Europe Has Its Own Version of the Inflation Reduction Act That Could Impact US Manufacturers
Key Highlights
- The EU’s IAA introduces 'Made in EU' and low-carbon requirements, impacting procurement, subsidies and foreign investments in sensitive sectors.
- European policies aim to retain industrial capacity, jobs and innovation within the continent, especially in strategic sectors like clean-tech and semiconductors.
- U.S. manufacturers will need to reassess supply chains, ownership structures and manufacturing footprints to meet new eligibility and localization standards.
- Executives should act swiftly to identify vulnerabilities, build strategic partnerships and develop flexible operational models before regulations fully take effect.
A German automaker could soon discover that building vehicles in Mexico with Chinese batteries may disqualify it from competing for parts of Europe’s future industrial economy.
Ever since the Reagan-Thatcher revolution of the 1980s, and especially after the end of the Cold War, companies have operated in an environment where economics generally outweighed geopolitical and national security considerations. Governments broadly embraced free trade, deregulation and market liberalization, enabling multinationals to build globally integrated supply chains optimized for efficiency and cost.
That era is now beginning to fade. The Inflation Reduction Act (IRA), signed into law on August 16, 2022, marked a major turning point. It signaled that even the United States, long the leading champion of free-market globalization, was once again embracing industrial policy as a strategic tool. More broadly, it reflected a growing shift in how governments think about industrial capacity, supply chains, economic security and technological leadership.
Now the European Union (EU) is responding with something potentially even more disruptive: an industrial policy framework designed not merely to attract investment, but to redefine who qualifies to compete in Europe at all.
Streamlined Permitting, Made in EU Requirements
The EU’s Industrial Accelerator Act (IAA), unveiled in March 2026, marks a significant shift in European industrial policy away from climate ambition alone and toward competitiveness, resilience and strategic autonomy. The Act introduces “Made in EU” and low-carbon requirements for public procurement and state aid. It also streamlines industrial permitting through digital one-stop approval systems, creates industrial acceleration zones with simplified approvals and imposes tighter conditions on large foreign investments in sensitive sectors.
For European policymakers, the IAA is not merely protectionism. It is also a response to mounting concerns over industrial hollowing-out, Chinese clean-tech dominance and the geopolitical vulnerabilities exposed by the energy crisis following Russia’s invasion of Ukraine. If European taxpayers subsidize the energy transition, Europe increasingly wants the factories, jobs, intellectual property and industrial capacity tied to that transition to remain in Europe as well.
IAA Goes Further
The key difference between the IRA and the IAA is subtle but profound. The IRA primarily uses subsidies to attract investment into the United States. The IAA goes further by embedding industrial policy directly into market access itself. Public procurement and support schemes could increasingly favor EU-origin products, local value-add and low-carbon compliance.
In practice, this could affect everything from EV battery sourcing and grid equipment manufacturing to low-carbon steel, industrial automation systems, transformers and semiconductor packaging. An automotive supplier using Chinese cathode materials, Korean battery cells and final assembly in Eastern Europe could face a materially different competitive position under future EU procurement and subsidy rules.
The IAA represents a new form of industrial policy built around eligibility, resilience and strategic alignment rather than traditional tariff barriers alone. As a result, competition may increasingly shift away from lowest-cost supply chains toward what might be called “qualified supply chains” that satisfy political, regulatory, carbon and localization requirements. Companies will also need to determine whether their ownership structures, sourcing models, supplier networks and manufacturing footprints satisfy whatever definition of “European” ultimately emerges.
Ironically, the primary geopolitical target is not the United States, but China. European policymakers increasingly fear losing control of EV, battery, clean-tech and industrial supply chains to Chinese competitors, particularly in sectors tied to decarbonization and strategic technologies.
For American firms with globally distributed supply chains, the operational implications we discuss below could be significant.
Market access pressure
Access to public procurement, subsidies and policy-supported demand pools could increasingly depend on origin, local assembly and carbon compliance. Export-led models into Europe may gradually lose competitiveness even if their products remain technologically superior.
Structural cost gap
European manufacturers may benefit from subsidies, accelerated permitting, infrastructure prioritization and regulatory advantages that improve project economics. Meanwhile, global supply chains could face mounting compliance burdens tied to traceability, audits, certification and carbon reporting.
