NorSun AS
Our mission is to be a leading manufacturer of silicon ingots and wafers for premium solar cells, through innovative technology, sustainable production and operational excellence.
ID: 110813748180-76
Lobbying Activity
Meeting with Thierry Breton (Commissioner) and ENEL SpA and
1 Dec 2023 · Réunion ministérielle de l’Alliance Solaire
Response to Net Zero Industry Act
27 Jun 2023
I. ISSUE: Temporary Crisis and Transition Framework (TCTF), adopted by the European Commission in March and allowing to fund gaps of PV manufacturing investments has been a timely and appropriate measure; however, it has not addressed the operational gap issues including existing capacities, where production is struggling to be competitive in European markets due to price war including state support elements of the suppliers from third countries. In addition to TCTF, allowing support from the Member States on capital investments (CAPEX), the European PV manufacturing operational expenditures (OPEX) gap should be solved finding the solution and envisaging clear perspective for potential investments as well as for the investments already completed. Despite various efforts including the provisions of NZIA on permitting, European PV manufacturing is lacking investments and investors trust partly because the off-take market for the respective European PV production is not yet secured. NZIA makes a right shift into this direction by proposing non-pricing incentives through articles 19-21, however, the smooth functioning of the proposed system would be efficient only in case three factors were included in the NZIA as a package: II. PROPOSAL: To include in the NZIA legislative text the following positive discrimination package: (1) increasing the price difference from 10% to 30%; (2) extend the definition of sustainable PV products and its resilience; (3) define the ceilings for European PV manufacturing products with price premium for 40% of the market share. III. POSITIVE DISCRIMINATION PACKAGE: 1) European made PV hardware has to have the possibility to be sold with price premium to re-shore the PV manufacturing industry (for 7 years, 2024-2030). 2) Net-Zero Industry Act (NZIA) proposals, introduced by the European Commission, goes into the right direction, however, the price premium should be widened (from 10% price premium to 30% price premium) and focus from public procurements and auctions should be extended to all PV deployment projects being delivered in the EU. 3) As 40% European PV manufacturing target for each step of the value chain has been proposed in NZIA, the following concrete measures should be delivered in the same package to ensure the achievement of foreseen target. 4) The proposals for the EU Member States should be obligatory, however, certain flexibility could be given to the Member States to choose the measures but guaranteeing 40% European produced components in implemented PV projects. 5) Firstly, the TOP priority for access the electricity grid should be granted to those entities which guarantee at least 40% European produced materials/componets in the PV deployment supply chain. 6) Secondly, the priority in public procurements and public auctions should be given to the project, envisaging the usage of sustainable and resilience products (Net-Zero Resilience Bonus-Points System). 7) Thirdly, Member States should have a flexibility to propose the alternative criteria to be used in developing PV projects, however, in any case this should lead to 40% domestic production for each step of the value chain in the EU with the price premium for the respective PV products. 8) Constant monitoring (on yearly basis) of domestic European PV manufacturing should be introduced as the projects granted the priority access to the electricity network would have an obligation to report the factual usage of at least 40% of European produced materials. 9) All the above-mentioned measures should be introduced as a package in the NZIA during the legislative process in upcoming months. 10) Alternatively, other measures should be proposed and elaborated, which effect would be the same or similar to the IRA in the USA. Please see attached for more details.
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