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News 07 February 2024

EERA joins European PV industry in calling for crucial changes to the proposed methodologies for the Ecodesign and Energy Label legislations

EERA Secretary General Adel El Gammal has joined fellow representatives from prominent European PV research institutes and organisations, along with European PV associations and manufacturers, in calling for changes to the proposed methodologies for the Ecodesign and Energy Label legislation. 

On 1 February, together in a joint letter to the European Commission, the signatories have advocated for regulations that serve the climate and the environment, and crucially, incorporate a rational and comprehensive methodological approach.

‘‘With solar energy expected to become the world’s primary energy source in the coming decades, it is crucial that solar PV materials are manufactured in an environmentally and socially responsible manner.’

Ecodesign and Energy Labelling legislations set carbon footprint thresholds for PV modules to enter the EU market, in which signatories recognise their robust potential to promote the competitive advantage of the European PV manufacturing value chain. However, the letter states that this can only be achieved if ‘‘the carbon footprint calculation methodology prevents greenwashing and closes loopholes for manipulation.’’

Against this backdrop, the letter outlines three recommendations proposed by the ensemble of stakeholders that are vital for ensuring the competitiveness of the European PV manufacturing industry and moreover, achieving the central goals of a clean transition.

  • Carbon Footprint Calculation: the letter details the concerns of the industry regarding the calculation of the carbon footprint of the PV modules on a kilowatt-hour (kWh) basis, emphasising that such a method allows for manipulation through lifetime, degradation, and green energy certificate uncertainties. Instead, the letter calls for the calculation to be on a kilowatt-peak (kWp) cradle-to-gate basis. This latter method is considered to be the more reliable, in which it is widely utilised in many countries and international standards.
  • Limitations on Green Certificates/PPAs: the extensive use of green certificates/Power Purchase Agreements (PPAs) is thus far permitted in the draft version of the Ecodesign legislation, meaning manufacturers, including those primarily dependent on fossil fuels, will be allowed to acquire a carbon footprint classification that does not accurately reflect the climate impact of their manufacturing processes. In response, the letter advocates for strict limitations on these mechanisms, alternatively proposing the use of EPEAT, which imposes clear limitations on market-based energy usage and employs stricter control mechanisms compared to the proposed version.
  • Improved Energy Label: The current Energy Label design centres exclusively on energy yield, omitting a number of key factors, among them reducing production-related emissions, recyclability, and durability. As such, the industry primarily calls for the incorporation of these factors into the label, and furthermore, if this is not possible, the letter recommends ceasing the introduction of an energy label for PV modules.

‘‘It is essential to recognize that achieving a transition to a greener economy extends beyond the mere exclusion of a small fraction of the worst modules from the EU market. What is truly required are more stringent standards.’’

Read the letter in full here.

Discover more information on the initiative here.