EU consultation
21 submissions from 20 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 97 submissions on this file. Shown here: the 21 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
11 submissions from industry — companies and their trade associations — against 6 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 1.8 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 16 Dec 2022 — it ran from 23 Sept 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg draft, Reg.
Showing 21 of 21 submissions.
· · filed 28 Oct 2021 · source
BayWa r.e. strongly supports the further improvement of quality, performance and reliability of PV products that are being installed on the field. We welcome additional regulations such as the ecodesign label and energy labelling in support of this, however we would also like to highlight the importance of considering current industry developments when introducing such regulatory measures.
The European Solar Manufacturing Council supports the introduction of sustainability policies for PV modules, inverters and systems, in particular the proposal for the mandatory policies Ecodesign and Energy labelling, coupled with the voluntary Green Public Procurement. We believe that these policies, if designed well, will promote sustainability and can contribute to the EU Green Deal and ‘Fit for 55’ proposals.
· · filed 28 Oct 2021 · source
In order to achieve the much-new acceleration to reduce greenhouse gas emissions, low emission modes of transport and infrastructure need to be introduced more rapidly. More environmentally friendly systems and structures can be achieved, in particular, by means of radio communication along the logistics chain (i.e. Internet of Things — IoT; Control and guidance of transport; Police and etc.).
Filed in German · English published by the European Commission
As a trade union for solar energy professionals in France, Enerplan welcomes the draft European legislation harmonising environmental requirements for solar photovoltaic devices at EU level and supports the Commission’s 6 proposal (a combination of eco-design requirements, energy labelling and EU Green Public Procurement criteria).
Filed in French · English published by the European Commission
Of the different policy options outlined in the Inception Impact Assessment, we support option 6 – the introduction of Ecodesign, Energy Labelling and EU Green Public Procurement (GPP) measures. This choice would follow a holistic approach to support a sustainable PV industry and consumer landscape.
· · filed 28 Oct 2021 · source
Feedback to Ecodesign and energy labelling for PV modules, inverters and systems: Inception impact assessment Dear Madams and Sirs: I generally support and endorse the statements from SolarPower Europe and from ESMC. I provide the following additional feedback: 1.
· · filed 28 Oct 2021 · source
Feedback to Ecodesign and energy labelling for PV modules, inverters and systems: Inception impact assessment Dear Madams and Sirs: I generally support and endorse the statements from SolarPower Europe and from ESMC. I provide the following additional feedback: 1.
· · filed 28 Oct 2021 · source
SolarPower Europe welcomes this opportunity to provide feedback on the European Commission’s Inception Impact Assessment on Ecodesign and Energy Labelling requirements for PV products. We closely followed the preparatory work conducted by the Commission and the JRC in advance of this Inception Impact Assessment and look forward to the outcome of this work.
Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European Recycling Industries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024”, 80% of products’ environmental impact are determined at a design stage.
· · filed 28 Oct 2021 · source
The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu welcomes the European Commission’s initiative to assess the need for regulation to manage the environmental impact of photovoltaic (PV) modules, inverters, and systems.
REC Group appreciates the opportunity to provide its feedback on the European Commission’s Inception Impact Assessment on Ecodesign and Energy Labelling requirements for PV products. We strongly support the introduction of policies focusing on sustainability of PV modules, inverters and systems. Among the listed six policy options in the Inception Impact Assessment, Option 6 seems the most appropriate to REC.
>>Challenges: GISAD welcomes the initiative of the EU Commission to standardize photovoltaic modules, inverters and systems. GISAD does not see it as its task to deal with the details of legal regulations. GISAD develops general principles and recommendations from the perspective of an EU Marshall Plan, which should be into account taken in the legislation. GISAD negates 1. “no action” or 2.
· · filed 28 Oct 2021 · source
We welcome this initiative that aims at reducing the environmental impact of photovoltaic (PV) products (modules, inverters, systems), by improving their quality and long-term energy performance, as well as their ability to be repaired and recycled.
ECOS, EEB and the Coolproducts and Right to Repair campaigns welcome this initiative. It is necessary to address the environmental impacts of solar energy production while supporting the uptake of this key technology to reach the EU climate objectives. We consider a revised version of Option 6 most appropriate: stringent ecodesign requirements and GPP criteria, combined with an Ecolabel instead of an Energy Label.
· · filed 27 Oct 2021 · source
The International Amateur Radio Union (IARU) is a Non-Governmental Organisation representing the interests of Radio Amateurs throughout the world. Radio Spectrum is a finite natural environmental resource which at the international level is managed by a UN specialised agency, the International Telecommunication Union.
Hespul is a non-profit organisation whose objects are to contribute to the creation of a low-carbon and efficient society based on renewable energy, while upholding the values of equity and public interest. For more than 10 years, Hespul has been advising photovoltaic projects in France and helping to put in place the legal framework, defending the position of non-professional producers.
Filed in French · English published by the European Commission
ECI welcomes the initiative relative to the environmental impact of photovoltaic modules, inverters and systems under the Energy Labelling Regulation and the Ecodesign Directive. Photovoltaic power is expected to play a major role in the future energy mix, in accordance with the European Green Deal proposals.
In connection with the ongoing consultation process presented by the Commission on the environmental impact of modules, inverters and photovoltaic systems (eco-design initiative) on behalf of the chemical industry, we would like to stress that there is a need to ensure minimum criteria to be met by equipment authorised for use in the territory of the European Union, such as energy yield or the lifetime of individual…
Filed in Polish · English published by the European Commission
The Ile-de-France Photovoltaic Institute (IPVF) is a collaborative research institute, accredited as Institute for Energy Transition (ITE) in France. The IPVF's internationally renowned research teams are working on the development of the next generation of industrially viable and sustainable photovoltaic modules.
Call for feedback – European Commission to examine need for new rules on environmental impact of photovoltaics Feedback from the Spanish Galvanizers Association (ATEG) Solar parks take up many hectares and can have a significant impact on the environment, generating problems of social acceptance, therefore, is crucial to limit and reduce the environmental impact of facilities of such magnitude, but at the same time…
· · filed 27 Oct 2021 · source
This opinion is submitted by the Fédération Française du Bâtiment (Fédération Française du Bâtiment). The introduction of an energy label for photovoltaics seems counterproductive: • for PV modules, this would amount to calculating efficiency under pseudo-real conditions while peak power is an already very relevant indicator.
Filed in French · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.