Subject: FW: Amendments proposals to Industrial Accelerator Act
From: "info - MKM" <[email-masked]>
To: "info - MKM" <[email-masked]>
Date: Tue, 7 Apr 2026 14:01:43 +0300

_____

From: Vasileios Tsianos <[email-masked]
<mailto:[email-masked]> >
Sent: Tuesday, March 31, 2026 12:52:18 PM
To: Peeter Kadarik - MKM <[email-masked]
<mailto:[email-masked]> >; Margus Raha
<[email-masked]
<mailto:[email-masked]> >
Subject: Amendments proposals to Industrial Accelerator Act

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Kind greetings,

The proposed amendments to the IAA from Neo:

We ask that the EU amend Annex II so that, where a wind turbine uses
permanent magnets, those magnets must be one of the mandatory Union-origin
components, and make that rule binding in auctions as a pre-qualification
condition. Specifically:

1.	No need not reopen the 2025/1178 list unless you need to narrow
the term to rare-earth sintered magnets specifically. It already lists
“permanent magnets of wind turbines” as a main specific component for both
onshore and offshore wind. The actual loophole is in the IAA draft, which
lets wind comply via other components, so magnets can still be skipped.

2.	Main redline: amend IAA proposal COM(2026)100, Article 34(8),
Annex II, Part I point 1(d), and Part II point (d) to add:
“Where the wind turbine incorporates permanent magnets, permanent magnets
of wind turbines shall constitute one of the main specific components
required to originate in the Union.”
Use “originate in the Union”, not “EU producer,” because that is the
draft’s legal test.

3.	We need a real magnet quota, not just mandatory inclusion. We
recommend to add a percentage in the same two Annex II points:
“For wind turbines incorporating permanent magnets, at least [>30]% of the
value of the permanent magnets of wind turbines incorporated in the wind
turbine shall originate in the Union.”
That is the cleanest way to create a legal domestic-share rule for magnets
themselves.

4.	For offshore wind, amend auctions too, not only procurement. In
Article 26 / Annex II Part II(d), make the magnet requirement a
pre-qualification criterion, not just an award criterion. The Commission’s
impact assessment says auctions drive about 60% of EU wind deployment, so
procurement-only misses much of offshore wind.
5.	Close the origin-equivalence workaround. Add a carve-out in
Articles 28e and 28f so FTA/customs-union/GPA-origin content does not
automatically count as Union-origin for wind magnets. Otherwise non-EU
magnet content can still qualify.
6.	Tighten the waivers if the mandate must be real. Carve the
wind-magnet rule out of Article 25a(3)(c)-(d) and Article 26(5), otherwise
cost and delay derogations can waive it.
7.	One-line legal gap statement: CRMA creates upstream supply,
circularity, recyclability and recycled-content rules for permanent
magnets, but not downstream sourcing mandates for wind developers; current
NZIA resilience rules are anti-concentration rules, not EU local-content
obligations.
8.	Recital support: add a recital stating that an explicit
wind-magnet rule is justified because the Commission’s own impact
assessment identifies about 93% single-country dependency for permanent
magnets of wind turbines, and the current one-/two-component wind rule
does not guarantee that this dependency is covered.

With appreciation,

Vasileios Tsianos
Senior Vice President
Neo Performance Materials (TSX: NEO)

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