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Spain proposes three-layer solution to define geography for 'Made in EU' act - Finance news and analysis from Global Banking & Finance Review
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Spain proposes three-layer solution to define geography for 'Made in EU' act

Published by Global Banking & Finance Review

Posted on September 24, 2026

2 min read

· Last updated: September 24, 2026

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Spain Suggests Three-Layer System for Defining 'Made in EU' under Industrial Act

Spain's Proposal for the Industrial Accelerator Act

BRUSSELS, Sept 24 (Reuters) - Spain has proposed a three-tier system to determine which third countries qualify as "Made in EU" under the European Commission's planned Industrial Accelerator Act, according to a document from sources at Spain's industry secretariat.

The IAA is part of broader EU efforts to help local industries compete with global rivals, notably China, that do not face Europe's strict regulations and higher energy costs.

Sector-Specific Approach and System Structure

The proposal would allow treatment to vary by sector, avoiding a blanket approach.

Details of the Three-Layer System

  • The first layer would consist of only the bloc's 27 member states. The second layer would include the EEA and "trusted partners" while the third would be countries with a free trade, customs or procurement agreement with the EU.
  • The three-tier system would allow the Commission to act "surgically" rather than exclude "an entire country for lack of reciprocity in just one product", the document said.
  • Countries producing critical components that cannot easily be replaced in the EU could also qualify for the third tier.
  • How the layers are applied could be changed over time as the EU's own capacity grows.
Eligibility and Uncertainties
  • Under the proposed IAA, goods from the 27 EU member states, plus Iceland, Liechtenstein, and Norway - which are part of the European Economic Area (EEA) - would qualify.
  • The final list of exemptions based on trade agreements or reciprocity would not be set until after the act is agreed in 2027, leaving allies such as Britain and Japan uncertain about how their companies will be treated.

(Reporting by Julia PayneEditing by Ros Russell)

Key Takeaways

  • Spain’s proposed three-layer model distinguishes between: (1) EU member states; (2) EEA and trusted partners; (3) countries with trade, customs or procurement deals – enabling nuanced ‘Made in EU’ treatment depending on sector.
  • The Industrial Accelerator Act (IAA), introduced by the European Commission in March 2026, aims to boost EU industrial competitiveness, set a target of 20% GDP manufacturing share by 2035, and link public procurement to ‘Made in EU’ and low‑carbon requirements in strategic sectors such as net‑zero technologies, energy‑intensive industries, and automotive (europarl.europa.eu).
  • The three‑tier system would allow the EU to act ‘surgically’—excluding or including countries flexibly based on reciprocity, strategic dependencies, or critical components, and could evolve over time as EU industrial capacity grows (observatory.clean-hydrogen.europa.eu).

References

Frequently Asked Questions

What is Spain's proposed system for the 'Made in EU' act?
Spain proposes a three-tier system to determine which countries qualify as 'Made in EU' under the Industrial Accelerator Act.
Which countries fall under the three layers of Spain's proposal?
The first layer covers EU member states, the second includes EEA and trusted partners, and the third features countries with EU trade, customs, or procurement agreements.
How could the layers in the three-tier system be applied over time?
The way layers are applied may change as the EU's own industrial capacity grows.
When will the final list of trade agreement exemptions be set?
The final list of exemptions will not be decided until after the act is agreed in 2027.
What impact could the proposal have on countries like Britain and Japan?
There is uncertainty for countries such as Britain and Japan regarding whether their companies will qualify under the act.

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