The report “Expert input paper on eco-design & energy labelling for photovoltaic modules, inverters and systems in the EU” is the result of a Joint Mission Group of Solar Industry Experts and Researchers, building on the findings of the European Commission Preparatory Study for Eco-Design, Energy Labelling, Green Public Procurement and Ecolabelling. Below is an extract from the report.


Over the last five years, the PV industry has pro-actively engaged with regulators, policy makers and wider stakeholder groups, to quantify the environmental performance of PV technologies and demonstrate the tangible advantages of the different PV technologies available. In the EU, the PV industry participated in the Product Environmental Footprint (PEF) Pilot Phase and developed sectoral Product Environmental Footprint Category Rules (PEFCR) for Photovoltaic Modules used in photovoltaic power systems for electricity generation. This validated the environmental performance of PV technologies in the EU and helped better inform decisions on what EU sustainable product policies would be most appropriate for this category of products. The PEF pilot phase, the development of the PEFCR as well as the related pilot and screening studies, clearly identified the environmental hotspots in the life cycle of PV systems, aiding in the development of voluntary industry standards to address these hotspots at a global level.

Building on the results of the PEF pilot phase, the European Commission added photovoltaic panels and inverters to the work program for Eco-Design in 2016 and extended the Preparatory Study carried out from 2017 to 2019 to also assess whether sustainable product policy instruments such as the EU Energy Label, Ecolabel and Green Public Procurement would be appropriate for the PV industry.

The European Commission’s policy scenario evaluation concluded that the best way to further regulate PV panels was via a combination of mandatory and voluntary policy instruments. This scenario evaluation considered mandatory instruments such as eco-design measures for photovoltaic panels and inverters, augmented by the use of the Energy Label for residential PV systems, and voluntary instruments such as Green Public Procurement Criteria. The latter aspects will be developed between 2020 and 2023 to focus on a number of sustainability, quality, durability, circularity and performance criteria

In order to inform the development of these criteria, representatives of the photovoltaic value chain came together to set up a Joint Mission Group under the umbrella of the European Technology Innovation Platform Photovoltaics (ETIP PV), in cooperation with SolarPower Europe, PVThin, the European Solar Manufacturing Council, and IECRE, to review the results of the preparatory study and provide recommendations for the next regulatory discussions.

Summary of recommendations for policy makers

Photovoltaics is a proven technology capable of making a substantial contribution to a sustainable global energy system. Its widespread use in all geographic regions, versatility in application, modularity in scale enables a socially acceptable energy transition by offering distributed electricity generation, employment and new business opportunities.

The Joint Mission Group welcomes the policy recommendation on the introduction of eco-design requirements for photovoltaic modules and inverters in the EU. These future requirements should be based on standards, which determine the service life, energy yield and degradation – which are the most important parameters influencing the sustainable performance of these components. Given the longevity of the components and the fast evolution of new products & technology concepts, reference values established through accelerated life cycle testing and lifetime yield prediction should provide minimum requirements for performance guarantees, replacement and reparability within the eco-design regulations.

The introduction of an Energy Label for residential scale photovoltaic systems will be a novelty for electricity generating equipment and runs a risk of confusing and disincentivising the electricity prosumer. In line with the policy priorities of all supporting organizations, the Joint Mission Group wants to re-emphasise that every kilowatt peak of solar electricity generation capacity installed provides significant environmental and societal benefits in achieving the green transition of the EU Economy. Given the available, enormous potential of private and commercial rooftops and facades across the European Union to become active generators and empower electricity prosumers, an Energy Label should not disincentivise development of specific applications, but rather ensure transparency of environmental and quality performance of the system components deployed to allow conscious and informed choices.

An informed electricity prosumer in the European Union should have comprehensive and holistic sustainability performance data available for the photovoltaic modules and inverters upon purchasing those components. The lifecycle environmental impact of these system components is well understood, and lifecycle hotspots have been identified and can be effectively addressed by creating market pull for more sustainable products. The introduction of an independently validated combined Energy & Environmental Impact Index, embedded in a quality conformity assurance framework is seen as the most effective mean to enable this transparency and induce the continuous improvement in sustainability performance of these product groups.

The introduction of product sustainability regulations should also support long-term energy security, resource resilience and the revitalisation of all of the value chain of PV products in the EU.

Additional recommendations

Eco-Design for photovoltaic modules

The service life and degradation of a solar module determine the life-time total energy yield that a module generates. These two parameters therefore determine the environmental impact of the generated electricity to a considerable extent. In the current proposal, a lifetime of 30 years is assumed for all module technologies. Degradation can be determined according to a proposed measurement procedure. However, according to the authors, there is no scientifically accepted procedure. The proposed procedure is therefore unreliable and time-consuming. Alternatively, technologies are assigned to two different categories. For crystalline silicon solar modules, an annual degradation of 0.7% is assumed. For thin-film modules, an annual degradation of 1.0 % is assumed, where modules based on crystalline silicon hetero-junction solar cells also fall into this category.

