On March 4, 2026, the European Commission published a proposal for a new EU Regulation — the Industrial Accelerator Act (IAA) — designed to strengthen EU manufacturing capacity and accelerate industrial decarbonisation. The goal of this proposal is to support EU manufacturing to reach 20% of EU GDP by 2035, after declining to only 14.3% in 2024.
The IAA is not implemented yet. If adopted by the European Parliament and Council, it would introduce a new set of demand-side rules aimed at creating “lead markets” for low-carbon and, in some cases, European Union-origin industrial materials used in construction, infrastructure, and parts of the automotive sector. The proposal has already drawn public reactions from steel, automotive, and international trade stakeholders and governments. The near-term implication for manufacturers and AEC supply chains is that public procurement and subsidy-backed projects would require verifiable low-carbon and even EU-origin materials.
Ireland, as an EU member state, would be directly subject to the IAA's public procurement and subsidy rules from January 1, 2029, if the proposal is adopted, on the same terms as any other Member State.
The UK sits outside the EU, but UK-origin materials are not automatically excluded. Under the UK-EU Trade and Cooperation Agreement (TCA) and the UK's own membership of the WTO Government Procurement Agreement (GPA), acquired in its own right after Brexit, UK content can currently be treated as equivalent to EU origin for procurement and subsidy purposes. That treatment isn't guaranteed to continue, since the European Commission retains the power to revisit which countries qualify by delegated act. One exception already in the draft: new electric vehicles must be assembled within the EU to qualify, so a vehicle assembled in the UK would likely fail that specific requirement even where its components meet the equivalence test.
Ireland is bound by the IAA as an EU member state. UK-origin materials and products can currently qualify on equivalent terms via the TCA and GPA, though that status could change and doesn't extend to UK-assembled electric vehicles.
The proposal is consistent with existing EU regulations to define what low-carbon materials are. It directly links to the criteria of the Construction Products Regulation (CPR) and the Ecodesign for Sustainable Products Regulation (ESPR).
CPR requirements closely align with those governing the creation of Environmental Product Declarations (EPDs). In practice, this means that manufacturers will likely need EPDs to prove that their products comply with the mandates of the IAA.
The clearest, date-specific requirements are in Annex II, which splits obligations into public procurement and other forms of public intervention. They introduce low-carbon and ‘made in the EU’ obligations, to be applied from January 1, 2029.
From January 1, 2029, Member States would need to apply the requirements of the IAA to at least 45% of their national budget allocated to public support schemes for construction/renovation of buildings and infrastructure. For those projects, only beneficiaries that meet minimum low-carbon / Union-origin requirements would be eligible.
The minimum requirements for each material are:
Public procurement
The same requirements will apply for public procurement covering buildings, infrastructure, and motor vehicles for civil purposes. The same core quantities appear: 25% low-carbon steel, 5% low-carbon and EU-origin concrete/mortar, and 25% low-carbon and EU-origin aluminium.
The IAA proposal will move through the EU legislative process. Once approved, it would enter into force on the day after publication in the Official Journal. The Commission anticipates an evaluation two years after entry into force.
There is one key fixed date: January 1, 2029, for the Annex II low-carbon / EU-origin shares for steel, concrete-mortar, and aluminium in covered procurement and support schemes.
The IAA closely aligns with the requirements of the existing CPR and ESPR, as well as many national and urban regulations with tight low-carbon limits for construction products. Manufacturers and procurement teams should be ready ahead of deadlines and start preparing now to remain competitive.
If you manufacture in the UK or Ireland, treat this as live regulatory tracking, not a future problem. Irish public contracts will apply IAA thresholds directly from 2029. UK exporters currently benefit from equivalence under the TCA and GPA, but that status could be revisited, so building EPD evidence now protects against either outcome.
UK and Ireland-based AEC firms working on EU or Irish-funded projects should treat Annex II thresholds as a near-term tender requirement, since the 2029 deadline falls within most current project pipelines.
