TEXXECURE Rating Foundation gGmbH

TEXXECURE

1.

Lobbying Activity

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

13 Oct 2025

TEXXECURE Rating Foundation strongly recommends that criteria in public procurement should be clear, transparent, and harmonized, setting stringent rules of procedure for improved sustainability and resilience. Our recommendations are built on non-price criteria that should naturally follow EU laws and, while being consistent, be practicable for an effective implementation. In this respect, as suggested by the Joint Mission Group expert input paper (https://pvthin.org/wp-content/uploads/2021-02-ETIP-PV-Report-expert-input-paper.pdf, see Part 2: Operating system example on pages 26ff.) and in the most recent task 12 review of PV sustainability standards issued by the IEA (https://iea-pvps.org/key-topics/t12-sustainability-standards-review-2025/, see chapter 2.2 Product Standards on pages 53ff.), the TEXXECURE / IECRE rating system is recommended to serve as an effective non-price criteria lever to create an equal level playing field for all market participant ensuring sustainability by requiring a minimum BBB rating for any PV components (modules, inverters etc.) to be imported to or manufactured in the EU. In a further embodiment, the rating system can be further advanced to the Environmental and Social Impact Index (ESII, in the above mentioned papers referred to as Environmental Impact Index "EII"). For the purpose of clarification, TEXXECURE Rating Foundation gGmbH is a Germany based non-profit organization, and can therefore be considered applicable as a public reference rather than as a private system. This is supported also by the attached presentation that includes a support letter issued by the DKE.IECRE.CMC, the Technical Advisory Group for Conformity Assessment Renewable Energies and German mirror committee of the decision making IECRE management committee (REMC). DKE is the German Commission for Electrotechnology, Electronics, and Information Technology with DIN and VDE (DKE Deutsche Kommission Elektrotechnik, Elektronik, und Informationstechnik in DIN und VDE). Setting said rating minimum requirement will elevate the sustainability in both, technical terms as well as ESG terms for further deployment of PV technology in the EU. Following the most recent discussions and a building industry consensus in several fora, e. g. SPE, ESIA, EU PVSEC and others, time is of the essence to implement an effective scheme that allows all relevant market participants to use a harmonized system to ensure proper quality and fair trade conditions in PV systems.
Read full response