PV Sustainable Product Policies: a quick guide on EU sustainability instruments

by Raffaele Rossi - 2 February 2023
As the European Commission is currently working on a legislative proposal to introduce sustainable product policy measures for solar PV modules and inverters in the EU, having a clear understanding of what these different policy measures and their intended objectives are can appear troublesome to non-experts.

This article provides a quick recap on the difference between four EU sustainable product policy measures: Ecodesign, Energy Label, Ecolabel and GPP. One should not mistake one for another since they are very different EU instruments with different purposes!

 a) Ecodesign is a measure that sets minimum requirements for all products placed on the market. In the current proposal for solar PV products, published by the European Commission in June 2022, such requirements include maximum embedded carbon footprint, minimum quality and reliability requirements, material content disclosure, circular requirements (dismantlability, recyclability, etc). The purpose of this instrument is to remove the lowest performing products from the market. For this reason, the minimum requirements set by Ecodesign are initially rather low and should be easily met by most incumbents. With the passing of time, minimum requirements are then progressively made more stringent, aiming to give a bottom-up push to product quality and sustainability. 
b) Energy Label is a measure that helps end-consumers understand the energy performance of products. It rates electrical and other products on a range of A to G based on the electricity they consume (or, for PV modules, they produce). This is the label that is typically found on white goods like fridges and washing machines. In the current European Commission proposal, this tool would be applied to all PV modules placed on the EU market.
c) EU Ecolabel is a measure that provides an opportunity for the most sustainable products to claim their higher environmental performance. Consumers seeing the EU Ecolabel on the packaging of a product know that this product has lower environmental impacts compared to its peers. It uses a set of different criteria to assess the environmental performance (e.g. carbon footprint, type and quantity of materials used, type of packaging, recyclability, etc). This label is meant to help end-customers recognise the products with the highest sustainability features within a product group. Crucially, this is not a mandatory instrument applied to all products, but is rather a voluntary tool that targets only the top performing products (~top 10%). As such, this measure sets a high bar on the thresholds to be reached in order to be eligible for the Ecolabel. Companies who sell products with exceptional sustainability features can lodge an application to get the EU Ecolabel, if this tool is available for that specific product group. At present, however, there is no EU Ecolabel for PV products, nor is it the intention of the Commission to develop one.
d) EU Green Public Procurement (GPP) is another voluntary tool rewarding best performing products in terms of environmental sustainability. Differently from EU Ecolabel, which aims at helping end-consumers to recognise greener products, this tool is meant to support green purchases from the public sector (public offices, municipalities, etc). The criteria used in GPP are somewhat different to the criteria used in an EU Ecolabel. A GPP tool is typically composed of a combination of technical specifications – standards to comply with – and award criteria, which provide the basis for public purchase decisions.
In the June 2022 proposal, the EU Commission recommended to set up Ecodesign and Energy Label tools for PV products at a first stage, followed by a GPP tool at a second stage. The rationale is that the GPP tool would be based on criteria that need to be measurable and trackable: the obligation to disclose the necessary information to do so will be introduced through Ecodesign. By contrast, the initial proposal to set up an EU Ecolabel for PV products as a fourth policy instrument has been put aside by the European Commission. This followed the recommendation from the Commission’s JRC Preparatory Study, which assessed that the effects of an EU Ecolabel on the residential PV segment would have a high level of uncertainty. 
As an important final remark, the tools described above are EU product policy instruments. There are other several existing Ecolabels available that are not EU instruments (for the solar sector, the industry-based EPEAT Ecolabel for PV modules and inverters). The term "Ecodesign" can be also generally used for all those actions taken at the manufacturing stage to improve product circularity and sustainability.

Interested in learning more about this topic? Get in touch with our Head of Market Intelligence, Raffaele Rossi