The EU's "Made in EU" agenda: The draft Industrial Accelerator Act and its possible implications for Turkish exporters

The European Commission's proposal for an Industrial Accelerator Act (COM(2026)100), published on 4 March 2026, seeks to strengthen "Union origin" and low-carbon criteria in EU public procurement and in certain public support schemes. Although the proposal has not yet been adopted into law, a notable feature from a Turkish perspective is that it opens the possibility — under specified conditions — for content originating in third countries that have a customs union or a free trade agreement with the EU to be treated as "Union origin". This approach is, however, subject to important limitations, in particular with respect to reciprocity, regulatory alignment, and the Commission's power to narrow the scope through delegated acts.

General framework of the proposal

The IAA is presented as the cornerstone of a new industrial policy aimed at increasing the share of manufacturing in EU GDP from around 14 % to 20 % by 2035. The proposal provides for three principal policy instruments:

1. "Lead Markets" — origin and low-carbon criteria in EU public procurement and in certain public support schemes. The following minimum thresholds are envisaged in the official annexes to the proposal:

  • Steel: At least 25 % of the total volume procured under public contracts is to be low-carbon (no "Union origin" requirement).
  • Aluminium: At least 25 % is to be both low-carbon and of "Union origin".
  • Concrete and mortar: At least 5 % is to be both low-carbon and of "Union origin".
  • Electric vehicles: The annex provides for vehicles to be assembled within the Union, for components (excluding batteries) to have a Union content of at least 70 %, and for certain battery components to be of "Union origin". Stricter requirements for batteries, e-powertrain and electronic systems are scheduled to apply three years after entry into force.
  • Net-zero technologies: Thresholds are envisaged that tighten over time.

These thresholds may change significantly during the legislative process.

2. Conditions on foreign direct investment in strategic sectors. The proposal introduces additional conditions — such as quality employment, innovation, technology transfer, and local value creation — for investments exceeding EUR 100 million, in particular in areas where more than 40 % of global production capacity is concentrated in a single third country.

3. Industrial Manufacturing Acceleration Areas. Member States are to designate at least one industrial acceleration zone within 12 months of the date of entry into force; these zones are to feature a single digital one-stop-shop, accelerated permitting procedures, and coordinated infrastructure services.

The Turkish dimension: the Customs Union and the definition of "Union origin"

The most notable aspect of the proposal from a Turkish perspective is that the definition of "Union origin" may — under specified conditions and within the framework of the non-preferential rules of origin laid down in the Union Customs Code — encompass content originating in third countries with which the EU has concluded a customs union or a free trade agreement. In this context, where the conditions set out in the proposal are met, it is possible for products manufactured in Turkey to be taken into consideration under the "Union origin" criterion in the context of public procurement and public support mechanisms covered by the IAA.

This mechanism is, however, not unconditional. The principal limitations to be taken into account are the following:

  • Reciprocity. The proposal emphasises mutual access to public procurement markets with the EU. Turkey is not a party to the WTO Agreement on Government Procurement (GPA); this remains an important variable in the practical application of the mechanism to Turkey.
  • Regulatory alignment. Alignment with the environmental, technological, and supply-chain standards established under the Net-Zero Industry Act, the Clean Industrial Deal, the Carbon Border Adjustment Mechanism (CBAM), and related instruments is to be expected. Emissions targets and battery rules are of particular importance in this regard in the automotive sector.
  • The Commission's power to narrow the scope. The Commission will be empowered, by delegated act, to exclude — in whole or in part — third countries that do not grant "national treatment" to EU products or companies. A similar exclusion may also be applied on grounds of avoiding the creation of dependencies by the EU or pursuant to provisions contained in the relevant agreement.

Accordingly, the extent to which Turkey may in practice benefit from the IAA mechanism will depend on (i) the final outcome of the legislative process, (ii) how the reciprocity requirement is defined, and (iii) possible arrangements between Turkey and the EU regarding the mutual opening of public procurement markets.

Sectoral potential and areas for preparation

Automotive. The automotive industry — Turkey's largest export sector (with 2025 exports of approximately USD 41.5 billion according to OİB data) — is likely to be directly affected by the vehicle-specific provisions of the proposal. The draft text envisages, for the transitional period, an approach under which certain battery solutions may be taken into consideration under the "Union origin" criterion provided that final assembly takes place within the EU or, under the Customs Union, in Turkey. If preserved in the final version, this framework may be regarded as capable of influencing location decisions for battery investments.

Steel and aluminium. Whereas only a low-carbon requirement is envisaged for steel, both a low-carbon and a "Union origin" requirement apply to aluminium. This differentiation increases the strategic importance of decarbonisation investments for Turkish steel producers.

Green technologies (wind turbines, heat pumps, photovoltaic systems). Given Turkey's existing manufacturing capacity and the presence of European OEMs in the country, the IAA framework offers potential for new business opportunities for well-prepared firms in this area.

Energy-intensive sectors (cement, chemicals). Full compliance is expected, save for the disproportionate cost exemption (25–30 %).

Timeline

  • 4 March 2026: The Commission's proposal was published (COM(2026)100).
  • Ordinary legislative procedure: Negotiations in the European Parliament and the Council will continue; significant amendments to the text are possible.
  • Entry into force according to the current proposal timetable: Preparatory documents point to around 2027, although the exact date will depend on the course of the negotiations.
  • Application of the thresholds for energy-intensive sectors in public procurement: The annexes to the proposal set the date as 1 January 2029.
  • Tightened thresholds (net-zero technologies and electric vehicles): Three years after entry into force.
  • Industrial Manufacturing Acceleration Areas: Member States will designate at least one zone within 12 months of entry into force.

Legal notice: 

This article is provided for general information purposes only and does not constitute legal advice. The IAA is currently a Commission proposal and is expected to undergo amendments as a result of negotiations between the European Parliament and the Council. For an assessment of your specific situation, please contact us.



Author: Gürkan Erdebil