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 welcomes the European Commission's proposed amendments of the Renewable Energy Directive. Attached you may find our full feedback to the proposal. Considering the market growth of solar, the EU can go further even faster in its renewable energy ambition. According to SolarPower Europe modelling, the 40% target is insufficient to reach the required 55% GHG emissions reduction target by 2030.

To be on a pathway consistent with achieving climate-neutrality by 2050, SolarPower Europe supports the European Union to review upwards its 2030 greenhouse gas emissions target to at least 55% and to increase the ambition of its 2030 renewable energy target accordingly by June 2021, before the upwards review initially established by the RED II for 2023.

The RE-Source Platform welcomes the initiative of the European Commission to review the Renewable Energy Directive (RED II) and allow for a faster transition to a green, smart and resilient European energy system.

Solar Power Europe’s recommendations for the Energy Performance of Buildings Directive 2010/31/EU: - Introduce requirements to deploy on-site solar PV and storage on all suitable buildings. - Design Mandatory Energy Performance Standards that incentivise integrated building renovations, with a focus on final energy consumption reductions.

The European Green Deal is a game-changer for Europe. It places the achievement of a climate-neutral economy at the core of a new European growth strategy, and triggers an unprecedented momentum to create local jobs, support the competitiveness of EU businesses, and boost Europe's industrial leadership.

SolarPower Europe welcomes the European Commission's efforts to make supply chains more sustainable. We believe that ensuring respect for human rights and the environment and advancing the clean energy transition go hand in hand.

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 supports the regulatory proposal’s objective to extend the scope of Ecodesign beyond energy-related projects. As already pointed out in our feedback during the previous phases of this legislative initiative, we believe that broadening the scope of sustainability policies to additional sectors of the economy will strengthen EU efforts to reach climate neutrality and achieve the objectives laid out…

SolarPower Europe response to Inception Impact Assessment on Sustainable Products Initiative SolarPower Europe supports the EU Commission’s effort in extending the scope of Ecodesign beyond energy related products.

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

To be on a pathway consistent with achieving climate-neutrality by 2050, SolarPower Europe supports the European Union to review upwards its 2030 greenhouse gas emissions target to at least 55%. However, the EU is not on track to meet its energy efficiency targets, with energy consumption increasing three years in a row.

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.

The taxation of energy products and electricity is a central tool to drive a fair, consistent and cost-efficient energy transition. It will be central to give the right signals to an energy-efficient and renewable-based electrification of Europe.

The coherent and effective taxation of energy products should be the centrepiece of any successful energy and climate policy. It gives a clear price signal to consumers and allocates the costs of the energy transition according to the polluter-pays principle included in article 191.2 of the TFEU.

The coherent and effective taxation of energy products should be the centrepiece of any successful energy and climate policy. It gives a clear price signal to consumers and allocates the costs of the energy transition according to the polluter-pays principle included in article 191.2 of the TFEU.

SolarPower Europe response to Batteries modernising EU rules roadmap SolarPower Europe welcomes this Inception Impact Assessment (IIA) on the modernisation of the EU battery legislation. The new legislation is expected to constitute a cornerstone of the EU’s climate and energy policy and a crucial instrument in achieving the EU’s 2050 climate neutrality goal.

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

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.

Attached can be found SolarPower Europe's full feedback to the Net-Zero Industry Act. As main highlights: SolarPower Europe welcomes the proposal for a regulation on the Net-Zero Industry Act (NZIA), as part of the Green Deal Industry Plan, to improve the regulatory environment for solar PV manufacturing in Europe.

SolarPower Europe provides the following recommendations to scale up the market uptake of renewable hydrogen, building on the priorities provided to the EU Hydrogen Strategy, EU Strategy on Energy Sector Integration, and the revision of the TEN-E Regulation: 1. Foster targeted deployment of renewable hydrogen in hard-to-abate sectors, where direct electrification is not cost-efficient or technically viable.

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.

Electrification of transport can be a game changer for the transport sector, still responsible for a quarter of greenhouse gases emissions in the EU. With falling technology costs, electric mobility can allow for the fast and efficient decarbonisation of road transport, while reducing air and noise pollution and improving health conditions in cities.

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.

SolarPower Europe’s Position Paper on Revision of the Guidelines for Trans-European Energy Infrastructure SolarPower Europe welcomes the European Commission’s proposal for the revision of the Regulation on guidelines for Trans-European Energy infrastructure (TEN-E Regulation) and its further alignment with the European Green Deal, in particular the removal of the oil and gas infrastructure categories and the…

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

Thanks to decreasing costs and scalability, solar will be at the core of the future European energy system: solar PV is set to represent more than 60% of Europe’s total electricity generation according to Lappeenranta University and SolarPower Europe’s 100% renewable energy system scenarios . This will require huge investments in a modern grid infrastructure and ‘smart’ technologies.

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.

SolarPower Europes recommendations overview (please refer to the attached document): 1) Broaden the definition of existing generating modules to include projects under development that have concluded a final and binding main equipment procurement contract, rather than limiting the definition to already connected assets only (Article 45 and 55).

Solar Power Europe welcomes the opportunity to provide feedback on the draft act for the changes to the Waste Shipment Regulation regarding the green-listing of certain waste streams for the purpose of shipping for recovery within Member States.

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 Reply to the European Commission’s consultation on the Just Transition Fund Reaching carbon-neutrality across Europe will require large-scale deployment of renewable energies, to supply carbon-free and cost-competitive electricity for consumers and businesses. According to Bloomberg, renewable energies will make up 90% of the electricity mix in Europe by 2040, mostly driven by wind and solar .

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).

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.