It calls for a proportionate and evidence-based approach that supports environmental objectives while ensuring the continued deployment of solar energy in Europe, supporting both decarbonisation and energy security objectives.
In particular, it highlights the importance of regulatory certainty, technical feasibility and supply chain readiness, to avoid unintended disruptions to solar deployment and Europe’s decarbonisation and energy security goals.
Building on this, SolarPower Europe puts forward the following recommendations:
Phase-out of PFAS in PV modules:
SolarPower Europe supports a phase-out of PFAS in PV module backsheets, reflecting the positive industry shift away from fluoropolymers use, which are considered a low concern sub-group of PFAS.
Appropriate concentration limits:
Limits aligned with existing PFAS-free certification thresholds (e.g. 0.1% w/w) are needed to account for trace amounts while avoiding unnecessary barriers to solar deployment.
Predictable transition period:
Regulatory certainty, including the proposed 18-month transition phase, is essential to allow manufacturers to adapt and scale up alternatives.
Harmonised EU certification:
A single REACH-based PFAS certification along the lines of existing frameworks to avoid fragmented national requirements and reduce administrative burden.
SolarPower Europe's Consultation Response on PFAS
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Limited availability of alternatives:
Technically and commercially viable PFAS-free substitutes are not yet available for several critical inverter components, due to strict performance, safety and durability requirements.
Targeted derogations for essential components:
Exemptions are necessary for key elements such as wires and cables (including connectors), insulation materials and capacitors, to ensure the continued functionality and reliability of solar PV systems.
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