HoloSolis

Holosolis contributes to the EU’s goal of local PV module production and curbing global warming.

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ID: 720168452131-03

Lobbying Activity

Response to Minimum requirements on environmental sustainability for NZIA public procurement procedures

9 Oct 2025

HoloSolis welcomes the opportunity to contribute to the European Commissions public consultation on specifying minimum requirements on environmental sustainability in the public procurement of clean technologies, as part of the Net-Zero Industry Act (NZIA). We welcome the Commissions efforts to provide guidance on implementing Article 25, which introduces sustainability and resilience criteria. We suggest that that carbon footprint performance criteria in public procurement should be the main minimum environmental sustainability criterion for PV modules. Such a criteria should be based on the French methodology set in PV tenders for building. Based on more than 10y of experience, this methodology is the best suited to reach the NZIA goals set in art 5. This criteria can bet set as an eligibility criteria and as an award criteria.

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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

13 Jun 2025 · Presentation of the Holosolis PV Gigafactory project and exchange on the next steps at EU level to reshore manufacturing

Response to Implementing Act on non-price criteria in renewable energy auctions

14 Feb 2025

Art 7, Resilience: o The definition of the Implementing Act should be seen as a minimum requirement. We recommend to allow member states wishing to do so to define resilience as made in Europe. o The definition proposed in article 7 of the Commission's implementing act refers to the country of origin of production. However, if production facilities in countries other than the dominant one on the European market are run by industrial groups in the dominant market, the gain in terms of resilience will be very small. The definition of a country with over 50% market share should correspond to the combined market share of all production originating not only within the third country's borders, but also that produced outside its national borders by entities controlled directly or indirectly by companies based in that country A strong focus must be paid to avoid any circumvention of the criteria. Art 8, Carbon footprint: o PEFCR method for PV presents some limitations that need to be solved: The inventories in the annex "PV_module_Life Cycle Inventory_Revision_2232024b" do not reflect technological developments in the PV sector. In addition, the data proposed for calculating the carbon footprint of the components does not meet the quality requirements of ISO 14040-044, which impose temporal, geographical and technological correlation, as well as completeness of the data. The losses and breakages defined do not provide a reliable calculation for a module, as they do not take into account its specific characteristics (wafer thickness, size, cell technology, etc.). However, these factors are major differentiating factors between players and have a significant impact on the carbon footprint results. The PEF database lacks essential information: it does not cover all the materials, chemistry and processes commonly used to carry out an LCA. This shortcoming compromises the quality and reliability of the results obtained. o Some member states like France are using a CFP methodology more than 10 years. The Implementing act should include a grandfathering clause allowing Member states to use a methodology already in place in a tendering mechanism. Art 4, Responsible business conduct: o The implementing text proposes to base itself on the application of delegated regulation 2023/2772, in particular on the elements set out in points 61 (a) to (e) of annex 1. Authorities in charge of the tendering mechanism will not be able to this amount of information. o We recommend to avoid creating too heavy a workload for the authorities in charge of calls for tender by making it possible to refer to the respects of international regulation or guidance that are quicker to assess than the analyze of Due diligence documentation. Art 13, Pollution For some technologies, the main environmental impact may occur during component manufacture. This is particularly true of photovoltaic projects, whose installation and operation have very little impact on the environment. We therefore propose adding the manufacturing stage, as well as compliance with European environmental standards Art 5, cybersecurity: Article 16 stipulates that compliance with cybersecurity criteria is based on the submission of a cybersecurity plan by the petitioner. The analysis of this plan is not compatible with the deadlines of a call for tenders when it covers a very large number of projects, as is the case in photovoltaics. It would be impossible to provide cybersecurity plans for every company taking part in a photovoltaic tender, as the administrative burden on the contracting entity would be far too great. To resolve this difficulty, we propose that Member States should be able to refer to a list of equipment to ensure the cybersecurity of installations. This provision would be consistent with Article (7) 1.a, which stipulates that inverters - equipment whose cybersecurity is essential - may not come from the third country in a dominant position.

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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Mar 2024 · Exchange on state of play in solar manufacturing sector in Europe. Role of the industrial solar alliance

Meeting with Thierry Breton (Commissioner) and ENEL SpA and

1 Dec 2023 · Réunion ministérielle de l’Alliance Solaire