Understanding the regulation of 5G equipment suppliers through the advocacy coalition framework

Abstract

This article explores the global political contestation over fifth-generation (5G) telecommunications regulation following the Trump administration’s 2019 executive order restricting Chinese-made equipment. In response to this geopolitical shift, two competing coalitions – one US-led and largely composed of democratic states and non-state allies, and another spearheaded by China and its partners – emerged to shape divergent global policy approaches. Drawing on the advocacy coalition framework (ACF), this article moves beyond the dominant state-centric perspective on international relations by analysing how non-state and subnational actors within these coalitions advocated competing ideas and coordinated their strategies to influence 5G regulation across borders. In analysing intra- and inter-coalition dynamics, I contend that incorporating relevant IR perspectives, namely power relations and interdependency, into the ACF offers a nuanced understanding of coalition politics in a policy context that involves complex trade-offs between security, technology, and economic interests. Empirically, I illustrate these dynamics with reference to the United Kingdom’s policy reversal on Huawei and the varied policy approaches to 5G regulation taken by European Union (EU) members. This article contributes to understanding global governance in adversarial emerging technology policy subsystems.

Fifth-generation (5G) wireless technology is poised to radically transform societies by supporting the development of robust digital economies and a wide range of remote applications. While 5G technology introduces new capabilities, it also generates new vulnerabilities. Its design architecture, such as the use of software-defined networking, can increase the chance of malicious actors exploiting software vulnerabilities to gain control over network functions (Levy, 2019). This double-edged reality has prompted governments to prioritise the security of 5G wireless networks and diversify supply chains, as these infrastructures are vital to a nation’s economy and societal functions.

Following Trump’s 2019 decision to ban Chinese-made telecoms equipment from the US 5G infrastructure, two competing coalitions emerged regarding the governance of 5G telecoms equipment. The first, a dominant US-led coalition comprising democratic states and non-state allies, advocated tightened scrutiny of 5G equipment vendors, particularly those from authoritarian states (especially China). The opposing coalition, primarily comprising Chinese governmental actors and firms, along with other state and non-state actors, advocated an alternative approach, namely balancing security needs with economic interests. The result was a nascent 5G policy subsystem (see Introduction to this Symposium) involving various policy trade-offs at the intersection of technology, security, and economics. This highly contested, high-stakes subsystem offered little room for political compromise.

International relations (IR) scholarship has primarily taken a state-centric perspective on political contestation over 5G regulation (Friis and Lysne, 2021; Moore, 2023), paying less attention to how various subnational and non-state actors (e.g. businesses) influence policy in this domain. Even when non-state actors are considered, their interactions with governments regarding 5G policy have been analysed within discrete national boundaries (Calcara, 2023; Walter and Trampusch, 2024), leaving their transnational activities underexplored. To fill these gaps, I apply the advocacy coalition framework (ACF) to explain the interactions of actors within and between the two coalitions in the transnational 5G policy subsystem. I explain how analysing policy core beliefs and actors’ agency based on the ACF can reveal the contested policy process of 5G regulation. I also show how integrating the ACF with IR perspectives – asymmetrical power relations and structural dependence among coalition members – can clarify the intricate forces surrounding high-stakes political issues. Incorporating these perspectives illuminates internal coalition dynamics, why belief-driven coalitions may fracture during policy implementation, and how conformity can be enforced. I illustrate these arguments using the United Kingdom’s policy reversal on Huawei and the varied 5G policy approaches taken by European Union (EU) members. Methodologically, this research adopts an inductive approach that analyses government policies and media reports from May 2019 – when the Trump administration decided to bar US companies from using foreign-made 5G equipment deemed a national security risk – to July 2025.

Contested 5G policy subsystem

The two distinct coalitions that emerged around transnational 5G governance after 2019 formed an adversarial policy subsystem (Weible and Sabatier, 2009), characterised by high levels of conflict and polarisation of beliefs across coalitions. Cross-coalition coordination was limited and interactions between coalitions were often viewed as zero-sum. While shared beliefs drove actions, competition for political influence extended beyond state actors to include non-state actors operating across poorly defined national boundaries. These insights from ACF research transcend realist IR traditions’ state-centric and purely materialist focus.

