Minimum requirements on environmental sustainability for NZIA public procurement procedures

We support the European Commissions efforts to establish minimum environmental sustainability requirements for public procurement procedures involving net-zero technologies. While we welcome the Commissions initiative, we believe that excluding geothermal energy at this stage contradicts the NZIAs technology-neutral approach.

The German Association of Local Public Utilities (VKU) represents 1.601 local public utilities in the fields of energy, water/wastewater, waste management and telecommunications. Our position on the European Commissions consultation on the implementing regulation on "public procurement of clean technologies minimum requirements on environmental sustainability" can be found in the attached document.

IDAE appreciates the European Commissions initiative on implementing minimun enviromental sustainability requirements for public procurement procedures involving certain net-zero technologies and welcomes the opportunity to send our contribution. Comments and suggestions on the draft can be found in the attached document.

The Net Zero Industry Act (NZIA) brings new rules to scale up the manufacturing capacity and access to a secure and sustainable supply of net-zero technologies in the EU to support the EUs Climate & Energy targets. It introduces mandatory non-price criteria in auctions both prequalification and award criteria for a share of national auctions and tenders.

ENERCON welcomes the Commissions intention to advance circularity in the wind-energy sector but believes the proposed 70 % recyclability requirement for blades risks missing the core challenge. Wind turbines are already 8590 % recyclable; the remaining issue is economic, not technological.

Bellona Europa welcomes the European Commissions Draft Implementing Act introducing minimum environmental sustainability requirements for public procurement of clean technologies under the Net-Zero Industry Act (NZIA). This initiative is a key opportunity to align industrial decarbonisation with the EUs climate and competitiveness goals.

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the consultation on Public procurement of clean technologies minimum requirements on environmental sustainability. For further details on our position, please refer to the document attached to this feedback. Best Regards.

SolarPower Europe welcomes the opportunity to contribute to the European Commissions public consultation on specifying minimum requirements on environmental sustainability in the public procurement of clean technologies, as part of the Net-Zero Industry Act (NZIA).

Please find enclosed the BDEW opinion on NZIA in the field of public procurement in German and English as a feedback to the consultation ‘Public procurement of clean technologies minimum environmental sustainability requirements’.

Filed in German · English published by the European Commission

The European steel industry fully supports the Net-Zero Industry Act (NZIA) as a key driver for accelerating clean technology deployment. Steel is an essential material for the EU economy as well as a strategic industrial and net-zero enabling material, indispensable for EU climate neutrality and serving as a core input for solar, wind, hydrogen and grid infrastructure.

Siemens Energy welcomes the opportunity to provide feedback on the European Commissions consultation on the Implementing Act on Public Procurement of Clean Technologies Minimum Requirements on Environmental Sustainability. Please find attached our response. We remain at your full disposal for any further discussion. Thank you.

The Korea Business Association Europe (KBA Europe), representing over 400 Korean companies in Europe, and the Korea International Trade Association (KITA), which represents more than 77,000 international manufacturing and trading firms in Korea, appreciate the opportunity to provide feedback on the draft implementing regulation of NZIA.

ENTSO-E, the European Network of Transmission System Operators for Electricity, is the association for the cooperation of the European transmission system operators (TSOs). The 40 member TSOs representing 36 countries are responsible for the secure and coordinated operation of Europe's electricity system, the largest interconnected electrical grid in the world.

The BDE as the Federation for the German Waste, Water and Circular Economy Management Industries welcomes the draft implementing act laying down minimum requirements for the public procurement of net-zero energy technologies and appreciates the opportunity to provide comments on the draft.

Thank you for the opportunity to provide input to the draft Implementing Act concerning sustainability criteria for public procurement of clean technologies, specifically a blade recyclability requirement for wind. Ørsted welcomes the Commissions efforts to drive decarbonization and supply chain resilience in the sector.

