EU / Spain — CISAF Cleantech Manufacturing Capacity Scheme SA.119884: EUR 700 million grants for net-zero technology production

Mechanism

Spain notified the Commission of a EUR 700 million horizontal scheme under CISAF Section 6.1 (Clean Industrial Deal State Aid Framework, adopted 25 June 2025), the strand that lets Member States subsidise new manufacturing capacity for net-zero technologies rather than decarbonising existing output. Eligible technologies mirror the CISAF Annex II list already seen in peer approvals (Italy SA. unpublished, Hungary SA.120705, Germany SA.121215, Greece SA.117469, Luxembourg SA.120921, France SA.120765): batteries, solar panels, wind turbines, heat pumps, electrolysers, and carbon capture, storage and utilisation (CCUS) equipment, plus production of the critical raw materials that feed these product lines. Aid is delivered as direct grants, open to projects anywhere in Spain, grantable until 31 December 2028. The Commission assessed the measure under Article 107(3)(c) TFEU and found it necessary, appropriate and proportionate under CISAF criteria.

This is a separate approval from Spain's EUR 408 million SA.119880 scheme (filed 2025-12-15 in this register), which was notified and approved five weeks later under CISAF Section 5 to fund electrification, hydrogen switching, waste-heat recovery and CCUS retrofits inside existing industrial processes. Together the two schemes give Spain roughly EUR 1.1 billion in CISAF-backed industrial capital: SA.119884 for building new clean-tech product lines, SA.119880 for cutting emissions in incumbent heavy industry (chemicals, ceramics, paper, metallurgy).

Downstream implications

• Spain now has both CISAF strands active (Section 6.1 capacity-building at EUR 700m + Section 5

decarbonisation-retrofit at EUR 408m), matching the pattern seen in Germany, Italy and France of running parallel schemes rather than a single combined instrument.

• Materials angle: unlike some peer Section 6.1 schemes that stop at finished products, Spain's

scheme explicitly extends aid eligibility to production of the critical raw materials feeding battery, solar and electrolyser manufacturing — relevant to the EU's CRMA onshoring push and to lithium/polysilicon supply-chain diversification away from China.

• ETF exposure: ICLN (global clean-energy), EWP (Spain equities), TAN (solar) all carry

potential exposure to Spanish beneficiaries once individual awards are disclosed.

Open questions

• No non-confidential SA.119884 decision text or beneficiary list has been published yet — worth

checking the EC competition-cases database for backfill.

• Whether Spain will file a CISAF Section 6.2 (electricity-price relief) scheme as Germany,

Bulgaria and Slovenia have done.

• How the EUR 700m (new capacity) and EUR 408m (retrofit) envelopes will be apportioned across

Spain's regions and whether any single project draws the EUR 200m per-project cap seen in the sister scheme.