PVthin – the international trade body promoting thin-film photovoltaic (PV) technologies – welcomes the European Commission’s initiative on ‘green claims’ and the overarching objective to harmonise these claims in the EU. The thin-film PV industry would support this approach as a continuation of the work on EU Product Environmental Footprint Category Rules (PEFCR) for PV (2013-2018 Pilot). This methodology is already used to validate Life Cycle Assessment (LCA) results in the framework of the International Sustainability Leadership Standard for Photovoltaic Modules and Inverters (NSF/ANSI 457), and has become the basis for a Type-III Ecolabel for the PV product category in the EPEAT registry, expected to be launched later in 2020.
In light of Green Deal ambitions, a stronger methodology/standard is needed to measure the ‘greenness’ of the energy sector. The thin-film PV industry and value chain welcome a clear framework to measure ‘green claims’, including ‘green electricity’. This would address the significant energy requirements of the industrial sector, which will be increasingly electrified as part of the ‘green transition’ and electrification-based sector coupling. Substantiating environmental claims with a reliable and clear methodology that looks at the full lifecycle of the product is crucial to compare different electricity generation technologies and energy vectors (e.g. batteries, hydrogen etc.), and understand which technologies are the most environmentally sustainable. In this context, PVthin supports option 3 to establish a legal framework requiring companies to substantiate green claims via Environmental Footprint methods.
With the EU’s vision to revolutionise its energy system and grid infrastructure, we believe it is a good time to agree a common methodology to assess the environmental footprint of electricity generation from different sources. TPEFCRs developed for solar PV demonstrate that PEF methodology can be applied to the electricity sector and could allow for electricity-based ‘green claims’. Furthermore, the embedded environmental footprint of electricity is considered in almost every organisational/product environmental footprint (OEF & PEF). Therefore, a harmonised definition and methodology to classify green electricity would be very useful. This approach could help avoid some issues/inconsistencies for green claims linked to unbundled RECs, or hard to verify Guarantees of Origin, by using a mandatory PEF-based characterisation for electricity generation technologies across the EU.
Achieving this will require:
1. Regular revisions & updates of current PEFCRs to ensure that they are in line with latest developments, e.g. thin-film PV technologies are rapidly developing and have come a long way since the pilot phase (e.g. perovskites).
2. The development of supplementary PEFCRs for different electricity generation technologies and cross-sectoral energy vectors.
Today, the PEFCR methodology provides the most comprehensive toolbox for the LCA of environmental impacts. It should be used for the development of standards, certifications and labels and is highly relevant to sustainable product policy, including Eco-design, Energy Labelling and Green Public Procurement. These are currently under development, at different levels, for PV modules, inverters and systems. Looking beyond this, PEF/OEF methodologies should become the benchmark for green certification initiatives, such as ‘green claims’, enhancing EU and global harmonisation.
PVthin strongly supports the establishment of a legal framework requiring companies to substantiate green claims via PEFCRs, and will continue to contribute industry knowledge and expertise to the development of a common methodology.