SolarPower Europe has analyzed the doable affect of introducing EU Ecodesign and Energy Label protection measures for photograph voltaic PV merchandise and has warned that the collection of the components to search out out the carbon footprint of a product shall be key to steer clear of potential fraud options.
For these inside the know, the upcoming EU Ecodesign and Energy Label protection measures for photograph voltaic PV merchandise are among the many most hotly anticipated legislative objects inside the works. These are the technical and data requirements that set the minimal necessities for circularity, energy effectivity, and environmental sustainability for merchandise being positioned within the European market.
In 2021, Ecodesign tips saved European prospects €120 billion ($129.5 billion) in energy expenditure and led to a ten% lower in annual energy consumption. Ecodesign tips apply to greater than 30 product groups, with Energy Labelling making use of quite a lot of these. Until now, photograph voltaic photovoltaic merchandise had no product class of its very personal – nonetheless, that’s all about to fluctuate. There are quite a lot of hypotheses and considerations about what the last word Ecodesign and Energy Label requirements for PV merchandise may seem like, so it’s useful to take a step once more, assess the tactic, and break down some recurring themes in enterprise discourse.
The European Price circulated a draft of the PV Ecodesign and Energy Label measures in June 2022, proposing requirements on most embedded carbon footprint, minimal prime quality and reliability requirements, supplies content material materials disclosure, and completely different spherical components for PV modules and inverters. In March 2023, a substitute of the draft carbon footprint calculation methodology was circulated amongst stakeholders.
With these drafts, the enterprise had a number of sincere issues, a number of of which have been the subject of the most recent dialogue. One key aspect is the carbon footprint accounting methodology, which should be set in a way that forestalls any danger of incorrect reporting. The collection of the carbon footprint purposeful unit – each considering the module nameplate functionality (kW) or barely the PV electrical power produced all by means of the module lifetime (kWh) – has stirred some debate.
The precedence is that incorrect use of the parameters wished to rework the carbon footprint expressed in kWp into the kWh format, which is the purposeful unit beneath the current European Price methodology, may open fraud options. These parameters are module power output, module degradation cost, photograph voltaic irradiance, and module lifetime, principally the weather that allow to calculation of lifetime energy yield from the module nameplate functionality.
Upon nearer look, however, that risk could possibly be very minimal as these parameters are each mounted, or based mostly totally on aim values: power output is set beneath commonplace check out conditions; degradation cost and photograph voltaic irradiance are going to be mounted values; module lifetime shall be each a set price or based mostly totally on product declare, equipped that minimal assure conditions apply. Commerce can really feel reassured – if the methodology goes down this avenue, as we anticipate the European Price will do, and as long as the mounted values are sensible, there shall be hardly room for any incorrect reporting using the kWh purposeful unit.
One different stage of debate is utilizing inexperienced certificates in producers’ electrical power accounting. As the corporate’s renewable shopping for sector booms, the perform of dependable inexperienced certificates grows rather more very important. The 2023 draft already engages with this drawback, setting minimal reliability requirements to be used to distinguish between reliable and unreliable inexperienced certificates.
We moreover understand the Price is fixed to work on the topic and even plan to set additional stringent requirements extra limiting utilizing inexperienced certificates, aligning the methodology with completely different sectors current course of the an identical course of – e.g. the battery sector. The European Price already signaled on a number of events that it didn’t blindly accept third-country inexperienced certification schemes with out clearly demonstrating reliability.
It’s important to verify the inexperienced certificates we use are reliable. It’s moreover very important to acknowledge that direct use of renewable electrical power, equal to a self-consumption PV system positioned on the manufacturing plant, clearly reduces the carbon footprint of the manufacturing course – this could be a good remark that we should always at all times encourage and acknowledge all through the regulation. Towards this background, using solely nationwide energy mixes to search out out the carbon footprint of a product would unnecessarily and significantly dilute granularity.
Previous primary issues regarding the tips’ content material materials, there have moreover been proposals that are not suited to the Ecodesign & Energy Label approved basis. There have been solutions to fluctuate the Energy Label into an indicator of embedded carbon or energy. This stems from a regular misinterpretation of the perform of the Energy Label, which is a tool meant for instance the product’s energy effectivity inside the eyes of end-users – in several phrases, how quite a bit the PV module energy expertise will help them in producing inexperienced energy and save on electrical power funds.
It’d parallel the label you presumably can see in your fridge, moreover that it signifies how a lot energy the PV module produces, barely greater than the facility consumed by the machine. At most, an embedded carbon label might very properly be included as a separate indicator on an influence label nonetheless shouldn’t change the essential operation of the label.
One different suggestion seems to point that Ecodesign might very properly be a substitute for the photograph voltaic industrial protection that the EU is undoubtedly falling temporary on. At SolarPower Europe, we’re clear that ESG-based market entry necessities, like Ecodesign or supply-chain sustainability legal guidelines identical to the Compelled Labour Ban, are key accompaniments to sturdy industrial protection. Market entry necessities help European producers to compete on a stage collaborating in self-discipline with world players – they’re all sure by the an identical tips.
Consequently, there would be the vital factor stage: Ecodesign won’t be about industrial protection; that’d be like making an attempt to utilize a baseball bat to unravel a Rubik’s cube. We should always steer clear of import limitations in disguise which threatens to decelerate the photograph voltaic market, nonetheless rather more importantly, there are greater choices accessible to help European photograph voltaic producers in catastrophe. We’re pushing for an EU Explicit Perform Vehicle to buy out and resell 2023 stock, and calling on Member States to consider state ensures or credit score rating traces to ailing producers.
In the long term, resilience insurance coverage insurance policies beneath nationwide applications and the Internet-Zero Commerce Act ought to play a key perform, whereas the European Funding Monetary establishment must assist photograph voltaic manufacturing enchancment initiatives. The additionally must EU come forward with a particular Picture voltaic Manufacturing Facility, linking to the Innovation Fund or Sovereignty Fund.
We’re anticipating the next draft proposal of Ecodesign & Energy Label Picture voltaic PV tips inside the coming weeks. Though the timeframe is dynamic and has already been subject to delay, this may indicate that the bundle deal might very properly be formally accepted all through the current yr, with tips starting to use as early as 2025. It’s vital to verify of well-timed finalization and no extra dithering to make it attainable for the European photograph voltaic sector is as a lot as take a pivotal perform inside the decarbonization drawback.
Author: Raffaele Rossi
Raffaele Rossi is Head of Market Intelligence at SolarPower Europe and has coordinated the efforts of SolarPower Europe’s Product Sustainability Workstream (and its predecessors) since 2019.
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