Recommendations on the NZIA Implementing Act
A toolbox of non-price criteria that are tailored and technology-specific to solar PV: environmental sustainability, resilience, responsible business conduct and cybersecurity according to Art. 26.1. and 26.2 in NZIA.
Read the paper
The Net-Zero Industry Act includes several measures relevant for the solar PV sector. It sets the goal to reach at least 30 GW of operational solar PV manufacturing capacity by 2030 across the full PV value chain. To do so, NZIA aims at the leveraging of public demand through public procurement (Art. 25), renewable energy auctions (Art. 26), pre-commercial and public procurement of innovative solutions (Art 27), and other forms of public intervention (Art. 28) using resilience and sustainability criteria to favour the diversification of the sourcing of net-zero technologies.
SolarPower Europe supports this goal and is proposing criteria to lower the EU dependency on net-zero technologies like solar PV, whose supply chains are currently heavily concentrated to a single source of supply outside of the EU.
The forthcoming Implementing Act for the NZIA will set the details of how resilience and sustainability criteria will be applied in public auctions and how sustainability will be applied procurement. This position paper serves as SolarPower Europe's input to this legislation.
Below we have highlighted some key parts of the position paper for ease. Please note, the paper should be considered the reference point for SolarPower Europe's position.
Solar Specific
Non-price criteria only work if they are technology-specific. It is not possible to apply the same criteria and metric to all net-zero technologies.
Awarding Resilience & Sustainability
Non-price criteria on sustainability and resilience must be applied as award criteria, ensuring better performers are rewarded for their efforts.
We strongly advise against applying sustainability and resilience as pre-qualification criteria, if we are to avoid scarcity of products and undersubscribed tenders.
Specific Resilience Auctions
Non-price criteria should only apply to a part of the auction market as is outlined in Article 26. For solar, we recommend a share corresponding to volumes of around 5GW in 2026 and 30GW in 2030 across EU, in line with the Net Zero Industry Act goal. Such approach creates a clear space for specific “solar resilience auctions”, giving much needed offtake visibility for European solar products while avoiding complexifying the rest of the auction market.
Resilience Bonus Points
SolarPower Europe proposes the definition of ‘resilience’ as global diversification ('other than dominant source of supply') with additional bonus points for European content.
Sustainability Criteria
SolarPower Europe proposes carbon footprint criteria as the dominant factor under the sustainability criterion.
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