European Commission proposes EU Industrial Accelerator Act introducing 'Made in EU' procurement preferences, low-carbon requirements, and tightened FDI screening for strategic sectors
The European Commission has proposed a new EU Industrial Accelerator Act (IAA), a legislative package that would introduce 'Made in EU' requirements in public procurement and in government schemes supporting purchases of qualifying products such as electric vehicles, alongside low-carbon content requirements. The proposal also includes stricter rules for foreign direct investment (FDI) screening in strategic sectors. The 'Made in EU' label — and the procurement preferences attached to it — would apply across member states' public purchasing decisions, creating a direct preference mechanism favouring European-manufactured goods in state-backed transactions. This mirrors approaches taken in the US Inflation Reduction Act and China's domestic preference frameworks, and is widely read as a response to competitive pressure from both. Cooley LLP attorneys have published analysis of the proposal, noting that the IAA introduces low-carbon requirements alongside origin-of-manufacture criteria. For legal practitioners, the most complex elements are the FDI screening tightening — which builds on the existing EU FDI Screening Regulation (Regulation 2019/452) — and the procurement preference rules, which must interact with the EU's existing WTO (World Trade Organization) commitments under the Government Procurement Agreement (GPA). British carmakers have also separately called for clarity on the EU's 'Made in EU' rules as post-Brexit trade arrangements evolve — a signal that UK businesses will need cross-border legal advice on how EU origin requirements interact with the UK–EU Trade and Cooperation Agreement (TCA) rules of origin provisions.
Why this matters
The IAA creates immediate advisory demand across international trade, EU regulatory, and public procurement practices. FDI screening tightening is particularly significant: it will affect non-EU investors — including US and UK PE funds and sovereign wealth vehicles — seeking to acquire assets in sectors classified as 'strategic' by the Commission, requiring pre-notification and approval in more transactions than today. The GPA compatibility question is a genuine legal risk: procurement preferences that favour EU-origin goods could be challenged by third-country trading partners at the WTO Dispute Settlement Body, and firms advising governments or contracting authorities on procurement design will need to map that exposure. For London-based international practices, the UK's own NSIA (National Security and Investment Act 2021) mandatory notification regime makes this a directly parallel story — clients with cross-border portfolios need coordinated EU and UK FDI counsel simultaneously.
On the Ground
A trainee on an international regulatory matter linked to the IAA would draft treaty analysis notes comparing the Commission's proposed procurement preferences against GPA schedules, prepare choice-of-law summaries for cross-border supply agreements affected by the new origin rules, and coordinate local counsel instruction letters to obtain advice on member state implementation of the FDI screening changes.
Interview prep
Soundbite
EU procurement preferences for 'Made in EU' goods create WTO compatibility risk — public law and trade practices both have live mandates here.
Question you might get
“How might the EU Industrial Accelerator Act's 'Made in EU' procurement preferences conflict with the EU's obligations under the WTO Government Procurement Agreement, and what legal mechanisms would a third-country government use to challenge them?”
Full answer
The European Commission has proposed the EU Industrial Accelerator Act, introducing 'Made in EU' public procurement preferences, low-carbon product requirements, and tightened FDI screening for strategic sectors. The proposal directly mirrors protectionist frameworks in the US and China, signalling a structural shift in how the EU deploys industrial policy through procurement rules. For law firms, the work spans EU regulatory compliance for manufacturers seeking the label, FDI pre-notification advice for non-EU investors in affected sectors, and WTO dispute risk analysis for governments implementing the preferences. The UK angle is material: post-Brexit, UK exporters to the EU market will be on the wrong side of the origin preference, and UK PE funds acquiring European strategic assets face more demanding FDI filing obligations. This is a story that activates international trade, competition, and M&A regulatory practices simultaneously.
Sources
My notes
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