drugs from another French multinational pharmaceutical company, including the negotiation of conditions with the French Ministry of Economics in a Phase II
• Representing EQT in multijurisdictional FDI proceedings related to its €6.8 billion acquisition of Asian private equity house BPEA, the largest-ever takeover of a private equity firm by another in the sector
• Advised on the acquisition of a French steel manufacturing company, which required French and German FDI filings and required negotiation of commitments with the FDI authorities in both jurisdictions
• Representing ABC Technologies in the German merger filing for the acquisition of Continental Automotive GmbH’s washer business 
• Representing Apollo in merger filing proceedings for its $6 billion acquisition of global distributor of technology products and solutions Tech Data Corporation and subsequent sale to SYNNEX 
• Representing McGraw Hill in merger filing proceedings in relation to the acquisition of competitor business Cengage and coordinating multijurisdictional merger filings
• Representing Digital Colony in merger proceedings before the EU Commission relating to its $14.3 billion acquisition (jointly with EQT Partners) of fiber network owner Zayo Group Holdings Inc
• Representing Heritour Ltd. in multijurisdictional merger filings in relation to the acquisition of Abercrombie & Kent Ltd
• Represented CMA-CGM in merger control proceedings before the European Commission, which was cleared at the end of Phase I with commitments, as well as coordinated a dozen related international filings
• Represented AirFrance in the sale of its catering business to a Chinese conglomerate in merger control proceedings before the European Commission and other national competition authorities (Ukraine, Brazil, COMESA, Kenya)
• Represented PernodRicard in merger control proceedings before the German Federal Cartel Office in its sale of two brands to a Swedish buyer; case was cleared after a detailed Phase II investigation

Antitrust

• Defending a global industrial equipment company against refusal to supply and discriminatory pricing claims under French and EU rules on abuse of dominant positions 
• Representing a pharmaceutical company in relation to a dawn raid and ensuing European Commission antitrust investigation
• Regularly advising a large French consumer goods manufacturer on EU competition rules
• Advised CMA-CGM in a price-signaling investigation before the European Commission; ultimately settled by commitments
• Represented Orange Poland in proceedings before the European Commission concerning an alleged abuse of dominance on the wholesale broadband markets in an Eastern European member state
• Submitted complaints to the European Commission on behalf of new Austrian entrant WestBahn against Austrian incumbent ÖBB for failure to correctly implement the EU railway regulatory framework, as well as violation of state aid rules and abuse of a dominant position, resulting in the opening of European Commission infringement proceedings against Austria

EU Trade & Sanctions

• Advice to a European cloud, data infrastructure, and AI solutions operator on compliance EU and member state import/export control rules regarding encryption products and services
• Advising a US financial services company on licenses from Belgium for unfreezing funds for their clients under EU sanctions rules
• Providing training on financial sanctions to a European banking institution
• Advising a non-EU joint venture on rules of origin for EV batteries for the import into the EU and their reexport to non-EU countries, such as the UK
• Defending the European subsidiary (including before EU sanctions authorities) of a non-European company against EU sanctions violation claims that could have led to its exclusion from European markets
• Advising a third-country importer of nuclear material on import/export control issues in relation to a cooperation agreement with a Belgian entity
• Brokering a common understanding between various German import control authorities on import control derogations for an American entity to import certain controlled materials for research into the EU via Germany (and subsequently other EU member states)
• Advising a Franco-Belgian entity on conducting business in the Republic of Congo and North Korea in relation to EU sanctions
• Advised a US private equity investor regarding the EU aspects of investments in assets subject to US sanctions against Iran
• Advised a French aerospace parts supplier on compliance with EU-Russia trade sanctions

EU Regulatory (Telecoms and Digital Markets Regulation)

