The European Union is rewriting the rulebook for who gets to participate in its clean energy economy — and doing so at speed. On 4 March 2026, the European Commission published its long-awaited proposal for the Industrial Accelerator Act (IAA), a sweeping piece of legislation that combines "Made in EU" procurement preferences, fast-tracked industrial permitting, and — most consequentially for foreign investors — a new mandatory approval regime for large inbound investments in strategic sectors. Batteries and energy storage systems sit squarely at the centre of it.
For Taiwanese battery and energy companies, the IAA arrives at a pivotal moment. Taiwan has quietly built one of the world's most sophisticated battery industry chains, and a handful of its companies — most visibly ProLogium Technology — have staked significant capital on winning a place in Europe's energy transition. Whether the IAA ultimately smooths or complicates that ambition depends on which clause you read first.
The Regulatory Landscape: A Thickening Web
To understand the IAA's implications, it helps to see it as the capstone of a regulatory architecture the EU has been assembling for several years. The EU Battery Regulation (2023/1542), which entered into force in August 2023 and is being phased in through 2032, already imposes demanding requirements on any battery sold in the EU market: carbon footprint declarations for EV batteries were due by February 2025; digital battery passports (containing carbon footprint, material origin, expected lifetime, and manufacturer details) will be mandatory from February 2027; and recycled content requirements kick in from August 2028. Due diligence obligations — requiring companies with over €40 million in turnover to audit their supply chains for cobalt, lithium, nickel, and graphite — were recently delayed to August 2027 as part of the Commission's "Omnibus IV" package, but they are coming.
Then came the Net-Zero Industry Act (NZIA), adopted in May 2024, which set a binding target for 40% of the EU's annual deployment needs for net-zero technologies — explicitly including batteries — to be manufactured domestically by 2030. The NZIA introduced non-price "resilience" criteria into renewable energy auctions and public procurement, requiring authorities to diversify supply sources and consider sustainability, cybersecurity, and responsible business conduct alongside price. From December 2025, Member States must apply these criteria to at least 30% of their annual renewable energy auction volumes.
The IAA now goes further still. It extends mandatory "Made in EU" and low-carbon requirements across public procurement and support schemes for batteries, battery energy storage systems (BESS), solar PV, heat pumps, wind technologies, electrolysers, and electric vehicles. More dramatically, it introduces a new FDI screening regime layered on top of the existing EU FDI Screening Regulation, specifically targeting large investments in sectors — including battery technologies and their value chains — where more than 40% of global manufacturing capacity is held by the investor's home country.
That 40% threshold is not accidental. It is calibrated, in practice, to point at China, which today accounts for roughly 83% of global battery production capacity and near-total dominance over cathode and anode active materials. The IAA's architects are explicit about this concern: the EU imported around €28 billion worth of batteries in 2024, of which €22 billion came from China alone.
Where Taiwan Stands: Not China, But Not Quite EU Either
This is where Taiwan occupies a genuinely unusual position. Taiwanese battery companies are not Chinese. They are not subject to the geopolitical suspicion that drives the IAA's FDI provisions. Taiwan holds no 40% share of any relevant global manufacturing category. And yet Taiwan has no free trade agreement with the EU, meaning Taiwanese investors do not benefit from the automatic exemptions extended to FTA partners or WTO Government Procurement Agreement signatories.
Under the IAA's proposed FDI framework, a foreign investor must notify a National Investment Authority before acquiring or establishing control at or above 30% ownership in a strategic-sector target, for investments exceeding €100 million. Approval is conditional on satisfying value-added conditions that may include: a cap of 49% on foreign ownership; joint venture arrangements with EU partners; IP licensing to the EU target, with that target owning all IP it develops; committing at least 1% of gross annual revenue to EU-based R&D; ensuring at least 50% of the workforce consists of EU workers; and publishing a sourcing strategy with a target of at least 30% of manufacturing inputs from within the EU.
For a Taiwanese company investing in a greenfield gigafactory — as ProLogium is doing in Dunkirk — several of these conditions may not be especially onerous in practice. ProLogium is already embedding itself in the French industrial ecosystem, partnering with French R&D bodies like CEA, hiring locally, and sourcing from European suppliers. Its investment is welcomed at the highest political level: French President Macron personally lobbied to bring the factory to France, and the project is supported by the France 2030 plan and the Green Industry Act. If anything, ProLogium's model is the kind of local value creation the IAA's architects had in mind — just not from a European company.