Investment diversion
Capital, suppliers, talent and manufacturing clusters are likely to concentrate around favored European industrial hubs. Early movers may secure subsidies, strategic sites, preferred supplier relationships and advantages that become difficult to replicate later.
Supply-chain redesign
The proposal includes provisions tied to local employment, EU sourcing, domestic R&D spending and ownership structures for major investments. Many firms may discover that some degree of localization becomes necessary simply to preserve long-term competitiveness.
A Shift in Strategy
Manufacturers may increasingly need to replace globally integrated supply chains with parallel regional operating models built around competing geopolitical blocs, each with distinct industrial policies, regulatory regimes and supply-chain requirements. That shift may challenge one of the foundational assumptions of modern operations management: that maximum efficiency always minimizes cost.
For decades, manufacturers pursued hyper-optimized just-in-time supply chains with minimal redundancy. In a world of tariffs, export controls, industrial policy, geopolitical shocks and supply disruptions, “just in case” capabilities may become strategically and financially superior to “just in time” efficiency. Global fragility may prove more expensive than regional redundancy.
For C-suite executives, this creates a profoundly uncomfortable reality: The operating model that dominated the post-Cold War economy may no longer fit the geopolitical realities now replacing it.
Should Europe remain primarily an export market, or become a localized manufacturing base? Which technologies and components are strategically important enough to move? Which supply-chain steps must become European, and which can remain global? How much redundancy should companies build into their operations? And perhaps most importantly: how much strategic flexibility should companies preserve before committing capital?
These are no longer operational questions delegated to procurement teams or regional business units but board-level strategic decisions with multi-billion-dollar implications.
Traditional strategic planning tools are poorly suited for this environment. Executives will need to think more in terms of scenarios than forecasts. Geopolitical foresight and adaptability are rapidly becoming core organizational capabilities in their own right.
More broadly, executives should begin preparing for a world in which competitiveness depends not only on operational excellence, but also on geopolitical alignment.
More importantly, executives should resist the temptation to wait for perfect clarity, as the IAA is still evolving politically. EU member states remain divided over how far and how fast the framework should go. France favors a stricter EU-only approach, while countries such as Germany and the Netherlands advocate greater flexibility and WTO compatibility. As with many EU industrial initiatives, implementation may ultimately prove more fragmented and uneven than the initial political ambition suggests. Final adoption may still be more than a year away.
Yet this creates a strategic paradox: By the time the rules are fully finalized, the best sites, suppliers, partnerships and incentive pools may already be spoken for.
That creates a narrow but important strategic window. Over the next six months, companies still have time to assess exposure, preserve flexibility, secure partnerships and position investments before industrial ecosystems begin to solidify around the new framework. The smartest firms will likely focus first on “no-regret moves”: identifying vulnerable supply-chain bottlenecks, improving traceability capabilities, evaluating alternative manufacturing footprints and exploring strategic partnerships inside Europe.
Companies that wait for regulatory certainty before adapting may ultimately discover that the geopolitical map of global manufacturing has already been redrawn without them.
About the Author
John Jullens
AMG Leadership Team Member, Arthur D. Little/Managing Partner, Arbalète LLC
John has more than 30 years of management consulting and industry experience in North America, Europe, and China. He specializes in developing growth strategies for clients in the automotive and industrial manufacturing sectors, including demand-side transformation, new market entry, globalization/emerging markets, brand and customer strategies, organizational redesign, and M&A due diligence and post-merger integration. He has published extensively on these topics for such leading publications as Harvard Business Review, Harvard Business Review China, CEIBS Business Review, and Strategy+Business.
Florent Nanse
Partner, Arthur D. Little
Florent is a partner based in the Boston office of Arthur D. Little. He is a member of the Automotive & Industrial practice as well as a core leader of ADL’s Global Growth Competency Center. Florent is primarily active in the manufacturing industries, where he focuses on topics involving result-driven growth strategy, go-to-market strategies, business building, technology and innovation and sustainability. A committed leader of ADL Global ESG initiatives, Florent holds an engineering degree from the Ecole Nationale Supérieure d’Arts et Métiers and a master’s degree in strategic management from HEC Paris.
