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International Thin-Film Solar Industry Association

PVthin

The objective and purpose of the Association is to strengthen global energy security and help create sustainable energy infrastructures and to promote the social, economic and environmental benefits of thin-film solar photovoltaic technologies.

Lobbying Activity

Response to Effectively banning products produced, extracted or harvested with forced labour

30 Nov 2022

The International Thin-Film Solar Industry Association (PVthin) categorically condemns the use of forced labour in solar photovoltaic (PV) supply chains and welcomes the European Commissions proposal for a regulation to effectively ban products produced, extracted or harvested with forced labour. Solar PV is at the heart of the energy transition and the fight against climate change. The International Energy Agency estimates that, in order to achieve climate neutrality, solar and wind will need to generate 70% of all electricity worldwide by 2050. The rollout of renewable energy technology must not come at the expense of human rights or the use of forced labour. The European Union has a critical role to play here. PVthin strongly supports the European Commissions commitment to effectively ban products produced, extracted or harvested with forced labour. An import ban will maximise legal certainty for the solar industry and support frontrunners who are able to document the absence of forced labour in their supply chains. PVthin welcomes the EUs commitment and encourages other jurisdictions to put forward bold measures to remove forced labour from the solar sector.
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Response to Sustainable Products Initiative

22 Jun 2022

PVthin – the international trade body promoting thin-film photovoltaic (PV) technologies – supports the regulatory proposal’s objective to extend the scope of Ecodesign beyond energy-related projects. PVthin, having closely followed the ongoing work by the Commission to define Ecodesign requirements for PV modules, inverters, and systems, looks forward to seeing Ecodesign gain ambition. Considering that PV products are one of the last generations to go through the previous Ecodesign rules, we would stress the importance of avoiding any legislative incoherence between products that are already in the scope of the existing Ecodesign Directive with products that will be in the broader scope of the Ecodesign Regulation. To provide stable conditions for market players, it will be essential to make sure that, once they enter into force, the PV Ecodesign policy measures are not affected by the transition from the Ecodesign Directive to the Ecodesign Regulation, ensuring a smooth transition between the two legislative documents.
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Response to Effectively banning products produced, extracted or harvested with forced labour

17 Jun 2022

The International Thin-Film Solar Industry Association (PVthin) categorically condemns the use of forced labour in solar photovoltaic (PV) supply chains and firmly supports the European Commission’s new legislative instrument to effectively ban forced labour products in the EU market. An import ban would maximise legal certainty for the solar industry and support frontrunners who are able to document the absence of forced labour in their supply chains. We believe that a targeted import ban will also be key to fostering sustainable and responsible corporate behaviour throughout global value chains and placing more stringent due diligence obligations on companies operating within the EU. PVthin welcomes the EU’s commitment and encourages other jurisdictions to put forward bold measures to remove forced labour from the solar sector.
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Response to EU Solar Energy Communication

11 Apr 2022

The International Thin-Film Solar Industry Association, or PVthin in short, is a coalition of thin-film photovoltaic (PV) manufacturers and suppliers which promotes the benefits of thin-film solar PV and clean energy more broadly. PVthin represents global leaders in the Thin-Film Solar Industry and broader value chain based on chalcogenide, perovskite, tandem and heterojunction PV technologies. We hereby submit our recommendations as an attachment.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

Please find attached PVthin's feedback to the call for evidence on "Review: Restriction of the use of hazardous substances in electronics".
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Response to Environmental impact of photovoltaic modules, inverters and systems - Energy Labelling

28 Oct 2021

Of the different policy options outlined in the Inception Impact Assessment, we support option 6 – the introduction of Ecodesign, Energy Labelling and EU Green Public Procurement (GPP) measures. This choice would follow a holistic approach to support a sustainable PV industry and consumer landscape. PVthin, in alignment with SolarPower Europe, supports the Commission’s Ecodesign proposals, which will be critical to establish a harmonised set of sustainability requirements for the PV sector at EU level. 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). We encourage the Commission to also ensure consistency with existing international standards that have proven to be successful in harmonising criteria and impact categories, such as the EPEAT Ecolabel for PV modules and inverters. These sustainability and circular economy aspects will also play a key role in the recast of the WEEE Directive planned for 2023. In this context, we would like to see these measures followed up with the establishment of a clear framework for reusing and refurbishing solar PV products to further enhance the circularity of solar energy. The strategic importance of establishing PV Ecodesign criteria was recognised in the updated 2021 EU Industrial Strategy, which states that the market expansion of solar “is a key opportunity, as greater scale should bring lower energy costs for industry as well as society at large. The Commission welcomes efforts to scale up manufacturing of these technologies in the EU, such as the industry-led European Solar Initiative.” Once defined, we would encourage the Commission to make full use of the Ecodesign requirements in an industrial policy context, including GPP, Guidelines for State Aid, and PV support schemes under the Renewables Energy Directive. By harmonising requirements and calculation methods at the EU level, the Ecodesign measures will enable member states to better integrate and weight sustainability aspects such as CO2 footprint in relevant procurement and auction schemes, creating a level playing field across jurisdictions. With regard to the proposed Energy Labelling requirements, we support their use as an additional instrument to inform consumers in a B2C context, provided they are underpinned by a clear methodology. This measure should not become a disincentive to install certain PV applications, but rather a tool enhancing transparency and helping consumers take informed decisions. Provided that this measure is targeting residential PV systems, manufacturers could be given the option not to include the Energy Label on products destined for non-B2C markets, which already use sophisticated site-specific design and energy prediction software to evaluate technology, real world efficiency and energy characteristics. Energy labelling for these applications would be unnecessary, complicating, and costly in mass deployment situations. Finally, market surveillance and enforcement will be critical for enhanced sustainability rules for PV products 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, while at the same time avoiding excessive burdens on producers. More should be done to reward manufacturers that allow for transparent supply chain certification and inspection.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

