Three main asks: 

• Set robust low-carbon definitions as soon as possible: Without clear thresholds, non-price criteria in procurement lack the decarbonisation signal industry needs to invest with confidence.  

• Make it “made clean in Europe”: The IAA must make Union-origin criteria inseparable from low-carbon requirements across both public procurement and public support schemes. Leaving Member States free to apply origin criteria without low-carbon conditionality risks locking in higher-carbon production pathways and sets a damaging precedent for future demand-side initiatives.  

• Set an ambitious timeline on the steel label: the Commission must provide a concrete timeline for the Ecodesign delegated act now. In addition, the proposed procurement quotas are too low to generate demand at the scale required. Ambition must match the urgency of the industrial transition. 

Quotes  

«The IAA’s low-carbon criteria depend entirely on delegated acts that haven’t been written yet — under either the Construction Products Regulation or the Ecodesign. The Commission must treat those delegated acts as a matter of urgency; without them, we cannot mobilise European public money to drive the transformation of our most polluting industries. »

The highly anticipated publication of the Industrial Accelerator Act leaves Bellona with a bittersweet taste. While we welcome that the focus on lead markets for low-carbon products remain a central pillar of the act, more ambition is needed. The Act as it stands falls short on creating the sufficient demand signal to support lead market creation for low-carbon products, due to lack of available definitions, low quotas, and limited scope. 

A welcome but incomplete step on lead markets 

Bellona welcomes the IAA’s emphasis on non-price criteria in public procurement and public support schemes, which can play a critical role in sending a strong demand signal for low-carbon products and in helping to close green premiums over time.  

However, the draft falls short in three main ways: first, because of the lack of low-carbon definitions, which are crucial to define the scope of application of the criteria and to send the needed decarbonisation signal. Second, due to the too low quotas proposed, which are insufficient to create demand at the scale needed. And lastly by neglecting to address private-sector demand, which is essential for creating lead markets at the scale European industry needs today.  

With regards to the “made in Europe” criteria, Bellona is concerned that the Act does not explicitly tie them to low-carbon requirements. When it comes to public procurement, both “Union origin” and “low-carbon” requirements are made mandatory; however, in public support schemes, the choice is left to Member States to choose either or both. As previously stated, any European-origin requirement must be inseparable to low-carbon requirements, as a “made clean in Europe”, conditional on demonstrably lower lifecycle emissions than alternatives. Otherwise, Europe risks locking in higher-carbon production pathways and actively undermining European industrial decarbonisation.  

Steel label: a credible demand signal is needed now 

The removal of a standalone EU steel label chapter from the March draft leaves questions unanswered. The Commission has indicated it will rely instead on a forthcoming Ecodesign for Sustainable Products Regulation (ESPR) delegated act. While Bellona acknowledges the ESPR’s potential as a more comprehensive framework, the steel industry’s investment decisions in hydrogen-based direct reduction and other clean routes cannot be put on hold indefinitely. Whichever instrument moves fastest and furthest is the one that must be used, and the Commission must do everything in its power to accelerate the process. 

The IAA is built on the ETS, and will crumble without it 

The IAA will only deliver if the wider policy toolbox retains its ambition. Frontrunners in clean industrial products are building their business cases on the carbon price signal via the ETS. The IAA is designed to complement and support that signal, not to replace it. Any erosion of ETS ambition would undermine the very investment decisions the IAA aims to incentivise, regardless of how ambitious the IAA itself may be.