The draft leans heavily on verification and monitoring, and details penalties in Articles 22, 23, and 32 For most requirements, the proposal says Member States must set national penalties that are effective, proportionate, and dissuasive.
The foreign direct investment (FDI) chapter is more prescriptive: national Investment Authorities would have to monitor compliance and they could impose penalties for providing false or misleading information, and for failure to notify or comply with investment conditions. For notification breaches, the proposal sets penalties that must be at least 5% of the foreign investor’s average daily aggregate turnover, or at least 5% of the investment value where the investor is a private person.
Where the Commission carries out its own monitoring, it may penalise false or misleading information or failure to provide required information with a penalty of up to 5%.
The Industrial Accelerator Act has drawn attention well beyond Brussels and sparked a long list of reactions from international governments, industry associations, and multinational companies. The proposal has opened political debate over European preference in public contracts and subsidies. EUROFER, the European steel association, supports lead markets for low-carbon steel, but asks for stricter Union-origin rules based on steel melted and poured in the EU. The automotive industry has also been very vocal: ACEA, the European Automobile Manufacturers’ Association, says the Act must reflect automotive supply-chain realities, especially battery manufacturing, energy costs, and industrial investment conditions.
Beyond Europe, China’s Ministry of Commerce called the proposal discriminatory and protectionist, citing local-content requirements and foreign investment restrictions, and warned of countermeasures.
The purpose of the IAA is to streamline permitting for manufacturing projects, create demand for European low-carbon industrial products, and strengthen strategic value chains.
The Commission has set five specific objectives:
Some of the expected benefits from the preferred policy option are:
The Industrial Accelerator Act is an EU proposal to boost low-carbon industry and demand, by establishing low-carbon and Union-origin requirements for many materials used in public procurement and support schemes. One Click LCA helps manufacturers prepare with product LCA and EPD workflows to verify and back their carbon impact claims.
The IAA is still a draft proposal and will move through the EU regulatory approval process. There are no set timings yet, except for 2029 as the year when material requirements start to apply if the proposal is approved. One Click LCA can help teams prepare carbon data and EPDs before rules tighten.
Annex II of the IAA targets steel, concrete and mortar including clinker and cement, and aluminum. One Click LCA supports LCA and EPD work for these products, including pre-verified and product-tailored EPD generators.
For covered segments: 25% low-carbon steel, 5% low-carbon and Union-origin concrete/mortar (including clinker and cement), and 25% low-carbon and Union-origin aluminium. One Click LCA helps evidence carbon claims thanks to LCA and EPD creation for whole product portfolios.
The IAA would enter into force one day after publication in the Official Journal. The key Annex II date is January 1, 2029, when material requirements would apply. One Click LCA can help build LCA and EPD readiness before procurement deadlines.
The IAA does not require EPDs explicitly, but it links directly to the Construction Products Regulation, which aligns with the international standards that set the rules for creating EPDs. One Click LCA helps create LCAs and EPDs that support credible product carbon claims and buyer documentation.
What does “low-carbon” mean in the IAA?
The IAA draft links low-carbon criteria to CPR and ESPR regulations, which depend on harmonized standards. One Click LCA helps calculate product carbon footprints and generate supporting EPDs aligned with CPR and ESPR criteria.
The proposal could reshape public procurement, low-carbon material markets, and industrial competition in Europe. Steel, automotive, and trade groups, as well as China’s government, have already reacted publicly to its 'Made in EU' provisions, with mixed reactions.
Yes. Ireland is an EU member state, so it would be directly bound by the IAA's public procurement and subsidy thresholds from January 1, 2029, if adopted. One Click LCA helps Irish manufacturers and AEC teams build the LCA and EPD evidence these rules require.
Not directly, but UK-origin materials can currently qualify on equal terms with EU-origin materials, under the UK-EU Trade and Cooperation Agreement and the UK's WTO Government Procurement Agreement membership. One Click LCA helps UK manufacturers and AEC teams prepare LCA and EPD evidence in case that status changes.