Safeguarding Supply Chains with Internal Market Emergency and Resilience Act
The current energy crisis caused by the US-Israel-Iran war serves as a reminder of how abruptly the EU Single Market can be disrupted. In these events, fragmented national responses often exacerbate the chaos, leaving businesses to navigate a patchwork of restrictions.
For a Chief Operating Officer and supply chain and logistics professionals, the lesson of the last few years is clear: in a crisis, information-sharing is essential. The objective of the Internal Market Emergency and Resilience Act (IMERA), entering into force in May 2026, is to formalise engagement between business and policymakers and must be viewed as a critical resilience tool for Irish industry.
Adopted in 2024 in the wake of the Covid-19 pandemic, IMERA is a Regulation designed to anticipate, prepare for, and respond to impacts of an emergency on the Single Market. Its primary purpose is to preserve the free movement of goods, services, and persons during emergencies, preventing the kind of costly bottlenecks and patchy implementations witnessed during previous global shocks. It establishes a framework for the secure exchange of information, monitoring of supply chains of critical importance, and the coordination of preparedness and response measures between Member States and the EU.
Crucially, IMERA is crisis-non-specific, but explicitly excludes medicinal products, medical devices, semiconductors, energy products, financial services and defence-related products. It establishes a permanent “contingency mode” for continuous awareness and monitoring of emerging threats. Information provided will be treated with respect for confidentiality and commercial sensitivity. By creating a unified EU response, it aims to replace unilateral Member State actions with responses including coordinated “green lanes” and harmonised standards, ensuring that lifelines within the European economy remain open.
At the heart of this framework is the Central Liaison Office (CLO), established within the Department of Enterprise, Tourism and Employment (DETE). The CLO serves as the direct conduit between Irish businesses and EU decision-makers coordinated by the European Commission. The CLO’s mandate is to monitor supply chains of critical importance; engage regularly with the business community for input on disruptions and shortages; and alert the EU-level liaison office when local incidents have the potential to impact the broader Single Market.
We understand the strain on businesses facing burdensome administrative requirements. However, proactive engagement with the CLO is a strategic investment. By sharing data on supply chain vulnerabilities now, companies enable the government to anticipate bottlenecks and plan responses accordingly before they become total shutdowns.
The narrative is shifting from compliance to collaborative resilience:
- Anticipatory action: Voluntary information requests during “vigilance mode” allow the CLO to identify risks to specific sectors before a crisis is officially declared.
- Protected dialogue: All shared information is treated with strict respect for commercial confidentiality and sensitivity.
- Priority and support: During an active crisis, the Commission can make “priority-rated requests” to ensure vital societal functions. Companies that accept them are compensated fairly, including opportunity costs, and are granted legal immunity for breaches of preexisting contracts necessitated by the request. Failing to comply with such a request within the agreed timeframe could lead to the imposition of fines by the Commission.
As Ireland prepares for its Presidency of the Council of the EU from July 2026, Ibec is championing an approach that makes resilience the foundation of competitiveness. We are calling for a Single Market that thinks in systems: open markets, secure supply chains, and adaptive regulation.
IMERA provides the framework, but its efficacy depends on the quality of the data provided by those on the front lines of global trade. We encourage Irish companies with European and global supply chains to reach out to the DETE CLO with ad-hoc alerts on issues they encounter. Ibec anticipates further discussions on IMERA during our upcoming Logistics and Supply Chain Skills Week in April. As much input as possible that the CLOs can get from businesses now, while still in the implementation phase, is key to developing a system of engagement that works for all stakeholders.
By moving beyond the reporting burden, your business isn't just complying with a regulation, it is helping to build a more resilient, predictable, and competitive European future.
Róisín De Bhaldraithe is an Ibec EU Policy Executive based in our Brussels office.