The galvanizing industry plays a key role in supporting the EUs sustainability and climate objectives by substantially enhancing the durability of steel products through effective corrosion protection. We welcome the opportunity to contribute to the European Commissions public consultation on specifying minimum requirements on environmental sustainability in the public procurement of solar technologies, as part of…

Turkish Steel Producers Association (TSPA) Statement on laying down rules for the application of Regulation (EU) 2024/1735 of the European Parliament and of the Council as regards minimum environmental sustainability requirements for public procurement procedures involving certain net-zero technologies

We are a centralised purchasing organisation that would be applying the Implementing Regulation prepared by the European Commission for the procurement of solar technology products. However, we note that several aspects of the draft Regulation remain unclear, particularly with regard to the practical application of the criteria in public procurement procedures. Our observations are as follows: 1.

The European photovoltaic industry welcomes the European Commissions initiative on Public procurement of clean technologies minimum requirements on environmental sustainability. For photovoltaic modules, it is essential that the minimum requirement on mechanical durability explicitly includes a hail resistance level slightly above VKF HW4, that is, impact testing equivalent to or beyond 40 mm hailstones, with…

The draft implementing act, as it stands, will have a very limited effect on reducing the environmental impact of NZIA technologies, compared to current practices in the public procurement. The European steel industry request that public auctions help create lead markets that will drive demand for low CO2 steel products made in the EU.

The Net-Zero Industry Act allows increasing the use of clean technologies, such as wind, heat pumps and grid technologies. This initiative sets out the rules for public procurement of these technologies. The basis for transparency is information on procurement through a dedicated European website to be advertised in all European public buildings.

Filed in Italian · English published by the European Commission

TEXXECURE Rating Foundation strongly recommends that criteria in public procurement should be clear, transparent, and harmonized, setting stringent rules of procedure for improved sustainability and resilience. Our recommendations are built on non-price criteria that should naturally follow EU laws and, while being consistent, be practicable for an effective implementation.

EXXERGY strongly recommends that criteria in public procurement should be clear, transparent, and harmonized, setting stringent rules of procedure for improved sustainability and resilience. Our recommendations are built on non-price criteria that should naturally follow EU laws and, while being consistent, be practicable for an effective implementation.

EDP welcomes the European Commissions initiative under the Net-Zero Industry Act (NZIA). To ensure effective implementation, EDP highlights three key considerations: First, harmonisation across Member States is essential to avoid fragmentation and ensure consistent EU-wide criteria, preventing the emergence of 27 divergent national rules.

While Article 2 correctly enumerates many technical specifications for photovoltaic (PV) modules, most of these are already verified through international certification (IEC 61215, IEC 61730, UL, EN). Certification ensures intrinsic product quality but does not address equally critical aspects of mounting, fixing, anchoring, sealing and long-term mechanical protection once the system is installed.

Celsa welcomes the European Commissions initiative to adopt implementing rules under Regulation (EU) 2024/1735 [Net-Zero Industry Act] to strengthen the role of public procurement in supporting the deployment of sustainable net-zero technologies. This initiative represents a key opportunity to align Europes public purchasing power with its industrial decarbonisation and circular economy objectives.

The European Solar Manufacturing Council (ESMC) welcomes the European Commissions initiative but we are concerned that the draft implementing regulation completely omits sustainability requirements for solar PV, despite the regulations stated purpose. Solar PV is central to Europes net-zero transition, and excluding clear environmental criteria risks undermining both climate and industrial objectives.

The proposed minimum environmental sustainability criteria rightly build upon existing standards. Where such standards are not yet firmly embedded in the sector, the criteria may serve as a catalyst for broader adoption. Nonetheless, we wish to highlight two critical points for further consideration: 1.

