The New Rules of Industrial Competitiveness: Data, Decarbonisation and Investment Readiness

European industrial policy is entering a phase in which regulation, funding and technological infrastructure are beginning to operate as a single system. Companies are no longer expected merely to claim that they work sustainably or introduce innovations. Increasingly, they must provide structured product data, traceable evidence, investment plans and measurable results.

Developments over the past week clearly demonstrate this shift. The European Digital Product Passport Registry is now operational. The European Commission has proposed an Industrial Decarbonisation Bank with a budget of EUR 100 billion, while linking part of future support to verifiable investment plans. Bulgaria is activating investment incentives and industrial infrastructure, while new European funding calls are seeking not general concepts but near-market projects and proven technological capabilities.

For industrial SMEs, this means that preparation for the next investment should begin not with selecting a funding programme or software solution, but with the quality of the data, processes and evidence available within the company.

The Digital Product Passport now has an operational infrastructure

On 20 July 2026, the European Commission launched the Digital Product Passport Registry, together with a testing environment, guidance for economic operators and technical support. This represents an important transition from a regulatory concept to an infrastructure that businesses can use in practice. The registry and testing environment are accessible through the European Commission’s dedicated portal..

The registry functions as a common European index. It manages identifiers and essential registration data, while the detailed product information remains the responsibility of the relevant manufacturer, importer or other economic operator. This information may be stored by the company itself or by a Digital Product Passport service provider.

This does not mean that all companies must immediately register their products. Requirements are being introduced gradually for different product groups. Digital passports will become mandatory for certain types of batteries from 18 February 2027. The adoption of sector-specific requirements for iron and steel is planned for the fourth quarter of 2026, while requirements for textiles, aluminium and tyres are expected during the second half of 2027. The timetable remains indicative and may change as legislative and technical work progresses. The European Commission maintains an updated sectoral roadmap for the introduction of Digital Product Passports.

For manufacturing companies, preparation does not begin with generating a QR code. It begins by determining whether the company can reliably connect a particular product with its materials, components, suppliers, technical documentation and different versions.

Minimum preparation should include:

• identifying the product groups for which sector-specific requirements are expected;
• creating consistent product identifiers;
• structuring specifications and bills of materials;
• collecting and updating certificates and supplier data;
• managing versions of technical and accompanying documentation;
• assigning responsibilities for entering, verifying and updating information;
• assessing whether the ERP, PIM, QMS or other systems in use can exchange structured data.

The precise scope of the required information will depend on the relevant sector-specific legislation. However, companies whose product data is currently scattered across spreadsheets, emails and folders maintained by individual employees can already begin preparing without waiting for the final deadline.

Decarbonisation will receive more resources, but also come with more conditions

On 17 July 2026, the European Commission presented a proposal to reform the EU Emissions Trading System. One of its main elements is the establishment of an Industrial Decarbonisation Bank with a planned budget of EUR 100 billion. An investment mechanism is also envisaged to support projects before the bank becomes fully operational. The proposal and its main parameters have been published by the European Commission.

The package seeks to balance climate objectives with industrial competitiveness. For sectors covered by the Carbon Border Adjustment Mechanism, it proposes a slower reduction in free allowances and an extension of the phase-out period until 2038.

More time, however, does not mean weaker requirements. Under the proposal, from 2031 the free allocation of allowances will be linked to verified decarbonisation investment plans. It is envisaged that 80% of the relevant allocation will be granted after the plan has been submitted and approved, with the remaining 20% released after the investments have been demonstrably implemented and a significant reduction in emissions has been achieved. The detailed parameters are set out in legislative proposal COM(2026) 616.

The proposal is yet to be discussed by the European Parliament and the Council, meaning that its parameters are not yet final.

For most SMEs, the immediate effect will not be a direct obligation under the Emissions Trading System. The requirements are more likely to be passed down through large customers seeking more reliable information from their suppliers about energy consumption, materials, production processes and carbon footprints.

Reasonable preparation for a manufacturing SME should therefore include:

• establishing a baseline for energy consumption across production processes;
• identifying the materials and operations with the greatest impact on emissions;
• collecting environmental and technical data from key suppliers;
• developing an investment plan with measurable impact;
• retaining data and evidence of the improvements achieved.

A new machine, photovoltaic system or energy monitoring solution will be easier to finance if the company can demonstrate not only its cost but also its impact on productivity, energy consumption and emissions.

Changes concerning the use of solvents may affect investment schedules

On 15 July 2026, the Bulgarian Ministry of Economy published for public consultation a draft amendment to Ordinance No 7 on emissions of volatile organic compounds from installations using solvents. The draft transposes changes to European legislation on industrial emissions.

One of the important changes provides that, in the event of a substantial modification to an existing installation, the modified part will be treated as a new installation. Interested parties have 30 days to submit comments. The draft, its explanatory memorandum and the correlation table have been published by the Ministry of Economy.

The changes may be relevant to companies involved in painting, coating, printing, furniture and packaging manufacturing, metalworking and other processes involving organic solvents.

Expanding a production line or changing the technology used may affect permit requirements, the equipment needed to limit emissions, monitoring obligations and the overall investment implementation schedule.

Before ordering new equipment, companies should assess the substances and quantities used, the applicable thresholds, expected emissions and the likelihood of the change being classified as substantial. This allows environmental requirements to be incorporated into the investment project in advance, instead of becoming a source of delay after the equipment has been delivered.

Competition between regions is increasingly measured through investment-ready infrastructure

On 15 July, the Bulgarian Ministry of Economy announced that nearly EUR 60 million had been allocated in the national budget for incentive measures supporting Bulgarian and foreign companies. The policy places an emphasis on infrastructure, better coordination between institutions and investments with high added value. The information was published on the Ministry of Economy’s website.

