European Solar Manufacturing Council

ESMC feedback to The Circular Economy Act The European Solar Manufacturing Council (ESMC) welcomes the Commissions initiative to strengthen circular economy measures. As solar photovoltaics are poised to become Europes largest energy source, it is critical to address key gaps in PV sustainability.

The Industrial Accelerator Act, together with the Net-Zero Industry Act and the Clean Industry Deal, is meant to secure and restore European manufacturing and strengthen resilient clean-tech value chains. The manufacturing sector is essential for safeguarding and boosting the EUs long-term economic success.

ESMC Feedback to: EU Public Procurement rules Under the Net-Zero Industry Act (NZIA), solar PV is identified as a strategic net-zero technology with a 40% EU manufacturing target across the value chain by 2030. Yet today, more than 95% of solar modules installed in the EU and their components are imported, predominantly from China.

Please find our full feedback text attached. We strongly support the move towards a comprehensive, risk-based Cybersecurity Act (CSA) framework that integrates both technical and non-technical risk factors, as well as the formalisation of a high-risk supplier framework. Europe's electricity infrastructure faces a critical and growing dependency on Chinese suppliers of inverter-based resources.

The European Solar Manufacturing Council, which represents around 70 companies involved in European solar manufacturing, including many inverter manufacturers, welcomes the opportunity to contribute to the revision of the Cybersecurity Act (CSA).

The European Solar Manufacturing Council (ESMC) urges the European Commission to extend the Carbon Border Adjustment Mechanism (CBAM) to key downstream solar products, including: Solar PV modules (finished photovoltaic panels) Mounting structures (aluminium and steel frames that support solar panels) Solar trackers (motorized systems that orient panels toward the sun) We also recommend that the Commission adopt…

Digital Product Passport Registry - feedback The European Solar Manufacturing Council (ESMC) welcomes the European Commissions initiative to strengthen circular economy measures. As solar photovoltaics (PV) are poised to become Europes largest energy source, it is critical to address key gaps in PV sustainability.

Please see attached document for full version. ESMC advocates for a delegated act to the cyber resilience act to introduce the product group: Products and applications with a purpose to manage energy generation and/or consumption that can be exposed to a public internet connection.

Our feedback focuses on two priorities: maximising security of supply through resilient European renewable energy; and addressing the severe security risks linked to Europes high dependency on Chinese solar PV inverters.

There are not enough investments followed by the non-adequate production of the Net-Zero Industries in the EU. The EU is currently too much dependent on the solar PV production import mainly South-East Asia and China in particular. This overdependency creates energy security risks for the EU electricity sector and the entire transition towards low-carbon economies.

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.

EU Rules of Origin (RoO) define the country where a product has been made for customs, trade, and regulatory purposes. Given the high dependence on a single third country in the solar PV supply chain, we see this consultation is a good opportunity to propose changes to the RoO framework with the purpose of mitigating that dependency.