The 'Made in EU' regulations of Europe begin at 5%, and there is no mention of software.
The Industrial Accelerator Act was introduced on 4 March 2026 as COM(2026)100, accompanied by an impact assessment and three staff working documents, according to the European Commission. The formal title indicates its purpose: to create a framework for enhancing industrial capacity and promoting decarbonisation in crucial sectors. This is a proposal, not yet legislation, currently undergoing the ordinary legislative process, pending positions from Parliament and the Council.
What the Act requires
The origin rules are detailed and focused on specific sectors rather than being general. Starting 1 January 2029, concrete and mortar used in buildings, infrastructure, or vehicles must contain at least 5% Union-origin content. Aluminium must contain 25%, while steel is exempt from origin requirements, instead facing low-carbon criteria. Vehicles receive the most stringent regulations; electric, plug-in hybrid, and fuel-cell vehicles must adhere to EU assembly requirements, minimum EU content thresholds for components, and specific battery sourcing rules, which take effect six months post-enactment. Net-zero technologies will have differentiated thresholds established through amendments to the Net-Zero Industry Act, affecting solar, batteries, heat pumps, wind, and nuclear energy. The scope is defined by NACE code, including energy-intensive industries such as C17, C19, C20, C22, C23, C24 and automotive C29.
Understanding the numbers
Five percent is more of a signal than an industrial policy. A requirement for one part in twenty of concrete to originate from Europe won’t single-handedly rebuild a supply chain. The 25% requirement for aluminium is more significant, yet still allows for three-quarters of the metal to be sourced elsewhere. This modesty has reasoning behind it, as the Act includes general derogations where origin requirements may lead to insufficient competition, excessive costs, technical incompatibility, or major delays. This is sensible legislation, but it also leaves room for flexibility. The main provisions of the Act are found in the automotive and net-zero chapters, rather than in the general framework.
What is excluded, and misconceptions surrounding it
The European tech discourse seems to be ahead of the legislation. The origin rules don’t address engineering software, cloud hosting, or design tools. Christina Rebel, CEO of the engineering collaboration platform CAD ROOMS, contends to tech.eu that they should. “If Made in EU becomes a condition for public procurement, the discussion cannot end with the product coming off the line; it has to begin much earlier,” she stated. This advocates for an extension of the Act. It is beneficial to view it as a call for change rather than a reflection of the current draft, which focuses on concrete, cars, and solar panels.
Addressing the existing gap
When we remove the legislative context, a real issue persists. Most European engineering teams depend on US-hosted platforms for product development. Each CAD file, every revision, and all design intellectual property reside on infrastructure outside EU jurisdiction. A procurement label attached to the final product does not alter that reality. This argument resonates in the cloud sector, where Airbus and Scaleway have created a sovereign cloud to counter American hyperscalers. This concern runs through various discussions on digital sovereignty in Europe, and hardware design remains the least scrutinized aspect of this issue.
Rebel presents an alternative that should be mentioned clearly. CAD ROOMS is EU-hosted, fully encrypted, and ISO certified, competing against the US platforms previously referenced. While that doesn't invalidate the observation, it does mean that the speaker stands to gain if regulations shift in her favor.
The part of her argument devoid of commercial interests
The electronics issue is a compelling aspect of her interview, and she has no personal stake in raising it. Enclosures may be produced in Europe or the US, but the internal components frequently cannot. “The essential electronic components simply weren’t available locally, or the European prices rendered the final product uncompetitive,” she noted. The depth of the Chinese ecosystem is a significant factor, with suppliers, manufacturing skills, and entrepreneurs located in close proximity, a pattern that is also emerging in robotics. Notably, China accounts for 97% of humanoid robots shipped globally.
The prototype gap the Act was never intended to address
The constraints are most pronounced where the IAA does not provide any assistance. Rebel highlights that founders receive European manufacturing quotes that make developing a working prototype financially unfeasible. Sometimes, hardware startups require €20,000 or €50,000 to reach a prototype. A company might need validation from its first thousand customers before securing funding for subsequent stages, which often necessitates manufacturing at least part of the product outside of the EU. The Act primarily serves as a demand-side instrument for bulk goods purchased by governments, failing to address the needs of small teams attempting to create a functioning unit.
The clause that omits China's name
One provision deserves more scrutiny than it has received. The Act evaluates foreign investments exceeding €100m if the investor comes from a nation that
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The 'Made in EU' regulations of Europe begin at 5%, and there is no mention of software.
The origin rules for products made in the EU begin with a requirement of 5% for concrete and 25% for aluminium. Engineering software and cloud hosting are completely excluded from the Act.
