立场文件-“欧洲制造”内容要求

ACEApositionpaper“Made in Europe”ContentRequirements INTRODUCTION The European Commission is planning to introduce sustainability, resilience, and minimumEU content requirements in procurement for strategic sectors, particularly targeting theautomotive industry. This includes setting European content thresholds for battery cells andcomponents in electric vehicles, as well as mandating minimum levels of European-madesteel, components, and batteries in corporate fleets under the upcoming Green CorporateFleets proposal. These measures aim to support low-carbon productsand strengthendomestic industrial capabilities. However, the introduction ofLocalContentRequirements (LCRs) must be handled carefullyto avoid negative impacts on competitiveness, supply chain efficiency, and market dynamics.The lack of clarity around the scope, definitions, and timelines of these requirements makesit difficult to assess their full impact. This position paperemphasises that “Made in Europe”policies alone are insufficient.Instead, a strong industrial base requiresfavourableconditionssuch as competitive energy prices, streamlined permitting, skilledlabour, and targetedincentives. Theautomotive industry urges theCommission to conduct a thorough impactassessment and engage with industry experts before moving forward with legislation. KEY RECOMMENDATIONS 1.Ensure legislative coherence and realismTo ensure effective implementation of local content requirements (LCRs) in EU initiatives like the Industrial Decarbonisation Accelerator Act and Green CorporateFleets, coordination across legislative frameworks is essential. Any proposedmeasures must bebased on consistent definitions–particularly for batteries,aligning with the existing Batteries Regulation–and should clearly outline whichstages of the value chain are affected. Given the already heavy regulatory burdenon the automotive sector, any new reporting obligations should be kept minimal.Before advancing legislation, the Commission should organise a dedicated expertworkshop to assess the potential impacts of “Made in Europe” and sustainabilityrequirements on the battery value chain, with findings feeding into a comprehensiveimpact assessment. 2.Prioritise gradual, case-by-case implementationGiven the complexity and global nature of automotive supply chains, any local content requirements must be introduced gradually, with sufficient lead time andtailored to different vehicle segments. A one-size-fits-all approach risks disruptionand reducedcompetitiveness.Instead, targeted incentives and differentiatedtreatment–especially for buses and heavy-duty vehicles–are essential to supportsustainable industrial growth. 3.Focus on incentives over mandatesTo attract investment in Europe’s battery value chain, supportive industrial and trade policies–like lower energy costs, streamlined permitting, and skilledlabour–areessential. Content targets alone are insufficient:they must be paired with incentives to avoid market distortion and rising manufacturing costs. A clear definition of “Madein Europe” and a thorough impact assessment are crucial before introducing anylocal manufacturing mandates. 4.Trade and international partnershipsLocal content requirements must be carefully balanced to preserve international partnerships, comply with trade rules, and avoid market retaliation. Europe’s batteryvalue chain depends on global cooperation, and overly strict “Made in Europe”mandates could jeopardise existing agreements and limit EU firms’ global marketaccess. Reciprocity and clear definitions are essential to avoid unintendedconsequences. 5.Local Content Requirements origin determination A change of tariff classificationfor local content requirements would be the leastburdensome option, while value-added criteria and specific processing rules riskhigh administrative complexity and uncertainty, especially with evolvingtechnologies. Existing preferential rules of origin (ROO) are outdated and optional,making them a poor fit for mandatory LCRs. Any new approach must minimisecompliancestrains and reflect current industry realities. MINIMUM “MADE IN EUROPE”CONTENTREQUIREMENTS The European Commission intends to setsustainability, resilience, and minimum EU contentrequirements in public and private procurement in strategic sectors to ensure lead marketsfor low-carbon products under the Industrial Decarbonisation Accelerator Act.Specifically, italsointends to set upEuropean content requirements on battery cells and components inelectric vehiclessold inthe EU.Additionally, the Commission intends to introduce a minimumlevel of Europeansteel, Europeancomponents, and Europeanbatteries in corporate vehiclefleets in the upcoming proposal on Green Corporate Fleets. The introduction of sustainabilityandresilience and/orlocalcontentrequirements (LCRs) forthe EU automotive sector must be approached cautiously, strategically, and holistically toensure that they do notundermine the competitiveness of the v