Make Europe Build Again – The EU Industrial Accelerator Act

Kamran Zaheer provides an insight into the anticipated “Industrial Accelerator Act (IAA)" and whether it will result in a “Made in Europe” regime.

On 4^th March 2026, the European Commission is expected to table a proposal titled the “Industrial Accelerator Act (IAA)”. The IAA is an EU industrial policy measure aimed at accelerating the build out of clean industrial capacity and reducing strategic dependencies in key net-zero value chains. In practice it is expected to do this by setting a framework for how the EU uses public levers, particularly procurement and public support schemes, to steer demand towards European supply.

The point is straightforward: the EU wants more clean-tech manufacturing and more of the supply chain located in Europe, and it is increasingly willing to use public procurement and public funding to push the market in that direction.

For those across the pond, the anxiety is simple, this may become a “Made in Europe” regime – whether through explicit local content requirements or softer “resilience filters” that end up favouring EU Production. UK manufacturers and suppliers’ risk being edged out of a huge market at precisely the moment the EU is spending heavily on clean energy, grids, industrial decarbonisation and net zero technologies.

In the near term, the most obvious “Made in Europe” candidates are the technologies being talked about publicly: batteries, solar, wind and nuclear. But the effects won’t stop there. If EU content requirements attach to major publicly funded projects, they ripple through supply chains: grid components, electrification kit, industrial decarbonisation packages, and specialist engineering services that sit behind the “headline” technology.

The scale is material. The EU remains the UK’s biggest trading partner. In 2024, UK exports of goods and services to the EU totalled £358bn (around 41% of all UK exports), while imports from the EU were £454bn (about 51% of the UK total).

EU public authorities spend over €2 trillion a year on goods, works and services (around 14% of EU GDP), so even a targeted “European preference” mechanism in clean-transition sectors can move real money and reshape supply chains.

What is the EU seeking to achieve?

The Commission’s Clean Industrial Deal frames the core objective as “industrial decarbonisation at speed” delivered through a mix of cheaper clean energy, investment mobilisation, demand creation for low-carbon products and the de-risking of supply chains. The EU is of the view that decarbonisation and competitiveness must be pursued together.

The Commission’s Clean Industrial Deal communication frames an industrial strategy anchored around two linked sets of industries: energy-intensive sectors (the backbone materials the economy runs on) and clean-tech manufacturing and deployment (the kit needed for electrification, renewables, and industrial decarbonisation). It also emphasises the objective of reducing “strategic dependencies” in critical value chains.

What “Made in Europe” may means in a Tender

“Made in Europe” requirements will not necessarily state that foreign suppliers are excluded. In practice it may show up as gates, scoring, and delivery obligations that make EU-based value creation a commercial prerequisite.

Eligibility

Public procurement or funding rules may require, for example, that a project is only eligible for support if X% of key components are produced/assembled in Europe, or that “critical components” meet EU-origin or EU value-added thresholds. Non-qualifying bids may be treated as non-compliant and rejected. For UK suppliers, the effect is simple: a bid may be cheaper and technically stronger and still not be in the competition unless it can evidence EU value-add (often implying EU assembly steps or EU supply chain substitutions)

Award scoring

Where suppliers are not excluded outright, EU industrial policy may be embedded into evaluation. Bids may score higher for EU manufacturing footprints, EU-based servicing/spares capability, supply chains anchored in Europe, or “resilience” scoring that favours short lead times and reduced exposure to single-country dependencies. This is often the more politically palatable route: the tender remains “open”, but the scoring makes EU-based value-add the easiest way to win.

Funding

Many clean-transition projects rely on subsidies, auctions, grants or consumer incentives. These schemes may embed EU-content or resilience thresholds as conditions of eligibility, shifting market demand even where procurement rules remain formally open.

All three levers above do broadly the same thing, they convert industrial policy into procurement obligations. UK suppliers will likely not be “banned” from competing, they may be outscored, disqualified or forced to relocate value-add to stay in the race.

The Legal Friction

The EU may insist it can do this whilst respecting its international obligations, and that claim will likely be tested.

Under the WTO Agreement on Government Procurement (GPA), offsets, including domestic content requirements and similar localisation conditions, are prohibited for covered procurement. The UK is a GPA party and has procurement commitments with the EU through the broader UK–EU legal framework for market access.

The argument is likely to turn on how measures are drafted:

• A blunt origin threshold in covered procurement is harder to defend.
• A regime framed as “resilience” or “sustainability” criteria may be argued to be permissible if it is genuinely non-discriminatory and linked to contract performance – although it can still be challenged if it functions as a proxy for origin.

The Commission’s own language already signals this balancing act: it refers to EU content requirements and preference criteria while stressing alignment with international commitments.

What should UK-based Suppliers do to adapt?

The issue for UK suppliers is not the politics; it’s how EU contracting authorities translate “Made in Europe” into tender conditions. The likely levers are eligibility rules, award criteria and contract performance conditions that reward EU value-add, EU servicing capacity and supply security. That may be enough to tilt outcomes even where the tender remains formally open.

UK suppliers that want to remain competitive will need to treat these points as bid requirements: demonstrate supply chain traceability, diversification and delivery assurance; present auditable sustainability/carbon claims; and show a credible EU delivery/support footprint where that becomes part of evaluation. Where EU content thresholds become hard gates, the commercial choice becomes structural, reconfigure the supply chain (including limited EU assembly or servicing) or accept that parts of the EU-funded market will be out of reach.

Conclusion

The IAA will test whether the EU can pursue strategic autonomy through procurement without tipping into a rules dispute with close partners. A focus on low-carbon outcomes, credible data and genuine supply chain resilience is difficult to criticise. The harder edge is where “resilience” becomes a proxy for origin, or where minimum EU-content thresholds become a blunt market-access control. At that point, the policy stops being primarily about decarbonisation outcomes and starts operating as a procurement barrier with predictable consequences: higher costs, reduced competition, and pressure on non-EU suppliers to relocate value-add into the Single Market.

For the UK, the takeaway is if the EU embeds European preference into eligibility, scoring and delivery conditions for publicly backed clean projects, the UK’s competitive position will turn on evidence (traceability, delivery assurance, auditable carbon claims) and footprint (how much of the value chain can credibly be delivered within the EU where required).

The UK Government, meanwhile, will need to decide how hard it pushes on treaty compliance and carve-outs for trusted partners, because “Made in Europe” rules that are rigid in practice will not only reshape who wins tenders,  they will reshape where investment, jobs and industrial capability land over the next decade.

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