SolarPower Europe

SolarPower Europe welcomes the European Commissions initiative to advance the Circular Economy Act, recognising its strategic relevance for the solar PV sector. As the EU prepares for increasing PV waste volumes in the 2030s, it is essential to define circular economy policies now, which will enable the efficient handling of PV waste and the recovery of strategic and critical raw materials.

SolarPower Europe welcomes the European Commissions initiative to revise the EU public procurement framework, which explicitly covers the three core directives adopted in 2014. Directive 2014/23/EU on the award of concession contracts. Directive 2014/24/EU on public procurement for the public sector.

SolarPower Europe response to Legislative proposal on substantiating green claims SolarPower Europe welcomes this legislative initiative and its objective to further harmonise, and bring coherence to green claims on the EU Single Market.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SolarPower Europe, the EU-level solar and battery energy storage industry association representing close to 320 members across the solar value chain, supports the Commissions objectives to reduce carbon leakage, ensure fair competition, and align climate policy with industrial resilience.

We at SolarPower Europe, the EU-level solar industry association representing close to 320 members across the solar value chain, note that although solar is not currently targeted under CBAM, the Commission has signalled a likely expansion to other downstream sectors.

Corporate PPA activity is strongly influenced by political and wider energy system conditions. Many issues impacting the broader renewables roll-out, also impact PPAs. Grids are a concern for corporate energy buyers and the uptake of renewable power purchase agreements (PPAs), which the Clean Industrial Deal seeks to accelerate. Our attached position paper provides more details and solutions.

SolarPower Europe feedback on the CRA SolarPower Europe welcomes the Commissions draft guidance on the application of the Cyber Resilience Act (CRA). Clear, proportionate and operational guidance is essential to ensure consistent implementation across complex digital value chains, including inverterbased technologies that are critical to the European electricity system.

The mapping of favourable areas (under article 15b) and acceleration areas (under article 15c) are two distinct processes that can be performed simultaneously or individually. Before entering into the details of how to perform mapping, it is paramount to consider the following principles: 1. The mapping should be technology-specific and should be focused on ground-mounted solar PV.

Energy security is primarily defined as the uninterrupted availability of energy sources at an affordable price. The European energy system has proven robust in delivering power, even under extreme stress thanks to a well-integrated market. However, a comprehensive view of energy security must also include accessibility, sustainability, resilience, cybersecurity and efficiency.

RE-Source Platforms response relates to section 2.4 Electricity Modelling of the draft Delegated Act. Our main message is: Corporates active during all life cycle stages in scope of the Regulation must continue to be incentivised to sign renewable power purchase agreements (PPAs) in advancement of their climate neutrality goals. Their existing PPAs must also count towards their carbon footprint reduction.

SolarPower Europe and its Battery Storage Europe Platform are the voice for the solar PV and BESS (Battery Energy Storage Systems) sector in the EU and welcome the publication of the draft implementing act on Battery Labelling as it provides key information for timely compliance with the Batteries Regulation (2023/1542).

SolarPower Europe is the leading solar association in Europe. In our July 2024 position paper "Setting a Harmonised Cybersecurity Baseline for Solar PV", we called for recognition of internet-connected solar inverters as critical infrastructure.

SolarPower Europe seeks to highlight the fact that the carbon footprint methodology developed under the ESPR Delegated Act for steel will establish an important precedent for future ESPR product groups and other applications of low carbon definitions in EU law such as under the Industrial Accelerator Act or the Net zero industry act.

SolarPower Europe and its Battery Storage Europe Platform welcome the opportunity to provide feedback on the additional draft legislation for Article 26 of the Critical Raw Materials Act (CRMA) and its accompanying Annex.

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).