Streamlining European preference – keep it targeted and workable

In its response to the proposed Industrial Accelerator Act, The Confederation of Swedish Enterprise calls for simpler rules, greater legal certainty and an outward-looking approach to trade and supply chains.

A central feature of the proposal is the introduction of European preference in public procurement and financing. The current design risks becoming overly broad and administratively burdensome. For European preference to be more proportionate, it must be targeted and streamlined:

Exclude basic raw materials such as aluminium, concrete and mortar from the scope of European preference. Due to the structure of the Union origin rules, the proposal is unlikely to target primary raw material production directly, but rather a vaguely defined range of downstream products containing these materials. This creates uncertainty regarding its effects and makes implementation more difficult.
Recognise that net-zero technologies are already covered by dedicated rules in the Net-Zero Industry Act (NZIA), including provisions on resilience and diversification. Introducing overlapping European preference requirements risks duplication, added administrative burden, and regulatory inconsistency.
Ensure predictability and simplicity in implementation, limiting verification requirements and compliance costs for contracting authorities and firms.

There is also a strong case for maintaining a wide scope of partner countries within the regime. Europe’s industry depends on global supply chains, and access to reliable inputs from trusted partners is essential for competitiveness. A narrow interpretation of “European” risks increasing input costs for European manufacturers, reducing flexibility in sourcing and harming the EU’s reputation in free trade negotiations.

An outward‑looking approach is therefore key to ensuring that European preference does not translate into European isolation. From a business perspective, it is also important to provide greater legal certainty as to exactly which countries fall within the scope.

Lead markets and low‑carbon criteria – a positive and necessary step

In contrast, the proposal’s emphasis on creating lead markets for low‑CO₂ products is both reasonable and promising.

Europe’s climate targets require a rapid scale‑up of low‑carbon technologies and materials. Yet today, producers often face a “green premium”, with higher costs compared to conventional alternatives. Public procurement can play a decisive role in bridging this gap. This approach aligns industrial policy with climate objectives and has the potential to drive both innovation and competitiveness.

To succeed, however, the lead market provisions must be carefully designed to ensure that the criteria are both realistic and ambitious. We endorse that the proposal refers to the ESPR processes and the Construction Products Regulation for defining what counts as low-carbon, which in turn will affect the suitable level of low-carbon content for the raw materials in scope.

Read our detailed position paper for a deeper dive into these issues and other aspects of the Industrial Accelerator Act.