Within the US-led dominant coalition, policy actors included regional governments and national state actors from liberal democratic countries, lawmakers, regulators, security experts, telecoms industry groups, researchers, and media. Members shared an ideological commitment to defending liberal democratic values against authoritarian ones. These beliefs formed the deep core beliefs that ideologically unite coalition members (Nohrstedt et al., 2023). Regarding policy core beliefs, members believed that non-democratic actors (both state and non-state) would exploit vulnerabilities in next-generation wireless networks to launch cyberattacks on opponents’ infrastructure (Barboza, 2020). Therefore, this coalition advocated rigorous scrutiny or even prohibition of using 5G telecoms equipment from high-risk vendors (typically referring to Chinese firms). Furthermore, several members of this coalition, including the United States and Japan, advocated adopting Open Radio Access Network (Open RAN) to diversify 5G supply chains. The Open RAN architecture encourages a modular network design that allows for the incorporation of United States and allied firms through shared standards, thus serving as a strategy for the United States and other countries to reduce reliance on dominant integrated vendors, such as Ericsson, Huawei, and Nokia, and promote their own firms.

The opposing coalition was also diverse, with unlikely partners such as policy actors from liberal democratic countries. Its members included Chinese state actors and technology companies (notably the 5G vendors Huawei and ZTE), network security experts, telecoms lobby groups, and researchers, some from the United States and Europe. They championed the benefits of open 5G markets, arguing that exclusionary policies stifle innovation, and advocated an approach balancing cybersecurity, economic benefits, and international collaboration. To address cybersecurity concerns, they campaigned to make telecoms equipment entirely transparent for comprehensive inspections by security experts and regulators. Some research institutions from liberal democratic countries also supported this approach. For example, the Atlantic Council, a non-partisan Washington think tank, criticised the ‘just say no’ approach of the dominant coalition, which compelled firms and countries to forfeit lower-cost, competitive telecoms equipment (Watts, 2020).

According to the ACF, members must demonstrate joint efforts to influence the policy process to qualify as an advocacy coalition. Each of the coalitions under study sought to frame policy issues and articulate unified messages in ways that contested the narratives of the opposing coalition. In the US-led coalition, policy actors emphasised the technical vulnerability of 5G infrastructure and potential cybersecurity threats from Chinese vendors. In a hybrid technological-security regime like 5G, expert knowledge is explicitly used to legitimise coalition narratives. Thus, experts are not mere information providers but active members of coalitions who shape policy discourse within technical regimes. Intelligence experts advocating a ban on Chinese 5G vendors to avoid the threat of cyberespionage included John Bolton, former US National Security Advisor (Barboza, 2020), and Christopher Wray, former FBI Director. Adam Segal, a cybersecurity expert, warned that 5G infrastructure makes it hard to separate the core network from the periphery, presenting a different type of risk from that posed by 3G and 4G networks (Berman et al., 2023). These expert perspectives were included in policy documents during the focal period, warning that the unrestricted use of critical technology developed by entities controlled by foreign adversaries will pose national security threats (US White House, 2019).

European policy actors also issued public statements, lobbied legislators, and used media platforms to shape international discourse. They produced consistent messages about the China threat. Norbert Röttgen, chair of Germany’s Foreign Affairs Committee, argued that the German government’s insufficiently stringent policy on Huawei risked compromising the country’s digital security (Posaner, 2019). He was echoed by UK members of parliament such as Tom Tugendhat and Iain Duncan Smith, who formed lobbying groups to raise concerns about China’s increasing influence (Da Gama and Bui, 2024).

