On October 5, 2026, Transport & Environment (T&E), European Metals and RECHARGE asked EU co-decision makers to add Union-content incentive thresholds for refined battery-grade critical raw materials, precursor cathode active material (pCAM), anode active material (AAM) and recycled materials to the Industrial Accelerator Act (IAA). This is a policy request, not an adopted requirement. The organizations say the measures could make demand more predictable and strengthen investment confidence for battery-chain projects in Europe and trusted partner countries.
What the October 5 letter asks the EU to add
The joint letter calls for minimum thresholds covering four categories in the Union-content incentives listed in Annex III: refined battery-grade critical raw materials, pCAM, AAM and recycled materials. The request is to recognize more stages and inputs in the battery value chain, rather than focusing incentives only on finished cells or a narrow set of components.
The signatories frame the IAA as a way to create demand certainty: if qualifying materials and intermediate products are included in incentives, they argue, projects may have a stronger basis for investment decisions. Their proposed reach includes projects in Europe and trusted partner countries. The October 5 account does not specify the proposed threshold values, the precise origin test, or how the criteria would work across individual incentive programs.
Why they argue for a whole-chain approach
The letter reflects a broader position shared by T&E, EIES and RECHARGE in a July 1, 2026 statement: battery resilience depends on more than cell production. That statement describes a chain spanning extraction and refining, key component manufacturing, cell production and recycling, and calls for support for battery-grade strategic materials, pCAM, AAM and locally recycled battery metals.
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In this chain, pCAM and AAM are intermediate active materials used in battery electrodes, while cells are the units assembled into batteries. Including upstream refined materials and these intermediate products in Union-content incentives could, in the signatories’ view, encourage investment at stages that feed into cell manufacturing as well as recycling.
What this means for car and battery manufacturing
For automakers and battery producers, the proposal is about where the inputs to a battery are made or processed, not simply where final assembly happens. Its potential effect would depend on the final eligibility rules: which stages count, how origin is established, whether trusted partners qualify, and how thresholds apply to public procurement, subsidies or tax incentives.
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T&E’s separate May 2026 IAA briefing advocated robust Union-origin incentives, a focus on strategic components, support for pCAM, AAM, critical raw materials and recycled content, foreign-direct-investment conditions, and low-carbon steel and aluminium requirements. Those points describe T&E’s wider advocacy agenda; they should not be read as the exact contents of the October joint letter.
What is known—and what is not—about the IAA’s status
The October 5 letter addresses co-decision makers while IAA negotiations are progressing. The organizational pages available for this account establish what the signatories requested, but do not establish that the proposed battery-material thresholds were adopted or what the final legal text says. The request should therefore be described as advocacy, not as a current legal obligation on manufacturers.
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T&E’s October 1, 2026 analysis discusses European cell-supply feasibility and the midstream role of CAM and pCAM. Its conclusion depends on all projects materialising, including projects it classifies as medium confidence. That is T&E’s assessment and assumption, not an independently verified projection here; it is separate from the specific terms requested in the October 5 letter.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Who the signatories are
T&E is an environmental advocacy organization, European Metals is a signatory to the letter, and RECHARGE describes itself as Europe’s industry association for advanced rechargeable and lithium batteries. The participation of organizations with different roles signals a shared policy request, but does not make the letter a neutral legislative assessment.
Quick Recap
Sources
- T&E, European Metals and RECHARGE call on co-decision makers to strengthen battery supply chains in the IAA, October 5, 2026.
- T&E, EIES and RECHARGE joint statement on the Industrial Accelerator Act, July 1, 2026.
- T&E, Boosting Made-in-EU EVs and batteries with the Industrial Accelerator Act (IAA), May 4, 2026.
- T&E, Ready to scale: Europe will have enough cells to meet demand and grow its domestic battery value chain industry, October 1, 2026.
- RECHARGE — European Battery Industry Association.
- T&E Batteries publications index.
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