• Representing several non-EU and EU companies in procedures before the EU Commission against disproportionate technical regulations contained in member state laws for products marketed in the European Union 
• Advising a non-EU online trading company and online platform on the applicability of the EU Digital Services Act to its business operations and handling of related requests from contractual counterparties
• Advising a telecommunications infrastructure supplier on liability for system vulnerabilities under EU rules
• Advising a non-EU online portal supplier on structuring its targeted advertising under the EU’s DMA, the EU’s DSA, and the new EU AI Act
• Advising an Asian multimedia company on the requirements for a child-protection tool under the EU’s DMA, the EU’s DSA, and the new EU AI Act when rolling out its software portal in the EU
• Assisting an IT service management company in registration with a Polish telecommunications regulator and follow-up procedures with the Polish telecommunications regulator
• Advising multiple clients on the progress and substance of the legislative process and practical implementation of EU telecoms and digital markets regulation, such as the Digital Markets Act, the Digital Services Act, the Artificial Intelligence Act, the Data Act, the Data Governance Act, the Cyber Resilience Act, the NIS2 Directive, the Cyber Security Act, and the EU Chips Act
• Advising a major non-EU telecommunications company on privacy and cybersecurity rules; in particular, the correct implementation of the NIS2 Directive in various EU member states with an impact on market access to and business operations within the EU internal market
• Advising a major non-EU company in proceedings before the European Commission against rules in certain member states excluding them directly or de facto from certain member states’ markets 
• Advising on consumer protection clauses under EU rules accompanying the expansion of a US company’s sales operations to the European Union

EU Regulatory (Energy and ESG) 

• Advising a US multinational finance corporation on the EU carbon emission aspects of several long-term agreements to purchase more than $200 million in carbon dioxide removal (CDR) services
• Advising a US aerospace company on compliance with the EU’s new carbon border tax (CBAM) for imports of aluminum and steel from own non-EU production sites as well as from non-EU suppliers
• Advising a US industrial manufacturer on compliance with the EU’s new CBAM for own imports and vis-à-vis their EU customers
• Assisting a global environmental nonprofit organization in a research project concerning environmental protection in the EU and the prevention of “greenwashing claims”
• Advising a US plastics and adhesives company on compliance with the EU’s Supply Chain Act (CSDDD) and the Deforestation Regulation
• Advice to emerging jurisdiction governments in a team led by the US Department of Commerce on the development of a legal framework for a national carbon market

EU State Aid and Foreign Subsidies Regulation (FSR) 

• Advising the European and US subsidiaries of a Japanese company on the possibility to bring a claim against foreign subsidies granted to its competitors
• Advised a multinational software company on establishing a due diligence process related to foreign subsidies
• Advising a Japanese-owned Belgian company in preparing a notification under the Foreign Subsidies Regulation in the context of its bid in EU public tenders in France, Germany, and the Netherlands
• Advising multinational company on the rollout of a foreign subsidies due diligence module
• Complaint before the European Commission for a German advanced materials manufacturer against state aid awarded to its competitor by the Estonian government
• Advice to a Western European Renewable Energy Producer on the compatibility of state-backed financing of a large renewable asset with EU state aid rules
• Assisting the European Commission Legal Service in the litigation before the European Court of Justice brought by a myriad of companies against the EU Commission’s decision to open a formal procedure against Germany’s Renewable Energies Act for potential violation of EU state aid rules

Litigation

• Defended a pharmaceutical company against antitrust and other general claims brought before the European General Court
• Represented General Cable in its appeal before the European Court of Justice against the ruling of the European Court upholding the European Commission’s decision to fine the company for its alleged participation in the power cables cartel
• Assisted the European Commission’s Legal Service in several proceedings before the European General Court regarding the opening of a formal state aid procedure against the German Renewable Energies Act 
• Represented French private equity house Wendel Investissements as intervening party in support of the European Commission against the actions brought by Odile Jacob in the context of the Lagardère/Natixis/VUP merger saga
• Represented Orange Poland before the European General Court in its appeal against the European Commission’s decision to fine the company for an alleged abuse of dominance on the wholesale broadband markets in an Eastern European member state
• Represented major French banks before the European General Court in an action for annulment against a decision of the European Central Bank in the area of financial regulation