Made in EU
Dear Member,
I want to make you aware of a potentially untoward development within EU institutions.
This is the emergence of the concept of ‘Made in EU’. This idea first appeared as long ago as 2014 and was originally conceived as a label backed up by an EU Regulation which could be assigned to products on the basis of EU legislative compliance and the incorporation of EU local content into products.
At the time, this didn't secure sufficient traction to be taken further.
However, against the background of a struggling EU manufacturing economy, with its competitiveness tested by relatively high energy costs and indeed by the EU’s own regulatory regime, two developments have now pushed the concept of ‘Made in EU’ to the fore once more.
The first was the publication in 2024 of the ‘Draghi Report’ on the competitiveness and future of the EU. This had been commissioned by Ursula von der Leyen from the former President of the European Central Bank, Mario Draghi. It recommended urgent actions to remove the competitiveness gap between the EU on the one hand and the USA and China on the other. Even after one year, there was little evidence on the ground that any of its recommendations had been seriously developed.
The second was the reaction by EU industry to the EU’s flagship strategy for combating climate change, ‘The Green Deal’, adopted in 2019. The cost burden was becoming increasingly evident. At a meeting with Ursula von der Leyen in Antwerp in 2024, some 78 business leaders presented her with what became known as the ‘Antwerp Declaration for a European Industrial Deal’. The European Commission responded by publishing a ‘Clean Industrial Deal’ in February 2025, ostensibly to be the natural business complement of the ‘Green Deal’. This strategy attempted to marry industrial decarbonisation with improved competitiveness.
However, progress in implementing the Clean Industrial Deal was slow and talk of the de-industrialisation of the EU was increasing in tempo. To maintain the pressure on the European Commission, on 11 February this year, a 500-strong gathering of business leaders under the umbrella of a ‘European Industry Summit’, again held in Antwerp, met Ursula von der Leyen and other Commissioners together with five European Prime Ministers. They urged the Commission to adopt emergency measures to restore competitiveness.
One of the key components of the Clean Industrial Deal was supposed to be an Industrial Accelerator Act. A proposal for this has now been published by the European Commission on 4 March. This introduced targeted ‘Made in EU’ obligations together with low-carbon requirements. The aim is to boost domestic EU demand and reduce reliance on Chinese products. It is of great relevance to public procurement and public support schemes. It mandates minimum percentage shares for products of ‘Union origin’. This would come into force on 1 January 2029. It also applies to specific strategic sectors such as ELVs, where 70% of components by value (excluding batteries) would need to meet these requirements.
With this document still being a proposal, it will be subject to scrutiny by the EU Member States and the European Parliament. One of our principal concerns lies in the definition of ‘EU origin’. Supply chains extend beyond the confines of the Member States. Will our UK-EU Trade and Cooperation Agreement be recognised in this, for example?
Parallel to this, recent developments surrounding the Single-Use Plastics Directive and the End-of-Life Vehicles Regulation have highlighted a clear policy shift that prioritises EU-sourced recycled materials. By tying mandatory recycled content targets directly to material recovered and processed within the EU bloc, these rules could effectively exclude the use of UK recyclate and manufactured components from the European market.
We have raised our concerns with EuPC and most recently pressed this point with the DBT Minister for Industry, Chris MacDonald, at our Parliamentary Reception. It would be unacceptable if EU industry were to receive concessions from the EU institutions and, as a result, UK manufacturing’s competitiveness were weakened.
Needless to say, we are very much alive to this issue and are exploring ways, with other industries, to influence the situation.
Regards,
Philip Law
Director General
British Plastics Federation
Additional Information
Industrial Accelerator Act published (4th March 2026)
The proposal was adopted on 4 March 2026 and is now entering the EU legislative process in the European Parliament and the Council.
Linked to the official publications are below...
Based on preliminary analysis by EuPC of the published text, they would highlighted the following points of potential relevance plastics firms:
Strategic sectors and industrial acceleration
The proposal introduces measures to accelerate industrial capacity and decarbonisation in selected strategic sectors, notably through faster permitting procedures and the creation of “industrial manufacturing acceleration areas”.
Importantly, Annex I includes "Manufacture of rubber and plastic products, as classified under NACE Code C22" and "Manufacture of chemicals and chemical products, as classified under NACE Code C20" among the sectors eligible for these measures.
