Arbitration analysis; The Singapore International Commercial Court (SICC) dismissed an EU Member State's application to set aside an Energy Charter Treaty (ECT) award, comprehensively rejecting the ‘intra-EU objection’—that investor-State arbitration between European Union (EU) parties is invalid following the decisions of the Court of Justice of the EU (CJEU) in Slovak Republic v Achmea BV (Achmea) and Republic of Moldova v Komstroy (Komstroy). The court held that EU law principles of autonomy and primacy operate only within the EU legal order, not on the broader international plane, and do not bind tribunals or courts seated outside the EU. The court further held that Article 26 ECT is governed by international law and remains valid for intra-EU disputes in non-EU seated arbitrations. This decision provides crucial clarity for practitioners advising on enforcement of intra-EU investment awards outside the EU, reinforcing that strategic seat selection can effectively circumvent intra-EU objections. It also confirms that investment treaties with their own definitions of ‘investment’ need not satisfy the Salini criteria (from Salini Costruttori S.p.A. v Kingdom of Morocco, ICSID Case No ARB/00/4), and reaffirms Singapore's narrow approach to public policy challenges. Written by Colin Liew, director, Head of International Litigation at Providence Law Asia LLC.