PVthin – the international trade body promoting thin-film photovoltaic (PV) technologies – welcomes the European Commission’s proposal to develop a Sustainable Products Initiative (SPI) as a key action under the Circular Economy Action Plan, the European Green Deal and the EU Industrial Strategy. As an international trade association promoting thin film photovoltaic (PV) technologies, PVthin strongly supports the EU’s ambition to establish itself as a global sustainability leader, paving the way for other regions to follow.
Given that the Commission has announced that the core of the Sustainable Products Initiative will be an expansion of the Ecodesign Directive, PVthin is well placed to contribute to this objective, having closely followed the ongoing work by the Commission to define Ecodesign requirements for PV modules, inverters and systems.
Furthermore, the Commission’s work in this space, will be critical to establish a harmonised set of sustainability requirements for the PV sector at EU level, in relevant areas such as public procurement. It will also help further clarify the interface and hierarchy between the many pieces of legislation covering the sustainability of products, materials and chemical substances.
PVthin believes that the SPI could also become, for certain product categories such as PV, an instrument to define minimum social requirements, related for example to labour and human rights conditions in the value chain. Careful consideration should be paid to the interface between the Sustainable Products Initiative and the upcoming Commission proposal on Sustainable Corporate Governance, as well as future social criteria to be added to the work on the Sustainable Finance Taxonomy.
Whereas the SPI consultation includes a number of questions on repairability, it should be noted that closed loop recycling systems such as those described above offer the most effective solution to promote the circularity of PV modules, particularly in utility scale installations. In some cases, repairability can come at the expense of truly efficient recycling schemes. PVthin encourages the Commission not to take a one-size fits all approach, where repairability considerations, driven by consumer good business models, are applied to B2B commercial relationships covered by extended warranties and end of life take back schemes.
Lastly, PVthin points out that market surveillance and enforcement will be critical for enhanced sustainability rules for PV panels to be successful. The stricter the requirements on sustainability, the more important it will be to ensure these are properly enforced, including for imported products. We strongly believe that more should be done to reward manufacturers that allow for transparent certification and inspection.