IAA legal reference

The proposed Union-origin and low-carbon requirements by product

The Commission proposal applies different Union-origin and low-carbon conditions to clean technologies, energy-intensive products and vehicles. The two tables below show the main product rules, timing and policy channels.

“Union origin” is the proposal's legal term; origin is determined under the Union Customs Code. For some products and policy instruments, the proposal treats products or components from certain partner countries as equivalent.

Legal text shown: European Commission proposal of 4 March 2026, COM(2026) 100. The requirements may change during the legislative process.

Read the official proposal ↗

Table 1

Energy-intensive industries

Union-origin and low-carbon provisions

Requirements for aluminium, concrete and steel
Product	Provision	Active in	Timeline	Low-carbon definition set by
Aluminium	25% Union-origin and low-carbon	100% of public procurement 45% of the budget of subsidy schemes for construction and cars	1 January 2029	Construction Products Regulation for construction; Ecodesign for Sustainable Products Regulation outside construction
Concrete and mortar (including clinker and cement)	5% Union-origin and low-carbon
Steel	25% low-carbon; no Union-origin provision

Table 2

Clean tech and EVs

Union-origin provisions; no low-carbon provisions proposed

Requirements and policy channels for clean technologies and electric vehicles
Product	Union-origin provision		Active in
Product	After 1 year	After 3 years	Public procurement	40% of auctions	Other public support	Manufacturing support
Battery energy storage systems (BESS)	Final product; for projects above 1 MWh, also the battery-management system (BMS)	Final product + BMS + cells + 1 component	Applies	Applies	Applies	Does not apply
Solar PV technologies	—	Inverter + PV cells (or equivalent)	Applies	Applies	Applies	Does not apply
Heat pumpsOnly hydronic (water-circuit) heat pumps; air-to-air is outside the provision. Origin is assessed under the Union Customs Code.	—	Finished hydronic heat pump must originate in the Union	Applies	Does not apply	Applies	Does not apply
Wind technologiesOnshore and offshore	1 component	2 components	Applies	Applies	Does not apply	Does not apply
ElectrolysersUsed to produce hydrogen	Final product + stack + 1 component	Final product + stack + 2 components	Does not apply	Applies	Does not apply	Applies
Nuclear fission technologies / SMRs	—	After 4 years: 2 components; after 6 years: 3 components	Applies	Does not apply	Does not apply	Applies
EVs	Union assembly + 3 battery components (including cells) + 70% Union-origin non-battery componentsAlready active 6 months after entry into force	Union assembly + 5 battery components + 70% Union-origin non-battery components	Applies	Does not apply	Applies	Does not apply
Small EVs	Union assembly + either 3 battery components or 70% Union-origin non-battery componentsAlready active 6 months after entry into force	—	Applies	Does not apply	Applies	Does not apply

EV support includes purchase premiums and tax advantages for corporate cars. The detailed vehicle-system percentages are set out in Annex III of the proposal.

Component reference

What counts as a main specific component?

For clean technologies, the component categories come from the official NZIA list. Energy-intensive-product percentages and vehicle assembly, component and value-share tests are instead specified directly in IAA Annexes II and III.

Battery technologies

Battery packs
Battery modules
Battery cells
Cathode active materials
Anode active materials
Electrolytes
Separators
Current collectors, including thin copper, aluminium, nickel and carbon foils
Battery-management systems (BMS)
Battery thermal-management systems (BTMS)

Solar PV technologies

PV-grade polysilicon
PV-grade silicon ingots or equivalent
PV wafers or equivalent
PV cells or equivalent
Solar glass
PV modules
PV inverters
PV trackers and their specific mounting structures

Heat-pump technologies

Heat pumps
Four-way valves
Scroll compressors or heat-pump rotary compressors

Wind technologies

Foundations or floaters are an additional category for offshore wind.

Nacelles (assembly)
Rotor hubs
Main, yaw and pitch bearings
Direct-drive or gearbox drivetrains, including the generator
Permanent magnets of wind turbines
Gearboxes of wind turbines
Blades
Towers
Foundations or floaters (offshore only)

Electrolysers

Alkaline (AEL)

Stacks
Separators (diaphragms or membranes tailored for water electrolysis)
Bipolar plates and end plates
Electrodes

Proton-exchange membrane (PEMEL)

Stacks
Membrane-electrode assemblies (3-layer) or catalyst-coated membranes
Porous transport layers or gas-diffusion layers
Bipolar plates and end plates

Anion-exchange membrane (AEMEL)

Stacks
Membrane-electrode assemblies (3-layer) or catalyst-coated membranes
Porous transport layers or gas-diffusion layers
Bipolar plates and end plates

Solid-oxide (SOEL)

Stacks
Electrolyte and electrodes
High-temperature gaskets or sealings
Interconnectors or meshes and end plates

Nuclear fission technologies

Fuel elements
Reactor vessels
Primary piping and valves
Steam turbines
Steam generators
Safety systems
Monitoring, instrumentation and control systems

Clean technologies

Main specific components are listed in Commission Implementing Regulation (EU) 2025/1178.

Open the NZIA component list ↗

Energy-intensive products and vehicles

The product scope, volume or value shares, assembly condition and mandatory EV items are in IAA Annexes II and III.

Open the IAA annexes ↗

Sources

Legal texts

Primary legal sourceEuropean Commission, Industrial Accelerator Act proposal, COM(2026) 100 ↗Clean-tech component definitionsCommission Implementing Regulation (EU) 2025/1178 ↗

Jacques Delors Centre policy briefs

Published 22 June 2026

Paradigm Shift in Principle, Paper Tiger in Practice?

The brief assesses the IAA's proposed EU-wide local-content and low-carbon conditions. It argues that narrow demand coverage and broad exemptions risk limiting their effect, and proposes ways to strengthen the rules while keeping them open to trade.

Read the policy brief ↗Policy brief

Buy European need not break the bank

Why the EU can afford stronger Buy European and low-carbon requirements

New data and cost estimates show that stronger Buy European and low-carbon requirements need not be expensive. Even large component premiums typically have modest effects on building and clean-energy costs. The brief argues for wider market coverage, requirements for more strategic components and removing unnecessary excessive-cost clauses, while retaining safeguards where buyers or energy consumers face substantial cost risks.

Read the policy brief ↗