We welcome the opportunity to contribute to European Commissions public consultation concerning draft Implementation Regulation under Regulation (EU) 2024/1735. When evaluating the draft regulation from the perspective of the EU public procurement legal framework, it is essential to ensure that its implementation remains sufficiently flexible and does not create unnecessary administrative burdens - particularly on…

Please see the feedback of PGE Polska Grupa Energetyczna S.A. below: 1) The resilience of solar technologies: The Article 2 lists the circumstances which PV modules should withstand. The current wording is directly referring to the heat (hot-spot heating effects) or weather event like hail, but only indirectly suggesting the impact of harsh winter and low-temperatures occurring in some Member States: outdoor…

Fraunhofer ISE has conducted an analysis of the proposed implementing regulations for photovoltaic (PV) modules and inverters. Our findings indicate that the current proposals fall short of incentivizing meaningful advancements in sustainability. The absence of additional requirements beyond existing market standards risks stagnation in environmental and social progress within the PV sector.

We would like to thank you for the opportunity to participate in the public consultation. We see potential for discussion on the following 3 points. 1) In our opinion, Article 1 lacks a definition of intended use and a classification as application of a specific area of law.

We consider the proposal to be good and realistic. There is a time-limited technology, at least here, which certainly justifies the absence of overlapping and conflicting regulation. As far as solar installations are concerned, it would appear that the basic requirements are already largely feasible at present. Wind blade waste is talked hard, so it is good to be tackled.

Filed in Finnish · English published by the European Commission

HoloSolis welcomes the opportunity to contribute to the European Commissions public consultation on specifying minimum requirements on environmental sustainability in the public procurement of clean technologies, as part of the Net-Zero Industry Act (NZIA). We welcome the Commissions efforts to provide guidance on implementing Article 25, which introduces sustainability and resilience criteria.

We strongly welcome the European Commission’s approach of setting mandatory sustainability requirements for public procurement of net-zero technologies with this draft implementing act. The initiative is an important step towards better anchoring sustainability and climate action in procurement decisions. However, in our view, there is still a need for additional and clarification on a number of points: 1.

Filed in German · English published by the European Commission

EnBW welcomes the European Commissions draft delegated act under Article 25 of the Net-Zero Industry Act (NZIA), particularly for its balanced and feasible approach to integrating sustainability criteria into public procurement for net-zero technologies. With regard to the listed requirements for PV in Article 2 there are no objections.

We thank the Commission for the opportunity to contribute. You will find our detailed position paper in attachment. Essentially, we, European manufacturers of carbon fibres, support the 70% recyclability thresholds for the blades of wind turbines.

The draft Implementing Regulation of the European Commission under Regulation (EU) 2024/1735 establishes minimum requirements for environmental sustainability in the public procurement of selected net-zero technologies. Clear, EU-wide technical specifications can make a decisive contribution to clean net-zero technologies in the European Union.

The draft Implementing Regulations current focus on technologies under Article 4(1)(a) and (b) of the NZIA Regulation (solar PV and wind) is understandable given time constraints and methodology gaps. Nonetheless, further clarity on the timeline and process for including technologies under points (e) to (k) would be valuable.

Vestas welcomes the Commissions ambition to encourage sustainable end-of-life treatment of wind turbine blades. This is key to achieving a fully circular wind energy sector in Europe. The Commission has proposed a 70% recyclability rate for blades as a minimum requirement for wind energy.

Attached is the position of PKEE concerning the draft Implementing Regulation establishing minimum environmental sustainability requirements applicable to public procurement procedures. The contribution addresses the following aspects: 1. The need to account for climatic differences across EU Member States (Art. 2(2); 2. Recommendation to simplify compliance verification for solar technologies (Art. 2(6); 3.

As part of the public consultation on the draft implementing legislation setting out minimum requirements for environmental sustainability for public procurement procedures, we would like to submit expert comments on the individual provisions of the submitted draft implementing regulation.

Clean technologies should be cleanly manufactured. There is no point installing a PV array to save on energy related carbon if the carbon cost of manufacture was high. It is worse than doing nothing as it encourages "spending" carbon today to save it tomorrow.