Industrial Accelerator Act: “Made in Europe” procurement criteria in the context of CBAM

Why the Industrial Accelerator Act is particularly relevant right now

In Brussels, a new initiative of the European Commission is currently being discussed under the title Industrial Accelerator Act, which is understood as a building block of the Clean Industrial Deal agenda. At its core, the initiative aims to organise decarbonisation more strongly as an industrial and competitiveness strategy and to deliberately strengthen European value creation. Reports on the draft indicate that the Commission does not intend to rely solely on traditional funding programmes, but rather to make targeted use of demand-side measures. The objective is to create a reliable market for climate-friendly products, particularly for energy-intensive basic materials such as steel, cement and aluminium, which are also at the centre of CBAM.

Public procurement and market access

According to reporting, the central lever of the draft is public procurement. Public contracting authorities are expected to anchor minimum requirements for a European share and for low-emission content in tender procedures. This would change the rules of the market, as procurement requirements would no longer be based solely on price, but also on origin and emissions profiles. For companies, this is decisive because, under the current framework, sourcing climate-friendly products or raw materials is primarily an economic decision. After all, CBAM or the European Emissions Trading System do not operate through bans or standards, but by pricing emissions. Procurement requirements work differently. They can effectively exclude offers if origin and emissions cannot be demonstrated or if thresholds are not met. In infrastructure, energy, transport and public construction projects in particular, this can quickly become the dominant competitive factor. One immediate effect is that emissions and origin certificates are no longer just compliance documents. They become sales materials that must be actively used in tenders and customer decisions.

State aid and permitting change project economics

In addition to procurement, reporting also refers to linking public funding and subsidies to decarbonisation and origin criteria. This would mean that eligibility for funding would increasingly depend on whether products are climate-friendly and whether value creation takes place in Europe. At the same time, the draft is presented as an acceleration instrument intended to make permitting procedures for industrial projects faster and more predictable. This aligns with the broader EU approach of treating lengthy permitting processes as a competitiveness barrier and implementing corresponding improvements. For companies active in CBAM sectors, this combination sends a strong signal. Demand is supported through procurement, investments are made more attractive through faster procedures and potential funding logic. This can deliberately accelerate the build-up of climate-friendly capacities within Europe.

Trading companies in focus

The perspective is different, however, for trading companies that import CBAM goods. For them, the new legislation may represent an additional burden. On the one hand, they already have to bear CBAM costs for imports this year. These alone can lead to competitive disadvantages, particularly when standard values are used. The new “Buy European” guideline could then pose a further risk to their business. This is likely to be more of a concern for importers of finished products than for those importing industrial intermediate goods. The latter could benefit from increased demand for greener intermediate products for further processing in Europe.

Foreign investment and European value creation as a new guiding principle

Another part of the discussion, according to reporting, concerns increased scrutiny of large foreign investments in strategic sectors. This raises the question of whether and how European value creation and supply chain shares should be taken into account more bindingly. Regardless of the final design, the direction is clear. The EU is increasingly linking climate policy, industrial policy and resilience within a single framework. For companies that import CBAM-affected goods or process them further within the EU, supply chain transparency becomes even more important. Origin, intermediate products and emissions data will be requested more frequently, not only by authorities but also by customers and contracting authorities.

Support

If you would like to assess what “Made in Europe” procurement criteria and low-carbon requirements mean for your imports and sales channels, feel free to contact me at helge@kolum.earth. We are happy to support you.