The companies that build the most advanced AI models have started writing a new clause into their licences: not in Europe. Not all of them, not for every model, but the direction is clear. If it continues, European companies and public bodies will work with worse tools than their competitors, and the gap will grow every year.
What is happening
Tencent. The licence of Hunyuan 3D 2.1, released in June 2025, opens with one line in capitals: it does not apply in the European Union, the United Kingdom and South Korea. The same clause appears in Tencent's video and image models.
Meta. Its Llama models that can read images are not licensed to companies headquartered in the EU. The text-only versions are.
Huawei. According to published reports, the licence of openPangu, its largest open model, bars use inside the Union.
Apple. The new Siri launched this autumn without European iPhones, because of the Digital Markets Act, and without a date.
To be fair: most models that only write text are still freely available, DeepSeek and Google's Gemma among them. The exclusions hit mostly the models that see, generate images, video and 3D, or act as assistants.
Why they do it
For a company giving a model away for free, the European market is a regulatory risk (AI Act, GDPR, DMA) worth more than the revenue it brings. Excluding Europe is the cheapest compliance there is. One line in the licence.
It is not geopolitics. American and Chinese companies reached the same line on their own.
Why it matters to us
Italy competes on things you look at: furniture, eyewear, fashion, machinery, packaging, visual quality control. These are exactly the sectors that use image, video and 3D models.
A European company today uses the second-best model, or the right one months late, or the right one in a legal grey zone. Its competitor in the United States or Asia does not. Each gap is small. Together they compound.
What to do
List the AI models your teams use and check where each licence allows you to use them. Keep tested alternatives for the ones that exclude Europe. Put the delay in the roadmap as a number, so the board sees it.
In the 1990s the United States limited the encryption it exported: strong keys at home, weak ones for everyone else. The rule ended in 2000, but systems built on the weak keys were still being attacked in 2015.
An export edition does not expire when the rule does. Nobody is closing Europe's door. They are handing it the export edition, one licence at a time.
— Pan