• PVthin Position Papers

PVthin Position Papers

Home › PVthin Position Papers

  • July 2022 - PVthin's response to the Indian Ministry of Environment S.O. 360(E) Notification – Including photovoltaics in Indian E-Waste rules

    At the moment, the Indian E-Waste rules include both an obligation to collect and treat electronic waste (WEEE) and a requirement that electronic goods not include certain chemical substances (RoHS). They exclude PV panels. Were India to include PV in its current E-Waste rules, and apply chemical content requirements to PV, it would have significant consequences on Indian energy security and solar industrial ambitions. PVthin believes that other regulatory approaches are better suited to the PV industry.

  • April 2022 - Why adding lead on the authorisation list of ECHA will hinder innovation in solar photovoltaics

    The European Chemicals Agency (ECHA) regularly assesses the substances on a Candidate List to decide which ones should be included in the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Authorisation List (Annex XIV) as a priority. Based on the prioritisation criteria, in February 2022, lead metal received priority and was proposed for inclusion in Annex XIV. This paper explains that adding lead to the Authorisation List of ECHA will hinder innovation in solar photovoltaics (PV) but also other industries, affecting further deployment of PV in Europe.

  • April 2022 - PVthin responds to the European Commission’s call for evidence on the EU Solar Energy Strategy

    In April 2022, PVthin submitted its feedback to the European Commission’s call for evidence on the EU Solar Energy Strategy. In the submitted position paper, PVthin welcomes the opportunity to comment on the European Commission’s plans to develop an EU Strategy for Solar Energy.

  • March 2022 - PVthin comments for RoHS review call for evidence

    In March 2022, PVthin provided comments to the call for evidence (CfE) on the review of the RoHS Directive. PVthin believes that RoHS “should not prevent the development of renewable energy technologies that have no negative impact on health and the environment and that are sustainable and economically viable.” As the race to deploy renewable infrastructure increases in pace under Fit for 55, requiring continuous innovation to achieve higher performing technologies, the RoHS exclusion for solar PV has only become more vital.

  • February 2022 - PVthin Condemns Forced Labour in the Solar PV Supply Chain

    PVthin unanimously adopted a written statement condemning the use of forced labour in photovoltaic solar power supply chains.

  • October 2021 - PVthin & SolarPower Europe share feedback on Ecodesign and Energy Labelling requirements for PV products

    We particularly support the Commission’s proposal to take into account, among others, the durability, degradation, recyclability, and ecological profile (notably carbon footprint) of PV products, building on existing methodologies such as the Product Environmental Footprint Category Rules (PEFCRs) for PV or the Environmental Footprint Declaration (EPD).

  • October 2021 - PVthin's feedback on the Review of the EU Renewable Energy Directive

    PVthin supports the direction set by the Fit for 55 Package and encourages EU Member States and the European Parliament to work further to increase the uptake of solar PV. The RED III review proposes a number of changes that will have a significant impact on our sector. These include an increase in the share of renewable energy in the EU mix to 40% by 2030 and a requirement for Member States to establish national frameworks governing support schemes for renewables and measures to facilitate Power Purchase Agreements (PPAs).

  • June 2021 - PVthin's position on the EU Sustainable Products Initiative

    PVthin 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.

  • August 2020 - Response to EU Commission's Legislative Proposal on Substantiating Green Claims

    Pvthin 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).

  • May 2020 - Preparatory Study – 3rd Consultation Comments Form (Options and Feasibility of EU Ecolabel and Green Public Procurement Criteria)

    General Remarks 1. The JRC report should reference the existing GPP criteria for the purchase of energy. These criteria focus on the share of renewable energy present in the energy purchased, seeking to reward renewables rich energy mixes. 2. Public authorities tends to purchase renewable electricity via (often technology specific) tenders. They do not hold auctions to buy the hardware & components (PV modules and inverters) that go into new renewable energy generation systems...

  • February 2020 - Commentaires PVthin - Etude de l\ADEME sur les impacts environnementaux du PV en France

    General Comments on the Report • The study seems biased in favor of silicon PV technologies and dismissive of thin-film PV technologies. • The study is equally dismissive of some thin-film technologies’ positive environmental impact, even though these were recently recognized as a best available technologies (BAT) by the European Commission...

  • December 2018 - The Economic Potential of Thin-Film PV in Germany

    The share of renewable energies in German gross electricity consumption has increased from 24 per-cent to 36 percent between 2012 and 2017.1 The coalition agreement of March 2018 plans to further increase the share of renewables in electricity generation, reaching 65 Percent by 2030...

  • September 2016 - Indium anomaly in the PEFCR for PV electricity generation

    In line with that objective and purpose, PVthin has been actively involved in the work of the Technical Secretariat of the PEF Pilot project on photovoltaic electricity generation. The members of PVthin and the undersigned companies representing the value chain of CI(G)S based thin-film PV technologies ask for an amendment...