This means plastics converting projects and plastics raw materials companies (who fall under NACE Code C20 - under "C20.1.6 - Manufacture of plastics in primary forms") could potentially benefit from streamlined permitting procedures and industrial deployment support (in acceleration areas).
Demand-side measures for energy-intensive materials
The proposal also introduces demand-side measures in public procurement and certain public support schemes to promote “Union-origin”(EU+ countries having signed free trade agreement or custom union) : art 8-9 and low-carbon products for specific energy-intensive materials.
According to Annex II, these requirements currently apply to:
- steel, and any product the performance of which depends primarily on steel : at least 25% of the total volume of steel used in the product or project that receives support shall be low-carbon;
- concrete and mortar, and any product the performance of which depends mainly on concrete and mortar: at least 5% of the total volume of concrete and mortar used, including the clinker and cement used to produce them, in the product or project that receives support shall be low-carbon and of Union origin;
- aluminium, and any product the performance of which depends mainly on aluminium: at least 25% of the total volume of aluminium used in the product or project that receives support shall be low-carbon and of Union origin.
At this stage, plastics are not included among the materials subject to these mandatory thresholds. The provisions would apply from 1 January 2029.
Possible future measures affecting the chemical value chain
The proposal empowers the Commission to adopt additional demand-side measures for the chemical industry, including requirements related to substances and mixtures of Union origin derived from sustainable carbon sources.
While these provisions do not yet directly target plastics converters, they could become relevant for polymer feedstocks and circular or bio-based carbon pathways in the future.
Construction products dimension
The proposal also contains an amendment to the Construction Products Regulation (CPR), which would allow the Commission to introduce environmental sustainability labelling requirements, including carbon-intensity related labelling, for construction products.
Although this amendment does not introduce the broader resilience clause mentioned in earlier drafts, it could still have implications for construction materials and value chains in the future.
Timeline
The Industrial Accelerator Act remains at the proposal stage and will now be examined by the European Parliament and the Council.
Indicative timeline:
- Commission proposal published: 4 March 2026
- Negotiations in Parliament and Council: 2026–2027 (indicative)
- Entry into force: after adoption and publication in the Official Journal
- Certain provisions applying after entry into force (6–12 months depending on the article)
- Demand-side requirements for energy-intensive materials: from 1 January 2029
Preliminary assessment provided by EuPC
"At this stage, the proposal makes plastics manufacturing recognised among the strategic industrial sectors eligible for acceleration measures but no direct requirements for/inclusion in Green Public Procurement.
However, the file could evolve during the legislative negotiations. In particular, potential extensions of demand-side measures to additional materials or developments affecting the chemical value chain will need to be closely monitored.
EuPC will continue to follow the legislative process and will keep members informed of relevant developments."
SUPD has been published in the comitology register
Following the briefing the BPF sent to Members on the 12th February 2026 (found HERE)
The link to the draft implementation act in the Comitology Register (D113092/01) can be found HERE
For the purposes of this Decision, the following definitions apply:
‘recycled plastic’ means plastic which was post-consumer plastic waste before recycling, and which has been produced by recycling (including sorting), as defined in Article 3, point (17), of Directive 2008/98/EC and including sorting, in the Union. As of 21 November 2027, it shall also cover post-consumer plastic waste that has been recycled (including sorted) in:
- a third country to which the OECD decision applies, unless the assessment carried out and decision adopted pursuant to Article 45(5) and (6) of Regulation (EU) 2024/1157 concludes that it does not fulfil the requirements of environmentally sound management of plastic waste;
- a third country with which the Union has concluded agreements or arrangements to ensure that the recycled plastic is obtained from post-consumer plastic waste that has been treated in each relevant installation in a manner equivalent to EU standards related to human health and environmental protection requirements under Union legislation, in particular in Directive 2008/98/EC and Regulation (EU) 2025/40, as relevant. The country shall also have a comprehensive waste management framework covering its entire territory and demonstrating its ability and willingness to guarantee environmentally sound waste management, taking into account in particular the following criteria:
(i) the measures implemented and planned to ensure the environmentally sound management of waste within its territory, such as the introduction of an extended producer responsibility system or an equivalent system implementing the polluter pays principle;
(ii) the measures implemented and planned to increase the proportion of plastic recycled from post-consumer plastic waste, and the indicators for monitoring these measures;
(iii) the measures implemented and planned to increase the proportion of plastic recycled from post-consumer plastic waste incorporated in products placed on the national market, and the indicators for monitoring these measures;
