The following comments were submitted on the 2nd of June 2026 to the European Commission’s call for feedback on the Industrial Accelerator Act proposal. This initiative aims to speed up the decarbonisation of industry through streamlined permitting, targeted funding, and improved regulatory predictability, thereby fostering EU competitiveness and the deployment of clean technologies.
Summary of the position
- The IAA is a necessary demand-side complement to EU ETS and CBAM, helping create lead markets for low-carbon materials and strengthening Europe’s clean industrial base.
- The IAA needs to prioritise genuine EU value creation and avoid risks for integrated supply chains and increasing administrative burden.
- Lead markets must be more ambitious to work: binding EU-wide mandates for low-carbon steel, aluminium and cement need higher targets, clear scope, and predictable phase-ins to unlock investment and avoid penalising first movers.
- Definitions matter: weak definitions of “low-carbon” materials (e.g. steel) risk classifying conventional production as climate-aligned and undermining the transition to near-zero solutions.
- ‘Made in Europe’ rules must accelerate, not slow, the transition: local content requirements should be gradual, sector-specific and carefully designed to protect competitiveness without delaying deployment of clean technologies.
Introduction
The European Commission’s proposal as Industrial Accelerator Act (IAA), is positioned as a cornerstone of the emerging Clean Industrial Deal. IAA establishes a framework to accelerate industrial capacity and decarbonisation, strengthen European clean-technology manufacturing, and reinforce the EU’s long-term economic resilience and competitiveness.
The IAA signals a decisive shift toward a more EU-centred industrial and trade strategy that integrates climate policy with industrial competitiveness. CLC sees the IAA as a necessary demand side tool to complement carbon pricing (supply of low-carbon solutions) and CBAM (level playing field).
Industrial Accelerator Act includes several policy instruments:
- Union content (‘Made in Europe’) criteria for strategic industrial value chains, especially in net-zero technologies.
- Lead markets to boost demand for low-carbon products (steel, aluminium, cement).
- Rules for foreign investments aiming to increase value for Europe from those investments.
- Industrial manufacturing acceleration areas to speed up permitting.
CLC welcomes the proposal of creating lead markets for low-carbon products from heavy-industry sectors, namely steel, aluminium and cement. Lead markets are essential to provide consistent demand-signal to markets and secure necessary investments for industrial decarbonisation.
Our recommendations:
- Boosting demand for clean materials requires more ambition for lead market creation
- Ensure that ‘Made in Europe’ rules boost deployment of net-zero technologies, instead of slowing down transition
Boosting demand for clean materials requires more ambition and clarity
Lack of demand has been one of the key factors limiting the growth of markets for low-carbon materials and products. CLC supports the idea of establishing lead markets for strategically important low-carbon materials and net-zero technologies.
Binding EU-wide mandates for low-carbon products are essential because they create the large, predictable demand base needed to scale the market. Without clear demand signals, investment in new capacity remains too risky and fragmented. This is recognized by the EU Clean Industrial Deal which says it clearly: “Businesses will only make the necessary investments if they are sure there is a market for their products.”
The IAA proposes the use of public procurement and other public support schemes to drive demand for low-carbon aluminium, steel, and cement. Proposed low-carbon mandates are 25% for steel, 5% for cement and 25% for aluminium and their real scope is still unclear. While the direction is right, there is a lot of unclarity about criteria, scope, exemptions and phase-ins. Final legislation needs to be clearly defined and targeted.
- Ensure ambitious enough but realistic targets for low-carbon material mandates to provide strong enough market demand signal.
- Clarity is needed about exact criteria and scope of proposed mandates to ensure that material-using sectors have legal and operational certainty in a way that requirements do not harm the competitiveness of the European export companies compared to their non-EU rivals.
- Gradually phased-in and updated targets should be considered as rigid targets with big jumps are challenging for both material users and producers.
- To deliver reliable demand effect and investment certainty, targets must be material‑specific, aligned with technological maturity, and regularly updated to reflect progress. It must also be ensured that targets increase gradually to expand demand rather than staying flat for years before making big jumps to the target level. Experience from other sectors like sustainable aviation fuels (SAF) show that this penalizes first-movers, holds back investments and increases political uncertainty.
In the Commission proposal definitions for low-carbon materials eligible lead market mandates are still unclear as they will be defined through Ecodesign for Sustainable Products Regulation (ESPR) and Construction Products Regulation (CPR) delegated acts.
- Ensure that low-carbon material definitions (for example low-carbon steel) are ambitious and drive demand for near-zero emissions solutions.
- Low-carbon steel definition proposed by JRC is weak and would classify conventional European fossil-based steel as “high performing”. This kind of weak classification does not incentivise investments to decarbonisation.
CLC sees the Commission proposal as a framework that can – based on impact assessment – expanded in coming years through covering additional sectors. The European Parliament and Member States should analyse if for example inclusion of recycled plastics mandate for construction plastics would be meaningful already at this stage. Upcoming Circular Economy Act and Revision of the Public Procurement Directive are considering similar issues around lead market creation. Alignment between these files is important to avoid conflicting and unclear legislation.
Ensure that ‘Made in Europe’ rules boost deployment of net-zero technologies, instead of slowing down transition
The IAA aims also to protect European net-zero and automotive supply chains through Made in Europe rules for public procurement, auctions and other support schemes.
European cleantech industries have been widely worried about a new ‘Photovoltaics moment’ where thriving, innovative European industry is quickly undermined by unfair, state-subsidized competition. The EU’s cleantech is facing a double shock – strong Chinese competition fuelled by overcapacities and technological innovation, at the same time with stagnating demand in the US due to Trump’s abrupt policy reversal.
Low-carbon industrial products and emerging cleantech companies in Europe require a robust domestic market protected from unfair competition. At the same time, it’s important to recognise that value chains of net-zero technologies (i.e. battery storages, wind power, electrolysers) are global and risking them should be avoided.
When implementing ‘Made in Europe’ criteria and enhancing resilience criteria for net-zero technologies deemed strategic and needed for transition, there is a need to address three concerns.
- First, certain industries and value chain segments exposed to international competition or a very price sensitive demand may fear the ‘inflationary’ pressure on costs local content requirements create. Sourcing EU-made equipment may command a premium compared to equipment coming from countries which maintain distortive non-market policies and practices. In most cases it will be important to assess how manageable that premium could be and how fast it may come down overtime, particularly for clean technologies with a proven cost reduction potential.
- Second, building localized production capacity for net-zero energy technologies at scale may not be sufficiently fast to meet European demand and substitute for non-EU imports. This is why the introduction of local content requirements may need to be gradual and based on a valuation of potential economic impacts with a granular assessment per value chain recognizing that there might initially be some inflationary effects that need to be evaluated against economic resilience arguments and security elements.
- Third, some value chains rely on imported components that cannot be replaced with European alternatives. Overall, a pragmatic ‘Made with EU’ model recognising trusted partners is necessary.
In further preparation of the Act, it must be ensured that its application does not slow down Europe’s transition towards the net-zero target. A domestic-content requirement may lead to higher costs and, consequently, to slower deployment of energy technologies that are essential for the transition.
In conclusion, the IAA can become a cornerstone of Europe’s clean industrial transition if it sends a strong, credible demand signal, prioritises genuine EU value creation and avoids design choices that slow deployment. Ambitious lead markets and carefully designed ‘Made in Europe’ rules are essential to align competitiveness, resilience and climate ambition.
Read the full position as a pdf below.
