Position Statement Translated from German with AI assistance

DIHK Position on the Advanced Materials Act

The EU Commission plans the "Advanced Materials Act" to establish a better legal framework for the development of highly innovative materials. DIHK considers the proposed reduction of sector-specific obstacles to innovation important but demands a low-bureaucracy, practical, and technology-open approach that is accessible to all companies.

Advanced Materials are considered a key component for future technologies, clean energy, and the technological sovereignty of Europe. They are used in Cleantech applications, mobility, electronics, energy production, construction, or aerospace. The EU Commission aims to strengthen the development, market introduction, and circularity of these materials, but DIHK believes the planned framework requires some adjustments.

Whether new battery materials for electromobility, recyclable composites in construction, or bio-based plastics in industry, so-called "Advanced Materials" are behind many innovations shaping Europe's economy today. However, practice shows that there remain significant barriers between research, market introduction, and wide application. The European Commission intends to address these issues with the "Advanced Materials Act" planned for the fourth quarter of 2026.

DIHK has contributed a preliminary position in the preparations for this EU legal act. It supports the goal of strengthening innovation in the Advanced Materials sector and reducing regulatory barriers but emphasizes: the specific design is crucial. The new framework must create genuine added value for companies and must not lead to additional complexity or delayed market introductions.

Advanced materials play a crucial role in Cleantech, mobility, energy, electronics, or aerospace. The planned EU legal act aims to improve development, scaling, and circularity. From DIHK's perspective, this could be an important element for competitiveness and technological sovereignty – provided that existing regulations are meaningfully supplemented and not overlaid.

Key DIHK Demands

In its preliminary position on the planned Advanced Materials Act, DIHK formulates central requirements along the entire innovation and lifecycle of advanced materials:

Practical, technology-open research and innovation funding

Funding measures should be cross-sectoral, low-bureaucracy, and accessible to companies of all sizes. Crucial is a better transfer of research to applications, for example, through simplified use of publicly funded patents and stronger networking between science and business.

Avoidance of innovation-inhibiting over-regulation

DIHK explicitly warns against creating new, complex requirements that delay market introductions. Experiences from highly regulated sectors like medical technology reveal how quickly excessive regulation can slow down innovation. The planned legal act should, therefore, remain streamlined and practical.

Strengthening and recognition of new recycling technologies

Innovative recycling processes need to be approved faster and integrated early into material developments. Existing technologies must not be favored if they displace new, more efficient solutions. Only in this way can a genuine circular economy for advanced materials emerge.

Accelerated processes and reduced bureaucracy

Approval, licensing, and testing processes should be significantly simplified and accelerated. Instruments such as real-world laboratories and regulatory sandboxes can help bring new materials to market maturity under real conditions more quickly.

Market-oriented design of supply security

Measures to strengthen European production capacities and reduce dependencies should be competition-neutral and avoid additional reporting obligations. Companies must continue to independently shape their investment and risk strategies.

FAQ

Answers to Frequently Asked Questions

Which companies are affected by the Advanced Materials Act?
Stakeholders across the whole value chain are addressed—from research institutions and start-ups to manufacturers and processors, as well as user industries such as energy, semiconductors, mobility, and construction. Depending on the provisions, companies that use or recycle innovative materials in other ways could also be included.

What opportunities does the proposed Act offer for small and medium-sized enterprises?

Small and medium-sized enterprises particularly stand to gain from enhanced support structures, greater knowledge transfer, and faster processes. However, programs must be easily accessible, and bureaucratic hurdles need to be reduced noticeably.

What are the biggest risks identified by the DIHK?
The DIHK warns against additional regulatory complexity, overlaps with existing EU regulations, and new requirements, such as those concerning sustainability, transparency, or safety, which could hinder innovation processes.

What does the focus on circular economy mean concretely?
Companies are expected to increasingly reuse and design "Advanced Materials" in a way that promotes recyclability. Key factors include efficient reverse logistics, access to high-quality recyclates, and rapid approval of new recycling methods.

How does the DIHK evaluate supply security measures?
The DIHK supports the goal of reducing dependencies on innovative materials but emphasizes that instruments like joint procurement or inventorying must be voluntary, market-oriented, and free from unnecessary bureaucracy.

Download

The complete DIHK position from January 7, 2026, with details is available for download here:

DIHK position on the planned Advanced Materials Act (PDF, 132 KB) (only available in German).

Key areas:
  • Digitalisation
  • Reducing Bureaucracy
This English version is provided for convenience only.
It has been translated with the assistance of AI.
No guarantee is made as to the accuracy or completeness of the translation.

Contact

Kramer, Lorenz_quad

Lorenz Kramer

Director Economic Policy in Europe