The opposing coalition also demonstrated coordinated advocacy against the US-led narratives. Huawei and its close business partners, telecoms operators in several countries, advocated open markets for 5G, arguing for a risk-based approach that assesses vendors based on ‘verifiable facts and technical data’ (AFP, 2019), instead of an exclusionary policy based on nationality. Prominent business figures issued public statements to align with the open-market stance. Media reports suggested that amid heated debates about cybersecurity risks from Huawei, Germany’s Deutsche Telekom and Huawei had reinforced their working relationships, with Deutsche Telekom executives describing Huawei as a ‘strategic partner’ and Huawei labelling Deutsche Telekom a ‘preferred customer’ for the company (Cerulus, 2020).

The competing advocacy efforts of the two coalitions shaped 5G governance policy. US diplomatic initiatives led to multilateral efforts to exclude high-risk vendors. Over 60 countries, including North Atlantic Treaty Organization (NATO) and EU members, and 200 telecoms companies joined the Clean Network Initiative to support building a clean network with only trustworthy suppliers (US Department of State, 2020). Meanwhile, business technical experts, trade groups, and telecoms operators argued that a ban would raise costs and delay 5G rollout (Walter and Trampusch, 2024). Their advocacy efforts led to political compromises, with some governments agreeing to gradually phase out Huawei equipment instead of implementing an immediate ban to address business concerns (Reuters, 2022). The competing views and lack of consensus may have contributed to the German government’s delayed decision in 2024 to exclude Chinese vendors from its critical network (Von der Burchard et al., 2024). Germany took 5 years to make this decision, despite US pressure.

Problematising contestation and internal coalition dynamics

The ACF has been criticised for assuming that shared beliefs naturally lead to coordinated strategies to pursue common goals (Schlager, 1995). This assumption overlooks contestation among coalition members. Here, I illustrate how intra-coalition fractures can be better explained by considering the attributes of the transnational 5G subsystem, asymmetrical power relations, and dependencies among coalition members.

Reversal of UK policy on Huawei

After banning Chinese telecoms suppliers from the US national network in May 2019, the Trump administration urged security allies to take the same approach to mitigate cybersecurity risks. Australia, Canada, New Zealand, and several European countries tightened their regulations on wireless equipment vendors, particularly high-risk vendors linked to authoritarian states. In January 2020, in contrast, the UK government introduced a two-tier system allowing Huawei equipment to remain in the United Kingdom’s non-core 5G network but not in sensitive core segments (Steward and Sabbagh, 2020). This arrangement permitted Huawei to continue supplying the United Kingdom’s 5G network, although in a much-restricted capacity.

However, this decision was short-lived. In July, the government reversed course, requiring British telecoms companies to remove Huawei equipment from the country’s 5G network by the end of 2027 (Reuters, 2022).

This policy reversal reveals the theoretical strengths of the ACF and how the framework can be strengthened to explain intra-coalition dynamics. According to the ACF, technical experts can reinforce or challenge prevailing policy discourses. Before the United Kingdom’s policy reversal on Huawei, experts at the National Cyber Security Centre (NCSC) had conducted cybersecurity risk assessments and persuaded lawmakers that Huawei equipment posed no additional risks of systemic breaches (UK Science and Technology Committee, 2019). According to this narrative, the United Kingdom’s robust security mitigation framework and Huawei’s ability to meet compliance standards provided a strong technical argument against the proposal to ban Huawei. These assessments influenced the United Kingdom’s January 2020 decision to allow Huawei to partially continue participating in the United Kingdom’s 5G network. Scientific and technical knowledge production and dissemination play an important role in mediating policy processes – a key insight of the ACF.

The structure of the focal policy subsystem and the power dynamics among coalition members are crucial areas in which the ACF can enhance analysis of intra-coalition dynamics. Security, economic, and supply-chain interdependence shaped the relationships among coalition members. A coalition’s dominant actor could leverage this interdependence to ensure compliance from other members. When the United States unilaterally restricted Huawei’s access to US technology in May 2020, this domestic policy disrupted Huawei’s supply chains, with international consequences. Lacking access to US technologies, the company had to rely on other (likely Chinese) suppliers for its components. According to the NCSC, this altered the security risks to which UK networks were exposed (UK NCSC, 2020). The United States’ unilateral action on Huawei thus necessitated a shift in the United Kingdom’s assessment of the company and, relatedly, the potential for cybersecurity risks.

