The Net-Zero Industry Act: Positioning Europe’s Clean-Tech Manufacturers for Growth—and Compliance

Europe’s ambition to build a competitive, resilient clean-technology industry at home has taken concrete legislative form in the Net-Zero Industry Act (NZIA). For manufacturers, project developers, investors, and public contracting authorities alike, the Act introduces a new set of obligations, opportunities, and procedural pathways that require careful navigation. At [Company Name], our team has developed focused expertise in the NZIA’s fast-evolving implementation landscape, helping clients turn regulatory complexity into a genuine competitive edge.

What the Net-Zero Industry Act Sets Out to Achieve

The NZIA emerged from the EU’s Green Deal Industrial Plan with a clear industrial policy objective: scaling up the EU’s manufacturing capacity for clean technologies so that the Union’s overall net-zero technology manufacturing capacity approaches or reaches at least 40% of its annual deployment needs by 2030. The Act was published in the Official Journal on 28 June 2024 and entered into force the following day, and it now sits alongside a growing body of secondary legislation that continues to refine its practical application.

Rather than functioning as a single, static rulebook, the NZIA is best understood as a framework still being built out in real time—one where delegated acts, implementing regulations, and Commission guidance published well into 2025 and 2026 continue to determine exactly how core provisions apply in practice.

Core Pillars of the Act

Simplified and Accelerated Permitting
Member States are required to establish Single Points of Contact responsible for coordinating the entire permit-granting process for net-zero manufacturing projects. Standard manufacturing projects benefit from defined timeframes of 12–18 months, while projects awarded “strategic” status benefit from faster timelines of 9–12 months. Where an environmental impact assessment is required, the Act imposes a maximum 90-day period for the competent authority to render its decision once all relevant information has been received.

Net-Zero Strategic Projects
Manufacturing projects, CO2 capture projects, storage projects, or transport infrastructure projects deemed essential to EU resilience and competitiveness can apply for “net-zero strategic project” status. This designation brings priority national status, accelerated permitting, dedicated financing advice through the Net-Zero Europe Platform, and urgent treatment in judicial and dispute resolution procedures. The Commission adopted implementing guidelines on assessing these applications on 18 June 2025.

Resilience and Non-Price Criteria in Public Procurement and Auctions
One of the NZIA’s most distinctive features is its resilience mechanism. In renewable energy auctions, authorities must apply non-price criteria—covering sustainability, resilience, cybersecurity, and responsible business conduct—to at least 30% of the volume auctioned annually in each Member State, or 6 gigawatts, whichever standard applies. Where the Commission identifies a critical third-country dependency (broadly, where more than 50% of supply for a given technology or its main components originates from that country), no more than 50% of a tender’s value may be sourced from that country. Implementing Regulation (EU) 2026/718 has since set out minimum environmental sustainability requirements that contracting authorities must apply in specified public tenders.

CO2 Storage and Carbon Management
The Act tackles a critical bottleneck for carbon capture investment: storage capacity. It requires Member States to make data on permittable CO2 storage sites publicly available, and it places an obligation on oil and gas producers to contribute to building EU CO2 storage infrastructure toward the Union’s injection capacity target—a delegated act on this obligation entered into force on 26 July 2025.

Skills and Platform Governance
The Act establishes Net-Zero Industry Academies to build the workforce needed for this transition, overseen by the Net-Zero Europe Platform, which brings together the Commission and Member States to coordinate implementation and can invite industry representatives and experts to participate.

A Regulatory Framework Still Taking Shape

For businesses trying to plan investment or compliance strategy around the NZIA, one of the central challenges is that key scope-defining details have been arriving progressively rather than all at once. Secondary legislation issued through 2025 has clarified which manufacturing projects and components qualify for the Act’s provisions on permitting, strategic project status, and resilience criteria, with Member States expected to implement associated auction and procurement rules from 2026 onward. Further changes may be on the horizon: a proposed Industrial Decarbonisation Accelerator Act is expected to build on the NZIA, potentially strengthening Union-origin requirements and introducing additional measures on permitting, procurement, and foreign direct investment in strategic sectors.

This layered, evolving structure means that a project’s eligibility for accelerated permitting, strategic status, or favourable procurement treatment can shift as new delegated and implementing acts are published—making ongoing regulatory monitoring essential rather than optional.

How We Support Clients Under the NZIA

Scope and Eligibility Assessment
We help manufacturers determine whether their products, components, or machinery fall within the Act’s scope, drawing on the latest delegated acts defining net-zero technologies and their primary components.

Strategic Project Applications
We guide clients through the process of applying for net-zero strategic project status, positioning applications against the Commission’s assessment criteria to maximise the chance of securing priority treatment and accelerated permitting.

Permitting Navigation
We work with project developers to engage effectively with national Single Points of Contact, helping projects move through permitting procedures within the Act’s mandated timeframes.

Procurement and Auction Strategy
For clients bidding into public tenders or renewable energy auctions, we help structure bids that satisfy resilience, sustainability, and cybersecurity criteria—particularly where third-country dependency thresholds affect eligibility.

Regulatory Horizon-Scanning
Given how much of the NZIA’s practical detail continues to arrive through secondary legislation, we provide continuous tracking of delegated acts, implementing regulations, and forthcoming legislation such as the Industrial Decarbonisation Accelerator Act, ensuring clients are never planning against an outdated picture of the rules.

Cross-Framework Integration
We help clients understand how NZIA obligations interact with related instruments—including state aid flexibilities under the Green Deal Industrial Plan, the EU’s carbon management and storage policies, and broader industrial decarbonisation initiatives—so that compliance strategies work coherently across the full regulatory landscape rather than in isolation.

Positioning for What Comes Next

The Net-Zero Industry Act represents a significant bet by the EU that regulatory certainty, faster permitting, and demand-side support can rebuild European manufacturing capacity in clean technologies. For businesses positioned to benefit—or those needing to adapt to new procurement and resilience requirements—the window to shape outcomes is now, while implementing rules are still being finalised and strategic project status remains genuinely competitive. Our team is ready to help clients navigate this landscape with clarity and confidence.