Europe's 'Made in EU' regulations begin at 5%, and there is no reference to software.
The Industrial Accelerator Act was introduced on 4 March 2026 as COM(2026)100, along with an impact assessment and three accompanying staff working documents, according to the European Commission.
Its formal title clarifies its purpose: it establishes a framework aimed at accelerating industrial capacity and decarbonisation in key sectors. Importantly, it is a proposal rather than a law and is currently undergoing the ordinary legislative process, awaiting positions from both Parliament and the Council.
What the Act actually entails
The rules concerning origin are specific and tailored to particular sectors instead of being broad. Starting from 1 January 2029, concrete and mortar used in buildings, infrastructure, or vehicles must contain at least 5% Union-origin content. Aluminium is required to have 25%, while steel is exempt from these origin requirements, subject to low-carbon criteria instead.
Cars are subject to the most rigorous standards. Electric, plug-in hybrid, and fuel-cell vehicles must comply with EU assembly requirements, meet minimum EU content thresholds for their components, and adhere to specific rules for battery sourcing, six months after the Act takes effect. Net-zero technologies will have their own distinct thresholds through amendments to the Net-Zero Industry Act, which will include solar, batteries, heat pumps, wind, and nuclear.
The scope is defined by NACE codes, covering energy-intensive industries C17, C19, C20, C22, C23, and C24, as well as the automotive sector C29.
Understand the smaller figure
The 5% requirement is not an industrial policy; rather, it serves as a signal. Mandating that one part in twenty of the concrete must originate from Europe will not, on its own, reconstruct a supply chain. The 25% requirement for aluminium is more significant, but it still permits three-quarters of the metal to be sourced from anywhere.
The modesty of these figures is intentional. The Act also includes general derogations where origin requirements might result in insufficient competition, excessive costs, technical incompatibility, or major delays. This approach reflects sensible drafting but also opens a significant loophole. The core provisions of the Act are concentrated in the automotive and net-zero sectors, not in the broader initiatives.
What the Act does not include, and the misunderstandings surrounding it
This is where the dialogue in European tech has outpaced the actual content of the text. The origin rules do not address engineering software, cloud hosting, or design tools. Christina Rebel, CEO of the engineering collaboration platform CAD ROOMS, asserts to tech.eu that they should be included. “If ‘Made in EU’ becomes a condition for public procurement, the discussion must begin much earlier than when the product exits the assembly line,” she stated. This proposal advocates for the Act to be extended. It may be more useful as a call to action than a reflection of the current draft, which primarily focuses on concrete, vehicles, and solar products.
The gap she highlights is nonetheless a real issue.
Removing the legislative context reveals a genuine problem: most engineering teams in Europe conduct product development on US-based platforms. Each CAD file, revision, and piece of design intellectual property exists on infrastructure outside EU jurisdiction. Simply labeling the finished product does not resolve this issue.
This argument has previously been covered regarding cloud computing, where Airbus and Scaleway built a sovereign cloud to counter American hyperscalers. It resurfaces in every iteration of the digital sovereignty debate across the continent, with hardware design being the least scrutinized aspect.
Rebel promotes an alternative solution, which should be stated clearly rather than discovered later. CAD ROOMS is EU-hosted, end-to-end encrypted, ISO certified, and competes against the US platforms to which she refers. This doesn’t invalidate her observation; it merely highlights that she stands to gain if regulations shift in her favor.
The component concern that lacks commercial interest
The issue with electronics is the most compelling point in the interview, and she has no personal gain from mentioning it. While enclosures can be manufactured in Europe or the US, the internal components often cannot. “The core electronic components simply weren’t available locally, or the European pricing made the final product uncompetitive,” she explained.
The depth of the Chinese ecosystem accounts for this, as component suppliers, manufacturing expertise, and entrepreneurs are all in close proximity, and this pattern can also be seen in robotics. Data supports this, showing that China produces 97% of humanoid robots shipped globally.
The prototype gap the Act does not aim to address
This constraint generally affects the earliest stages, and the IAA does nothing about it. Rebel notes that founders often receive European manufacturing quotes that render creating a first working prototype economically unfeasible. According to her, a hardware startup might need €20,000 or €50,000 to reach that prototype stage.
A business may require validation from its initial thousand customers before investors will finance the next phase. Often, reaching these customers necessitates manufacturing
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Europe's 'Made in EU' regulations begin at 5%, and there is no reference to software.
The EU's origin regulations stipulate a minimum of 5% for concrete and 25% for aluminium. Engineering software and cloud hosting are completely excluded from the Act.
