These papers act as SolarPower Europe's response to two public consultations on the implementation of the Net-Zero Industry Act, namely the consultations on:
- The Delegated act on primarily used components under the NZIA
- The Implementing act on list of net-zero technology final products and their main specific components
- The Implementing Act on non-price criteria for renewable energy auctions
Our full responses are available for download here (summary below):
Downloads
Feedback on the Public Consultation: Delegated act on primarily used components under the NZIA
Ensuring vital solar components are in scope of the Net Zero Industry Act.
Read here
Feedback on the Public Consultation: List of net-zero technology final products and their main specific components for the purposes of assessing the contribution to resilience
Urging the Net Zero Industry Act supports the full solar value chain.
Read here
Feedback on the Public Consultation: Implementing Act on Renewable Energy Auctions and Non-Price Criteria
Encouraging clear award criteria for made-in-EU products—key to supporting EU manufacturers and achieving the NZIA 30 GW manufacturing goals.
Read here
In papers 1 & 2, SolarPower Europe's input emphasises the importance of comprehensively recognising solar components under the scope of the Net-Zero Industry Act, including: solar mounting structures and equivalents to solar glass, as well as Metallurgical Grade Silicon or equivalent, and PV grade polysilicon or equivalent.
The third paper focusses on how Europe should define, measure, and award resilience criteria in renewable energy auctions. SolarPower Europe has a number of recommendations on how to get this process right:
Clarity
The draft Implementing Act shared via consultation is quite complex, so a key piece of feedback is clarity. In the spirit of the EU’s current ‘simplification’ agenda, ‘quality over quantity' should be applied to limit non-price criteria to a few, highly effective measures. This will reduce bureaucracy, minimise administrative costs, and ease the burden on companies—especially SMEs—and national authorities.
Forward Planning
Having a clear off-take pipeline is important for solar manufacturers (and their investors); the forward planning aspect could be improved in the current draft. Our paper outlines how the European Commission should require Member States to provide auction roadmaps and non-price criteria allocations in advance. The Commission must establish clear schedules for publishing supply chain dependency data and ensure a transparent methodology for calculating and assessing this information.
Defining & Awarding Resilience
Defining resilience continues to be complex; a simplification of the language is highly recommended. Member States retain the option to apply resilience either as an ‘award’ or as a ‘prequalification’ criterion in energy auctions. That is a problem because it means Member States could apply resilience criteria overly restrictive (excluding solar from bidding into auctions) or as overly loose (not giving any signal to EU manufacturers). Therefore, we suggest going a step further and setting clear rules for the ‘resilience as award’ scenario and for the ‘resilience as prequalification’ scenario, or a combination of the two.
If resilience is applied as prequalification, we suggest introducing this for a limited number of components in a solar project; on inverters, modules, and max one more component. If the award rule is applied, the auction should encourage bidders to include multiple resilient components (4+) to increasing bonus points.
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