Made in EU starts at 5% concrete and says nothing about the software

The European Commission published the Industrial Accelerator Act on 4 March 2026 as COM(2026)100, with an impact assessment and three staff working documents attached ^[1]. For anyone building physical product in Europe, the operative detail is that the origin rules are sectoral and uneven, and that the software stack your engineers actually work in is not mentioned ^[7][11].

Start with the numbers, because they are the part being quoted loosest. From 1 January 2029, concrete and mortar used in buildings, infrastructure or vehicles must carry at least 5% Union-origin content ^[4]. Aluminium must carry 25% ^[5]. Steel carries no origin requirement at all and gets low-carbon criteria instead ^[6]. A 5% floor leaves 95% of the concrete sourceable from anywhere ^[12], and the 25% aluminium floor leaves three quarters open ^[13]. Neither number rebuilds a supply chain on its own ^[14].

The modesty is deliberate. The Act carries general derogations wherever origin requirements would produce insufficient competition, disproportionate costs, technical incompatibility or significant delays ^[9]. That is careful drafting and also a wide exit.

Where the Act is actually demanding is vehicles. Electric, plug-in hybrid and fuel-cell vehicles face EU assembly requirements, minimum EU content thresholds for components and specific battery sourcing rules, applying six months after the Act enters into force ^[7]. That is the shortest clock in the file, roughly two and a half years earlier than the concrete date if entry into force lands in 2026 ^[15]. Net-zero technologies get differentiated thresholds through amendments to the Net-Zero Industry Act, covering solar, batteries, heat pumps, wind and nuclear ^[8]. Scope is drawn by NACE code: energy-intensive industries C17, C19, C20, C22, C23 and C24, plus automotive C29 ^[10]. None of those codes is software.

This is a proposal, not law, and Parliament and Council have yet to take positions ^[2][3]. It is also being read as broader than it is. Nothing in the origin rules touches engineering software, cloud hosting or design tools ^[11]. Christina Rebel, chief executive of the engineering collaboration platform CAD ROOMS, told tech.eu that it should: "If Made in EU becomes a condition of public procurement, the conversation can't stop at the product rolling off the line. It has to start much earlier" ^[16][17]. Read that as advocacy for extending the text, not a description of it. CAD ROOMS is EU-hosted, end-to-end encrypted and ISO certified, and it competes directly with the US platforms she is describing ^[20].

The underlying observation survives the conflict of interest. Most European engineering teams run product development on US-hosted platforms, which means CAD files, revisions and design IP sit on infrastructure outside EU jurisdiction, whatever label the finished unit carries ^[18][19]. The same argument produced the Airbus and Scaleway sovereign cloud against the American hyperscalers ^[21].

The bigger constraint is upstream of both. Enclosures can be fabricated in Europe or the US; the core electronics inside them frequently cannot ^[22]. Rebel says components "simply weren't available locally, or the European pricing made the final product uncompetitive" ^[23]. That is ecosystem depth, with suppliers, manufacturing expertise and founders sitting within reach of each other in China ^[24], and the same pattern now shows in robotics: China builds 97% of humanoid robots shipped worldwide ^[25].

What to watch: whether Parliament raises the concrete and aluminium floors or widens the derogations, and whether the automotive battery sourcing rules survive first contact with carmakers who cannot meet them in six months ^[3][7][9].