CCCEU Statement on the EU “Industrial Accelerator Act"

Brussels, 4 March 2026

The China Chamber of Commerce to the EU (CCCEU) has taken note of the European Commission’s proposal for the “Industrial Accelerator Act” published on 4 March. As the representative voice of Chinese-invested enterprises in Europe, we recognize the European Union’s strategic objectives of enhancing competitiveness, advancing the green transition, and safeguarding economic security. 

However, we express serious concern and opposition regarding certain provisions of the proposal that may have far-reaching implications for market openness, fair competition, and China–EU economic and trade cooperation.

I. Core Concern: Challenges to the Principle of Market Openness

We regret to observe that the proposal, through the introduction of extensive “Made in Europe” localisation requirements, mandatory technology transfer provisions, and stringent scrutiny of foreign investment, would significantly reshape market access rules within the EU.

While we understand the EU’s intention to strengthen supply chain resilience, the current design of the Act risks shifting toward a more exclusionary and protectionist framework. Such a direction may send signals of uncertainty to global investors, including Chinese enterprises, and could undermine the EU’s long-standing reputation as an open and rules-based market.

II. Specific Concerns: Systemic Risks Arising from Protectionist Instruments

We believe several mechanisms under the proposal could have substantial practical impacts on Chinese enterprises and their European partners:

Rising Costs and Reduced Industrial Efficiency

Mandatory use of higher-cost local components and still-maturing “low-carbon materials” could directly increase production costs for European manufacturing sectors, particularly downstream industries such as automotive and construction. These additional costs are ultimately likely to be borne by European businesses and consumers, potentially weakening the long-term global competitiveness of European products.

Barriers to Investment

The Act introduces targeted investment barriers in sectors such as batteries, photovoltaics, electric vehicles, and critical raw materials. Chapter IV, which includes a 49% ownership cap, mandatory intellectual property licensing requirements, and local employment quotas, effectively creates obstacles for large-scale investment from certain countries. Such measures may restrict the free flow of capital and hinder the deployment of advanced technologies and global best practices within the EU. Technology cooperation should be based on commercial willingness, not administrative compulsion.

The “Trusted Partner” Framework

Of particular concern is the establishment of an exclusive “trusted partner” system. Under Articles 8 and 9 of the proposal, products originating from third countries that have concluded a free trade agreement with the EU or are parties to the Government Procurement Agreement may, under certain conditions, be treated as equivalent to EU origin. As China is not included in this framework, the arrangement risks creating institutional discrimination. This could place Chinese enterprises and their European partners at a disadvantage when participating in EU public procurement and public support schemes, leading to an uneven competitive environment.

Increased Administrative Complexity

The Act introduces multi-layered review, reporting, and compliance mechanisms, including public procurement exemption applications and continuous foreign investment monitoring. These measures may impose significant burdens on Member State authorities and increase compliance costs for enterprises, particularly small and medium-sized companies.

III. Potential Impact on China–EU Industrial Cooperation

China’s strengths in clean energy, electric vehicles, and battery supply chains are the result of long-term market competition and sustained innovation, not unfair practices. Over the years, Chinese investment—through greenfield projects, technology partnerships, and job creation—has contributed positively to the EU’s green transition and industrial development.

We are concerned that restrictive provisions in the Act may:

Delay European industries’ access to mature and efficient supply chain support, potentially slowing the EU’s decarbonisation process;

Lead to a “lose-lose” outcome, whereby Europe risks losing high-quality partners and cost advantages, while Chinese enterprises face increased market access uncertainty;

Trigger retaliatory measures from trade partners, ultimately affecting European companies’ global interests;

Hinder China–EU joint ventures from cooperating in third markets under normal commercial arrangements.

IV. Calls and Recommendations

The CCCEU calls on the EU, in advancing the relevant legislative process, to effectively uphold the principles of fairness, impartiality, and non-discrimination in the investment environment, and to continue providing an open, transparent, and predictable business climate for all market participants, including foreign investors.We recommend that legislators give full consideration to the following aspects when examining the Act:

Uphold the principle of proportionality.

Thoroughly assess the real impact of localisation requirements and investment conditions on markets and industries, and avoid one-size-fits-all restrictive measures. Enterprises should retain the flexibility to determine optimal supply chain configurations.

Clarify the applicability of exceptions.

Establish clear, transparent, and operational exemption mechanisms in public procurement and investment review processes to ensure projects can proceed smoothly in cases of supply shortages or technical infeasibility.

Strengthen rule neutrality.

Ensure that implementing measures do not discriminate against any foreign investors and remain consistent with the principles of most-favoured-nation treatment and national treatment. Technology transfer and intellectual property licensing should be conducted on a voluntary, commercially negotiated basis, with full protection of trade secrets.

Reinforce dialogue and cooperation.

China and the EU share broad common interests in addressing climate change and advancing industrial transformation. We encourage both sides to make full use of mechanisms such as the China–EU Summit and high-level dialogues on trade, green development, and digital cooperation to establish channels of consultation and explore room for cooperation in the implementation of the Act.

The Chinese businesses remain committed to serving as reliable partners in Europe’s green trnansition and economic prosperity. We will continue to closely follow the legislative developments of the Act and maintain constructive engagement with EU institutions, Member States, and stakeholders, with the aim of promoting an open, fair, and predictable environment for China–EU economic and trade cooperation.