Only a day later, the second phase of the Zagore Industrial Park was inaugurated, having received nearly EUR 7.1 million in public support. Investment intentions amounting to almost EUR 300 million have already been declared for the park, with the potential to create more than 1,300 jobs. The government has also reported more than 300 identified measures for reducing the administrative burden. The figures concerning the industrial park and planned investments were published by the Ministry.

For the Ruse region, this example demonstrates that presenting its geographical location and industrial traditions in general terms is no longer sufficient. Potential investors expect specific information about:

• available industrial sites and their ownership;
• available electricity capacity and expected connection times;
• access to gas, water and sewerage infrastructure;
• road, rail, port and airport connectivity;
• permit procedures and realistic timeframes;
• available professional skills;
• local suppliers and subcontractors;
• the institution or team that will coordinate the investment process.

Regional investment readiness must be presented as a verifiable information system, rather than merely as a promotional brochure.

A positive sign for administrative digitalisation is the addition of three more registers to Bulgaria’s RegiX system: the Register of Expert Witnesses, the Register of Trustees in Bankruptcy and the Register of Persons with Legal Capacity. This enables public administrations to verify information directly instead of requiring citizens and businesses to provide certificates. The expansion of RegiX was announced on 14 July 2026.

Funding instruments are looking for investment-ready projects and regional partnerships

Calls under the Interregional Innovation Investments instrument, known as I3, are open until 12 November 2026. The instrument supports near-market projects at Technology Readiness Levels 6 to 9 that connect regional innovation ecosystems from different countries.

Funding may reach EUR 10 million per project, with an EU co-financing rate of 70%. Priority is given to investments that accelerate the market deployment of technologies, support the digital and green transitions and integrate less-developed regions into European value chains. The conditions and open calls have been published by EISMEA.

This is not a suitable instrument for a project that remains at the level of a general idea. It requires a validated technology, a specific investment case, companies that will implement the solution and partners with complementary roles.

The Ruse region could be competitive in proposals bringing together manufacturing SMEs, technology providers, the University of Ruse, business organisations, local authorities and partners from other European regions. RCCI and BIC Innobridge could contribute by identifying suitable investment cases, engaging relevant companies and building international partnerships.

Space technologies and semiconductors create opportunities beyond a narrow circle of specialised companies

The European Space Agency’s twelfth call for Bulgaria is expected in October 2026. To date, 54 Bulgarian projects have received support through ESA programmes, while small satellites have been identified as a promising area for further development. The information was published by the Bulgarian Ministry of Innovation and Growth on 17 July.

The opportunities are not limited to businesses that define themselves as “space companies”. Relevant capabilities may also be found among companies working in electronics, sensors, embedded systems, precision engineering, specialised materials, cybersecurity, software and data analysis.

A similar logic applies to the semiconductor industry. The European Commission has approved EUR 659 million in German state aid for four new manufacturing facilities defined as first-of-a-kind in Europe. The projects form part of the implementation of the European Chips Act and are expected to generate wider positive effects for the European semiconductor ecosystem. The decision was announced by the European Commission on 14 July 2026.

For a traditional manufacturing SME, the opportunity does not necessarily involve producing semiconductors or satellites. A more realistic role may be supplying precision components, manufacturing equipment, automation systems, power electronics, measurement solutions, testing services or industrial software.

Preparation should begin with a map of the company’s technological and manufacturing capabilities, applicable standards, equipment, capacity and previous experience. This enables the company to be presented according to the specific value it can add to the supply chain, rather than solely according to its traditional industry classification.

A practical 90-day framework for industrial SMEs

Companies can use the next three months to take six specific actions:

1. Determine your potential exposure to Digital Product Passport requirements. Review your product groups, target markets and role as a manufacturer, importer or supplier.
2. Assess the quality of your product data. Establish where specifications, material data, certificates, supplier information and different versions of documentation are stored.
3. Create an initial energy and emissions baseline. Measure the main sources of consumption and identify one investment with a verifiable impact on costs and emissions.
4. Review planned changes to production. For processes involving solvents, check the environmental and permit requirements before ordering new equipment.
5. Select one mature project case. Assess whether you have the technology, investment rationale and partners required for I3, ESA or another targeted funding call.
6. Map your position within strategic value chains. Describe your capabilities according to the problems you can solve for manufacturers of electronics, equipment, batteries, semiconductors, satellites and other high-technology products.

Conclusion

The overall direction is clear: industrial competitiveness increasingly depends on a company’s ability to manage and substantiate information.

The Digital Product Passport requires reliable product data. Decarbonisation funding will require verifiable investment plans. European projects are looking for mature technological cases and genuine partnerships. Investors compare regions on the basis of specific infrastructure, implementation times and available capabilities.

For Bulgarian SMEs, this does not necessarily mean making an immediate and complex technological investment. The first step is to establish an organised foundation of product data, measurable processes, technical documentation and clearly assigned responsibilities. This foundation will determine which companies can participate in the next generation of European industrial and technological value chains.

The Ruse Chamber of Commerce and Industry publishes materials of this kind to help companies in the region assess emerging requirements, prepare investment projects and build partnerships in Bulgaria and across Europe.

If you would like to discuss your organization's readiness for digital product passports, I3 and ESA opportunities, or inclusion in strategic technology chains, contact me at sminchev@rcci.bg or 0895 890 123.

Note: This article was prepared with the assistance of generative artificial intelligence, which supported the structuring of the content, verification of sources and drafting process. The final text reflects the author’s expert input, ensuring its accuracy and practical relevance. The information is current as of 21 July 2026 and does not constitute legal or financial advice.