Interdependence also allowed a coalition’s dominant actor to use threats to compel compliance from non-cooperating actors. The United States warned members of the Five Eyes intelligence-sharing alliance (comprising Australia, Canada, New Zealand, the United Kingdom, and the United States) to exclude Huawei from their national 5G networks or face restrictions on their intelligence-sharing arrangements with the United States (Brewster, 2019). Furthermore, it was reported that the United States used trade deals between the two countries to pressure the United Kingdom to adopt stricter measures on Huawei (Macias, 2020). In other words, misalignment with the US agenda would increase the United Kingdom’s economic and security costs.

The US–UK disagreement over Huawei demonstrates how policy coordination within the dominant coalition was eventually achieved through asymmetrical interdependence, based on unequal power relations. The United Kingdom depended more on the United States for security guarantees and intelligence sharing than vice versa, giving the United States more power to shape actors’ behaviour.

Accordingly, the ACF’s insights into intra-coalition dynamics can be enriched by integrating IR perspectives on power relations, notably asymmetric interdependence, leverage, and coercion. Such integration enhances the framework’s capacity to accommodate intra-coalition dynamics, particularly fractures within coalitions and the management of these tensions to achieve coordinated outcomes. Power-centric IR theories and the ACF can also be synthesised to understand the asymmetric power relations inherent in the focal policy subsystem. In the context of 5G, where supply chains are complex and transnational, changes occurring in one segment can alter opportunities and threats faced by other actors. Actors that control key technologies and processes (such as the US technology used in Huawei equipment) can exert greater influence over coalition members with limited room for manoeuvrability.

Variegated policy implementation in the EU

The advocacy efforts to regulate 5G suppliers resulted in both regional and international policy changes. The EU introduced a set of recommendations for members to tighten restrictions on 5G vendors; however, member-states differed in their actual policies on Chinese vendors. According to the ACF, secondary beliefs vary and not all coalition members are equally loyal; peripheral members tend to show less allegiance (Weible et al., 2010). To strengthen this conceptual development, I contend that the heterogeneity in policy across EU members can be more comprehensively explained by examining coalition members’ differing levels of dependence on critical resources. Such structural dependency on vital resources underlies intra-coalition dynamics in adversarial and highly competitive policy subsystems.

In 2020, the EU issued its 5G Security Toolbox, a non-binding policy document identifying standard measures for member states to mitigate cybersecurity threats to 5G infrastructure (European Commission, 2020). Specifically, it recommended that member states impose restrictions and exclude high-risk suppliers from critical networks. However, EU member states adopted different regulatory approaches to Chinese 5G vendors, from blanket exclusions and tightened risk-based assessments to open-door policies (Table 1).

Table 1.

EU countries’ policies on regulating 5G suppliers as of July 2025.

Policy	EU member state(s)
Blanket ban on participation of Huawei and ZTE in 5G networks	Germany (from July 2024), Estonia, Romania, Sweden
Blanket ban on participation of non-EU, NATO and OECD suppliers in 5G networks	Portugal
Restriction of participation of high-risk vendors, without specifying companies or their origins; increased vetting of suppliers	Belgium, Croatia, Czechia, Denmark, Finland, France, Germany (before July 2024), Greece, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Slovakia, Slovenia, Spain
No specific regulation on Chinese or high-risk vendors	Austria, Bulgaria, Cyprus, Hungary

Source: Strand Consult (2025) and media reports; compiled by author.

Within the coalition advocating for stricter regulation of 5G suppliers, policy alignment was moderated by members’ varying structural dependence on critical resources, which is essential for achieving national goals. In the 5G subsystem, these resources include access to vital technology for economic development and protection through multilateral security cooperation.

