IOGP Europe position on Industrial Accelerator Act and recommendations for modifications

Executive Summary

IOGP Europe recognises the Industrial Accelerator Act (IAA) as a positive step toward the creation of lead markets to stimulate demand for low-carbon products. To fully realise this potential, the IAA should aim to create a functioning market where demand is strong enough to sustain and reward the premium associated with low-carbon products.

IOGP Europe provides the following recommendations to ensure that the framework delivers its objectives in a practical, technology-neutral, and market-oriented manner. In this regard, the overall framework should provide a stable and predictable regulatory environment, with any empowerment of the Commission to further define, expand, or restrict requirements through delegated acts being narrowly framed and limited to what is strictly necessary to preserve legal certainty and investor confidence.

IOGP Europe’s 7 recommendations for strengthening the Industrial Accelerator Act proposal:

1. Technology neutrality and level playing field principles

As many of the key details will be defined through Delegated Acts, it is essential that the Regulation explicitly enshrines the principle of technology neutrality and level playing field in its core provisions. These principles must guide the development of Delegated Acts, ensuring fair treatment across technologies, including renewable vs low-carbon hydrogen, and geographical balance across Member States.

2. Alignment between IAA and NZIA on CCS

The IAA should facilitate the development and deployment of CCS across the entire value chain, including by coordinating dedicated support mechanisms as a critical enabler of low-carbon product supply chains. At the same time, it should amend the NZIA provisions on the CO₂ injection capacity objective to ensure a realistic, investment-enabling framework for CCS value chain.

3. Definition of low-carbon products & creation of lead markets

The definition of low-carbon products is a key element of the framework. The criteria developed under Articles 10 and 16 should take into account lifecycle greenhouse gas emissions intensity and ensure a level playing field across Member States. The criteria should remain technology-neutral and recognize the role of CCS and low-carbon hydrogen in achieving the objectives of the Regulation. Experience from the market shows that voluntary classification systems alone are unlikely to generate the scale of demand needed to drive industrial transformation or create meaningful market pull.

To effectively establish lead markets, it should be reflected at the later stage to move towards stronger and more predictable demand signals, inter alia through mandatory product standards. These should be technology-neutral and designed to avoid carbon leakage by reflecting both production intensity and consumption, rather than being constrained by jurisdictional boundaries. Sound policy design will be critical to ensure effectiveness while limiting cost impacts.

4. “Made in the EU” / Union origin requirements

Union origin requirements risk creating uncertainty for globally integrated industries by disrupting value chains and reducing investment predictability. They are not an effective solution to competitiveness or unfair trade challenges, which should instead be addressed through existing EU trade and market instruments.
Strengthening the European industrial base should be carried out in a proportionate manner, while preserving openness to international cooperation. The system boundaries for the production of the covered products must also be carefully clarified as they may add further complexity to the process, as well as have implications for the European energy market.

Union-origin criteria should be applied with caution to ensure their credibility and transparency, avoiding their excessive extension to entities from third countries. At the same time, strictly defined exceptions should be allowed in the context of deep strategic partnerships.

5. Foreign Direct Investment (FDI)

The proposed FDI provisions in the IAA create more uncertainty at a time when Europe needs to safeguard its attractiveness as an investment destination. We support the overall objective of requiring FDI to create value in the EU. The IAA provisions are as in initial EC draft overly prescriptive and will likely increase administrative burden for both authorities and investors. The EU should rather leverage the existing screening tools at its disposal.

6. Permitting

Single access points are a positive step, but they will only work if they genuinely coordinate the entire permitting process. Industrial projects often involve multiple components governed by different permitting frameworks and organizations. Without alignment, simplification benefits will be lost. The Industrial Accelerator Act should therefore align single access points with those under the Net-Zero Industry Act, the Critical Raw Materials Act, and the Renewable Energy Directive, ensuring one coherent permitting process coordinated by a single authority. Interoperability should be prioritised with existing frameworks, ensuring that project developers benefit from a single, coherent permitting pathway across the full value chain.

7. Corporate climate transition plans (Article 25(4)(h))

The inclusion of corporate climate transition plans in the designation criteria for Industrial Manufacturing Acceleration Areas should not in any way be used as a requirement for eligibility. As this would create legal uncertainty, litigation risk and duplication with existing CSRD disclosure requirements, while shifting the IAA away from its core purpose of strengthening Europe’s industrial competitiveness and deployment capacity. IOGP Europe acknowledges the overall objectives of the IAA in promoting lead markets and accelerating low-carbon industrial transformation, and stands ready to engage constructively with policymakers and stakeholders to ensure the framework delivers effective and workable outcomes. A set of proposed amendments is provided in the Annexes.

Download the document to view the Annexes