PVthin responds to EU survey on Safe and Sustainable by Design criteria for chemicals and materials

In June 2021, the International Thin-Film Solar Industry Association (PVthin) provided feedback to the European Commission’s survey on ‘Safe and Sustainable by Design’ (SSBD) criteria for chemicals and materials.

PVthin welcomes the Commission’s ongoing work to improve the sustainability of products under the European Green Deal, the Circular Economy Action Plan, the Chemicals Strategy for Sustainability, and the EU Industrial Strategy.

Current estimates show that, in order to reach the climate goals set by the Paris Agreement, the deployment of photovoltaics (PV) will need to reach a 10TW target by 2030. Material science will be key to reach this target and actors in the PV industry are currently pursuing a range of technological approaches to achieve this. The EU regulatory environment, including chemicals legislation such as REACH, can influence the pace of this transition.

In its contribution to the SSBD survey, we underlined the following key elements:

  1. Manufacturers in the PV sector often face complex trade-offs when considering the performance of their products across various dimensions of sustainability, including chemical content, resource use, carbon footprint, and circularity. SSBD criteria are an opportunity to address and balance these trade-offs, creating a common EU baseline for initiatives addressing chemicals in products.
  2. When considering which sectors to prioritise for the application of SSBD criteria, due consideration should be given to whether existing regulation already provides for rules on the safety and sustainability of chemicals and materials used in that sector. For example, the Commission is currently developing Ecodesign requirements for PV modules and inverters. The proposed requirement on recyclability already addresses “critical raw materials and environmentally relevant materials”.
  3. Successful implementation of SSBD criteria cannot be achieved in the absence of regulatory certainty and predictability, which in turn is impossible without firm definitions. We strongly encourage the Commission to base SSBD criteria on well-established regulatory lists such as the REACH Candidate List of Substances of Very High Concern and/or sectoral reference standards such as the IEC 62474 declarable substance standard.
  4. SSBD criteria should take into account existing sectoral initiatives such as the EPEAT ecolabel, which defines life-cycle based criteria for a range of product categories, including photovoltaic modules and inverters. Management of substances is a key element in the EPEAT criteria for PV modules and inverters.

Download the complete response here.

(Photo Credit: Karim Ghantous)