19 Oct 2021

PVthin welcomes this opportunity to provide feedback on the European Commission’s proposal to review the Renewable Energy Directive (RED III). 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). RED III will undoubtedly lead to more solar PV installations across the EU. As the rollout of renewable energy infrastructure increases in pace, it will be important to account for the environmental impacts arising from the production of its key enabling technologies. The solar PV market illustrates this well: Thin-film PV modules carry less than half the carbon footprint (300 vs 785 gCO2eq / Wp) and a water footprint three times lower (7 vs 22 litres / Wp) compared to average modules. State-run auctions remain an important source of demand for new PV installations the EU. Whereas the overall goal of these auctions is to ensure the cost-effective deployment of PV and other renewables, they also offer an opportunity to drive the market towards the most sustainable technologies. In looking to strengthen national frameworks for renewable support schemes and PPAs – Articles 1(2c) 1(5a) and 15(c) – RED III should also require basic sustainability and social criteria to be included for renewable energy technologies, complementing the EU’s ambitions under the Circular Economy Action Plan, the Ecodesign Directive, Sustainable Products Initiative, and the Sustainable Corporate Governance Initiative. The European Commission is currently developing a number of measures aimed at setting sustainability requirements for renewable energy technologies, including requirements for solar PV modules and inverters under the Ecodesign Directive and the Energy Labelling Regulation. Member State frameworks for support schemes and PPAs can play an important role in valorising the most environmentally virtuous technologies, as defined by these requirements, and thereby promote a level playing field across the EU. Some Member States already include sustainability selection criteria in their support schemes for renewables. This is the case in France, where solar auctions managed by the Commission de Régulation de l'Energie allocate points for the ‘low embedded carbon’ of PV system equipment. By including, for example, a carbon footprint criterion in support schemes, EU Member States have the opportunity to prioritise technologies that are produced sustainably. This would be in line with ongoing work by the Commission to develop Ecodesign requirements for PV, including on carbon footprint. Oversight measures to prevent forced labour and human rights abuses must also be integrated, ensuring that renewable energy technologies contribute to a fair and just transition. This approach would be in line with the latest draft Commission Guidelines on State Aid for Climate, Environmental Protection and Energy, which envisions the inclusion of non-price selection criteria (for instance additional environmental, technological, or social criteria) in competitive bidding processes provided these are not weighed more than 25% in the tender grading system. PVthin looks forward to working with its partners in the solar value chain to support the upcoming legislative negotiations between the European Parliament and Council.
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Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

PVthin strongly supports the ongoing work by the Commission to define Ecodesign requirements for PV modules, inverters and systems. This will be critical to establish a harmonised set of sustainability requirements for the PV sector at EU level. We particularly support the Commission’s proposal to take into account durability, degradation, recyclability, and the ecological profile (notably carbon footprint) of PV modules, building on existing Product Environmental Footprint Category Rules (PEFCRs) for PV electricity, developed during the 2013-2018 Pilot Phase. Today, the PEFCR methodology constitutes the most comprehensive toolbox for the lifecycle assessment of environmental impacts. This methodology should be leveraged for the development of standards, certifications and labels at all levels, and is highly relevant for the Sustainable Products Initiative, including Ecodesign and Green Public Procurement. Whereas PVthin understands the aim to establish a baseline for sustainable PV modules and inverters through the setting of Ecodesign criteria, EU initiatives in this area should be consistent and compatible with existing international standards that have proven to be successful in harmonising criteria and impact categories along the sustainability performance band of different products, such as EPEAT for PV modules and inverters. The strategic importance of establishing PV Ecodesign criteria was also recognised in the updated 2021 EU Industrial Strategy , which states: “The market expansion and global growth in demand for wind turbines, solar PV panels, and smart energy technologies is a key opportunity, as greater scale should bring lower energy costs for industry as well as society at large. The Commission welcomes efforts to scale up manufacturing of these technologies in the EU, such as the industry-led European Solar Initiative. The Commission is also working on ecodesign measures for solar panels, including possible requirements on carbon footprint.” The Ecodesign criteria under development for PV are an innovative case study that shows how traditional Ecodesign requirements (energy yield, material efficiency) can be coupled with additional sustainability measures on environmental footprint and quality control during manufacturing. PVthin agrees with the Commission that Ecodesign offers a comprehensive and reliable regulatory instrument to promote sustainability requirements covering the entire lifecycle of products. In our view, this also means that, where extensive assessments have been conducted concluding that Ecodesign requirements are the best regulatory instrument to address the lifecycle sustainability of product categories, these must be given priority when considering measures under legislation that is more narrowly focused. In particular, regulatory initiatives under chemicals and waste legislation should be consistent with sustainability requirements defined under Ecodesign. This has been recognised, for example, in a recent study conducted on the Commission’s behalf to support the evaluation of the RoHS Directive, which found that “the overlap of RoHS with Directive 2009/125/EC (Ecodesign Directive) is another main issue of coherence raised both under the OPC and by Member States”. The RoHS Directive already recognises that “the development of renewable forms of energy is one of the Union’s key objectives, and the contribution made by renewable energy sources to environmental and climate objectives is crucial” and that therefore 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”. The Commission has an opportunity to further clarify the interface and hierarchy between the many pieces of legislation covering the sustainability of products, materials and substances through the parallel Sustainable Products Initiative.
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

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.
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Response to Restriction of hazardous substances - evaluation

8 Oct 2018

Please find attached the input provided by PVThin, the international industry coalition whose objective and purpose is to strengthen global energy security, help create sustainable energy infrastructures, as well as promote the social, economic and environmental benefits of thin-film solar photovoltaic technologies.
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