On 18 June 2026, Carbon Management Europe (formerly Zero Emissions Platform) responded to the European Commission’s public consultation on the European Commission’s proposal for the Industrial Accelerator Act.
The IAA is a key opportunity to align EU climate ambition with industrial competitiveness objectives by addressing an important barrier to industrial decarbonisation: the lack of predictable and sustained demand for low-carbon products in Europe. While the EU has established important supply-side incentives through carbon pricing, innovation funding, and support for strategic infrastructure, these measures alone are insufficient to drive the scale of investment required to decarbonise European industry.
Currently, low-carbon production continues to face significant cost premiums over conventional alternatives, limiting market uptake and undermining the business case for investment in industrial decarbonisation technologies such as Carbon Capture and Storage (CCS). The IAA has a critical role to play in complementing existing supply-side measures by establishing a robust framework of demand-side policies capable of creating lead markets for low-carbon products across Europe – an objective that is central to the Clean Industrial Deal.
Carbon Management Europe’s feedback aims to enhance the IAA's ambition and strengthen its contribution to an ambitious, predictable, and coherent framework that stimulates demand for low-carbon products, while maintaining consistency with the broader EU industrial and climate policy objectives. To this end, the feedback mainly focuses on the following areas:
Chapter III – Strengthening the Union’s strategic industrial value chains
- Article 10
- Article 11
- Article 12
- Article 16
Chapter V – Industrial Manufacturing Acceleration Areas
- Article 25
Chapter VI – Final provisions
Annex II
Carbon Management Europe's recommendations
Ensure ambitious and harmonised low-carbon product definitions under relevant legislation
Ensure that delegated acts under the ESPR and CPR define low-carbon products based on their GHG intensity and exclude marginal improvements within conventional production pathways. The thresholds should be linked to an ambitious definition of “low-carbon” reflecting the highest classes of performance.
Make low-carbon requirements mandatory across all forms of public intervention
Require Member States to apply both low-carbon and EU-origin requirements across all forms of public intervention.
Restrict and clarify exemption mechanisms from low-carbon requirements
Ensure that exemptions from the application of low-carbon requirements on the grounds of disproportionate costs remain strictly exceptional by assessing cost impacts at project and/or contract level and establishing a clear, harmonised methodology for their application across Member States.
Include the possibility of introducing private demand-side measures to all strategic sectors with a clear timeline
Broaden Article 16 to expressly enable the European Commission to establish private demand-side measures beyond chemical products to all strategic sectors identified in Annex I, supported by a binding implementation timeline.
Increase and progressively strengthen low-carbon content thresholds
Raise low-carbon procurement requirements for steel, concrete, mortar and aluminium, with clear and progressive milestones for 2030 and 2040 to provide predictable demand signals and long-term investment certainty for decarbonisation projects.
Strengthen industrial ecosystems and policy coherence
Align the Industrial Accelerator Act with existing EU frameworks, including the Net-Zero Industry Act and forthcoming European Competitiveness Fund, while supporting industrial clusters and acceleration areas that enable coordinated decarbonisation.