The more complex question is what happens as Taiwanese companies scale up and begin to compete for EU public procurement contracts and support scheme benefits. Under the IAA's "Made in EU" provisions, batteries and BESS supplied under public procurement procedures and government support schemes must meet Union-origin requirements. Taiwan, lacking an FTA with the EU, does not automatically qualify for equivalent treatment. A Taiwanese company whose products are entirely manufactured at a factory in France would likely satisfy origin requirements. One supplying from Taiwan would not.
ProLogium: The Flagship Case
ProLogium Technology is the most consequential Taiwanese bet on Europe. Founded in 2006 and headquartered in Taoyuan, Taiwan, the company is the world's leading commercialiser of solid-state lithium ceramic batteries, holding over 1,000 global patents. It opened its first GWh-scale gigafactory in Taoyuan in 2024, shipping more than 600,000 cells, and has established an R&D centre in Paris-Saclay.
The Dunkirk gigafactory is ProLogium's flagship European commitment. The company broke ground in February 2026, having secured French government subsidies in 2023 and obtained environmental and construction permits in 2025. The roadmap calls for mass production of its fourth-generation all-inorganic solid-state batteries to begin in 2028, ramping to 4 GWh by 2029 and 12 GWh by 2030, with reserved land allowing eventual expansion to 48 GWh. Total investment is expected to exceed €5 billion by 2030, creating around 3,000 direct jobs and an estimated 12,000 indirect jobs in the region.
This investment positions ProLogium almost ideally under the IAA framework — not because it sidesteps the regulation, but because it genuinely satisfies its underlying logic. By manufacturing in France, ProLogium's batteries would qualify as EU-origin for procurement purposes. By collaborating with European research institutions, hiring EU workers, and building out local supply chains, it would likely satisfy the IAA's value-added conditions for inbound FDI. France specifically beat out Germany and the Netherlands for the investment — partly through Macron's personal diplomacy, partly through the competitive advantage of France's low-carbon nuclear electricity, which helps ProLogium meet the EU Battery Regulation's increasingly demanding carbon footprint requirements.
The ProLogium model illustrates the strategic logic the IAA creates for ambitious Taiwanese companies: if you want full access to Europe's fast-growing battery market, you need a European manufacturing footprint, not just a European sales office.
Other Taiwanese Players and the Broader Sector
Beyond ProLogium, Taiwan has a broader battery ecosystem — though most of its players are less visible in Europe. Amita Technologies, Simplo Technology (the global leader in battery modules), E-One Moli Energy (Molicel), and Formosa Smart Energy each occupy niches in the lithium-ion value chain. Taiwan's particular strength lies not in cell manufacturing at scale — where China, South Korea, and Japan dominate — but in battery management systems, high-value modules, precision components, and increasingly in solid-state technology.
For these companies, the EU's regulatory tightening creates a mixed picture. The Battery Regulation's carbon footprint declarations and supply chain due diligence requirements raise compliance costs but are technology-neutral — a Taiwanese LFP or NMC cell that meets the carbon threshold can be sold in the EU regardless of origin. The NZIA's resilience criteria in public procurement are more problematic for exporters: a Taiwanese-made BESS competing in an EU renewable energy auction faces scrutiny under the resilience non-price criterion that it might not face if it were manufactured within the EU or by a company from an FTA partner country.
Taiwan's energy companies — including those involved in grid-scale storage integration and power electronics — face similar dynamics. Delta Electronics, the Taiwanese power and thermal management giant, already has a significant European presence in industrial automation and energy infrastructure. Its BESS products compete in the European market, but the IAA's "Made in EU" provisions for BESS in public procurement and support schemes could erode competitiveness relative to locally manufactured alternatives, unless Delta invests further in European production.
The EU's cybersecurity provisions, meanwhile, deserve specific attention. The IAA proposes to prevent "high-risk suppliers" — to be defined under an upcoming Cybersecurity Act 2 — from supplying critical components for net-zero technologies to bidders in renewable energy auctions, public procurement procedures, or final products supported by government incentives. This provision primarily targets Chinese suppliers, but its precise definition matters enormously: if it sweeps in Taiwanese companies that source certain components from Chinese supply chains, the compliance burden could be substantial.