A successful 5G rollout is essential for economic development. Countries less capable of diversifying their supply chains beyond dominant Chinese vendors – which provide high-quality, cost-competitive products – have less room for policy manoeuvring. Countries with access to alternatives and willing to bear higher material costs tend to take more decisive actions against Chinese vendors. Dependency on critical technology is weighed alongside reliance on security protection provided by a leading member and its broader alliance network.

I illustrate this argument by examining the contrasting cases of Sweden, Germany, and Hungary. Sweden – a long-standing US ally and signatory to the US-led Clean Network Initiative – was the first EU member to ban Huawei and ZTE from its national infrastructure, clearly stating that Chinese vendors pose security threats. Both Sweden’s deep integration into the US-led NATO security alliance and its fewer barriers to finding alternatives to Huawei due to its home-grown 5G equipment maker, Ericsson, probably influenced its swift decision on Huawei.

Before July 2024, Germany took a balanced approach to 5G regulation (Cerulus, 2022). On the one hand, it avoided banning Huawei and Chinese vendors; on the other, to align with the US-led coalition’s broader policy orientation, it increased security vetting of all 5G vendors to mitigate security risks. This stance represented a temporary political compromise between those advocating bans and those supporting risk-based assessment on a case-by-case basis. Germany is a core member of the US security alliance; like Sweden, it is deeply integrated into the US security network. In contrast, however, Germany’s dependence on the United States during the focal period was countered by its strong trade ties with China and the domestic business lobby for Huawei (Starrs and Germann, 2021). In July 2024, Germany announced that all critical Huawei and ZTE equipment would be removed from its 5G network by the end of 2029 (German Federal Ministry of the Interior, 2024), probably influenced by continued US pressure on Germany to safeguard network resilience for multilateral military collaboration. However, a strong pro-Huawei business lobby in Germany could have influenced this delayed ban on Huawei.

Hungary represents a peripheral member of the US-led coalition. By the end of the focal period, it has yet to adopt the recommendations of the EU toolbox. Huawei continues to operate within Hungary’s 5G network. Hungary’s divergence from EU security norms is attributable to the country’s strong reliance on China. The country has deepened its infrastructure and development projects by actively participating in China’s Belt and Road initiative. Hungarian ministers have consistently stated that they see no evidence of security threats from Huawei and framed cooperation with Huawei as central to the country’s development (Szakacs, 2019). China-sourced technology represents 62% of Hungary’s 5G infrastructure (Strand Consult, 2025). Given such strong dependence, unfriendly policies towards Chinese firms would incur insupportable economic and political costs for Hungary.

A country’s stage of development and dependence on the resources provided by key members of the opposing coalition explain the diverse policy approaches observed. Recognising these dynamics has implications for coalition stability. To maintain cohesion, coalitions should allow some flexibility in policy implementation to suit individual states’ different developmental needs and levels of structural dependence on strategic resources.

Conclusion

I apply the ACF to examine two competing advocacy coalitions in the highly contested 5G governance domain from May 2019 to July 2025. The ACF provides valuable insights into how the coalitions’ shared beliefs and coordinating strategies shaped the policy process. Expert knowledge played a crucial role in generating and contesting discourses within a technology-security subsystem, although fractures were common. Integrating the IR perspectives of asymmetrical power relations and material structural dependence enriches the ACF’s analysis of intra-coalition dynamics. These perspectives help explain why belief-driven coalitions can fracture on policy implementation, especially when the scrutinised entity is a powerful international player (Huawei/China). A dominant actor in a coalition with control over resources can alter threats to and costs for other members. Coalition members’ material dependencies on internal and external actors shape their secondary beliefs and intra-coalition contestation. Rather than simply responding to open opportunity structures, as the ACF emphasises, members’ agency is often constrained by structural dependence. The transnational context may necessitate policy heterogeneity, while conformity can be imposed by a powerful actor, particularly in situations of asymmetrical interdependence. Incorporating power relations and interdependency into ACF theory offers a more empirically grounded account of coalition politics in a policy context that involves complex trade-offs between security, technology, and economic interests.