Specifying environmental requirements for publicly procured solar

Carbon footprint performance should be a key minimum environmental sustainability criterion for PV modules in public procurement, alongside the technical durability requirements under the Implementing Act of the NZIA. There should be a stricter carbon footprint threshold than general market standards, provided there is a harmonised carbon accounting methodology under PV Ecodesign that accepts supplier-specific electricity data. Both harmonisation and recognising such data are vital to prevent fragmented approaches across Europe, as already seen in France, and to ensure clear, consistent eligibility criteria under Article 25 NZIA.

Non-price criteria should follow EU laws such as the PV Ecodesign and the Corporate Sustainability Due Diligence Directive (CSDDD) to ensure consistency and practical application. In the absence of relevant harmonised standards, recital 10 of the draft implementing act under consultation states that “generally recognised state-of-the art should be used”. SolarPower Europe asks the European Commission to clarify how the standards will interact with the implementing regulation to ensure consistency, transparency and predictability for all economic operators.

SolarPower Europe further seeks clarification on whether all components will be covered, as it is important to understand if future implementing acts will extend the scope of minimum environmental sustainability requirements beyond photovoltaic modules and inverters to include additional components of PV systems, such as mounting structures, cells, or wafers. SolarPower Europe proposes the inclusion of minimum environmental sustainability requirements for the category “PV trackers and their dedicated mounting structures”, as they fall within the NZIA scope and their environmental performance can be clearly measured. PV trackers and their dedicated mounting structures should be required to be able to withstand prolonged exposure in open-air climates, including suitable resistance to corrosion, a minimum 30-year service life, the possibility to disassemble and reuse all parts (except foundation piles), and the use of recycled material for structural elements. 

SolarPower Europe requests that the European Commission correct a typographical error in the draft regulation. The standard for solar PV module durability is currently referenced as “EN IEC 6125:2021.” This appears to be a transposed number; the correct reference should be “EN IEC 61215:2021,” which is the harmonised standard for PV module durability in open-air climates.