The FDI Screening Dimension
The IAA's FDI provisions, while designed with Chinese investment in mind, create structural uncertainty for Taiwanese investors. The regime applies to investments exceeding €100 million in battery technologies and BESS, EVs and components, solar PV, and critical raw materials — sectors where the investor's home country controls more than 40% of global manufacturing capacity. Taiwan does not meet this threshold in any of these categories. But the IAA's provisions on "ultimate beneficial ownership" introduce a more complex dynamic: an investment by a company legally established in the EU but ultimately controlled from a third country triggers the same notification requirements.
For Taiwanese companies with complex ownership structures, or those that have raised capital from Chinese investors, this provision demands careful legal analysis. Mayer Brown's legal analysis of the proposed IAA notes that third country investors in batteries and BESS "will need to recalibrate deal structures and operating models to satisfy ownership, workforce, sourcing and IP transfer criteria." That calculus applies to Taiwan just as it does to the United States or Japan — even if the underlying policy intent is narrower.
The notification regime — which requires prior approval before acquiring or establishing 30% control or more, with decisions expected within 60-105 days — adds process friction to Taiwanese M&A activity in EU battery companies. A Taiwanese battery firm seeking to acquire a European BESS integrator, for instance, would now need to navigate this approval process alongside the existing national FDI screening regimes that Member States operate in parallel.
Opportunities Within the Constraints
It would be a mistake to read this regulatory landscape as simply hostile to Taiwanese companies. The EU's battery market is growing at extraordinary speed — European BESS deployment is expected to reach 16 GW in 2025, up 45% year-on-year, and EU battery demand is projected to grow 14-fold by 2030. The Commission has deployed over €1 billion in Innovation Fund grants for EV battery cell manufacturing, with an additional €200 million in InvestEU loan guarantees and €1.8 billion committed by the European Investment Bank to the battery value chain. "Made in EU" production — including production by Taiwanese companies that manufacture in Europe — is precisely what these instruments are designed to incentivise.
Taiwan's technological edge in solid-state batteries is a genuinely differentiating asset. The IAA's NZIA "strategic project" designation — which grants national-level priority treatment, faster permitting, and access to financial and advisory support — requires demonstrating "first-of-a-kind manufacturing processes not yet substantively present or planned in the EU." ProLogium's solid-state technology arguably qualifies. A strategic project designation would provide significant insulation from some of the friction the IAA introduces.
More broadly, the IAA's reciprocity logic creates an opening for EU-Taiwan political dialogue. The regulation grants equivalent treatment in public procurement to countries with whom the EU has concluded a free trade agreement or customs union. Taiwan does not currently have such an agreement, but bilateral trade relations with the EU have deepened significantly since 2022, driven by shared concerns about supply chain resilience and semiconductor dependencies. A future bilateral investment or trade framework — however challenging diplomatically given Taiwan's status — could alter Taiwanese companies' access to EU procurement markets meaningfully.
Strategic Implications
For Taiwanese battery and energy companies, the IAA and the broader EU regulatory environment it crowns create a clear strategic imperative: the route to full participation in Europe's energy transition market runs through Europe, not to it.
Companies that invest in European manufacturing — as ProLogium has done — gain access to EU procurement benefits, "Made in EU" origin status, eligibility for EU funding instruments, and insulation from the FDI screening burden that applies to purely exporting models. The compliance costs of EU Battery Regulation documentation, digital battery passports, and supply chain due diligence are significant but manageable for companies with the engineering and systems infrastructure Taiwan's sector has developed.
Companies that continue to serve Europe primarily through exports face a more constrained trajectory. The NZIA's resilience criteria in auctions and procurement will progressively favour EU-origin alternatives. Carbon footprint thresholds will tighten. And the IAA's "Made in EU" requirements for batteries subject to public procurement and support schemes will create structural headwinds for Asian exporters — including Taiwanese ones — that do not have local production.
The IAA is still a proposal. It must pass through the European Parliament and Council, and both are expected to propose amendments. The final text may be more or less stringent than the March 2026 draft. What is not in doubt is the direction of travel: the EU is building a regulated, incentivised domestic battery economy, and it intends to use public procurement, state aid, and investment screening to shape who benefits from it.
Taiwan's most advanced battery companies have already read this map correctly. The question for the rest of the sector is how quickly they can follow.
This article draws on the European Commission's proposed IAA (COM(2026) 100 final), the EU Battery Regulation 2023/1542, the Net-Zero Industry Act (Regulation (EU) 2024/1106), and publicly available company disclosures. It reflects the regulatory position as of April 2026; the IAA remains a legislative proposal subject to amendment.