Both the assumption for the lifetime and the assumption for the degradation do not reflect current technological differences. For example, glass-glass modules show very low degradation and long lifetimes. Silicon hetero- junction solar modules are offered in the market with an annual degradation warranty of 0.25 %.

In principle, the following procedures are conceivable for determining the service life and the degradation of a solar module:

  1. Same lifetime for all technologies, different degradation rates for different technology categories (part of the current proposal).
  2. Lifetime and degradation from the manufacturer’s performance warranty. Here it is important that the minimum warranty conditions are clearly defined in the Eco-Design specifications (replacement or repair for the first years, financial compensation thereafter, define measurement procedures in accordance with standards, take measurement uncertainties into consideration).
  3. Different lifetimes and degradation for different technology categories should be based on validated data in conformance with available and future standards, specifically determining degradation rates and expected lifetimes.
  4. Metrological determination of the service life and the degradation.

The expert panel evaluated the different approaches according to the following criteria: (i) effort for the module manufacturer in terms of cost and time, (ii) comprehensive consideration of all technological differences, (iii) need for regular revision, (iv) a scientifically accepted procedure is available, (v) benefit for the customer. The evaluation is summarized in the following table.

Option 1 does not take qualitative differences (reliability) of the modules into account, it has no added value for the module costumer. Option 3 also does not consider qualitative differences of modules. Allocation, regular adjustment and verification are very costly. The customer has no added value. Option 4 is very costly for the module manufacturer, qualitative differences would be proven, regular adjustment and review would not be necessary and the added value for the customer would be very high as qualitative differences are made visible. However, the authors are not aware of any scientifically recognized procedure so far, and the procedure would also be too time-consuming. The experts therefore strongly recommend option 2. A performance guarantee for module degradation and service life will be complied by the module manufacturers, otherwise they have to replace the modules in the event of reduced performance. Therefore, the manufacturer will carefully set the guaranteed degradation and lifetime and carry out appropriate tests. However, it is very important that the minimum guarantee requirements are comprehensively defined in the eco-design directive.

Eco-Design for photovoltaic inverters

One of the most important measures to reduce the environmental impact of photovoltaic inverters is its lifetime. As this is very difficult to estimate or guarantee at the time when the inverter is placed on the market, we suggest focusing on its reparability. This should not be met by defining minimum warranty requirements for inverters, as this could lead to negative incentives such as to plan to replace the inverter during the warranty time which could increase the overall footprint.

In order to promote reparability of photovoltaic inverters, and therefore to increase their lifespan, the Eco- Design measures should ensure the availability of spare parts and that the inverter is constructed to allow access to and replacement of identified parts, in particular that spare parts are available over a long period of time after purchase:

  • 15 years minimum for all electronic / electro-mechanical components of the inverter.
  • this includes the software needed for the full function of the device.
  • at least each individual printed circuit board and disconnectable component must be provided as independent spare part.
  • moreover, during that period, the manufacturer shall ensure the delivery of the spare parts within 15 working days within Europe.

Spare parts can be replaced with the use of commonly available tools and without permanent damage to the inverter. In order to enhance the repair market, manufacturers have to ensure the availability of repair and- maintenance information for professional repairers.

Energy Label for residential-scale systems

The policy recommendation on the introduction of an energy label, suggests a label for the entire solar photovoltaic system deployed on residential rooftops. Here, many factors such as the energy yield of the module, the efficiency of the inverter, the orientation of the module and the location are taken into account. Given the overarching policy objective to improve the sustainability performance of the different system components, the proposed methodology for the determination of the energy performance falls short on its ability to provide component level differentiation. In order to support the customer and the installer in the selection process of components, we suggest an energy label at the module level to be very important. Through this, modules with a better energy yield will also be rated better, which directly influences the purchasing behaviour.

Furthermore, the introduction of an energy label for building integrated photovoltaic systems should be reconsidered, until a holistic evaluation methodology for building products has been developed, which also enables the validation of additional functionalities provided by BIPV elements and to avoid creating disincentives for the building integration of photovoltaics.

The system energy label regarding the expected energy yield for a given location and installation should be complemented by an Environmental Impact Index, which evaluates the environmental impact of module, inverter & balance of system production, operation and disposal, in the various impact categories. The assessment should be based on harmonized PCRs or PEFCRs that are valid in all EU countries. The assessment method must be standardized, clear, cost-effective and simple – a proposal for implementation is provided in the paragraph on the proposed Environmental Impact Index.

It is important that unbundled renewable energy certificates are excluded in the supply chain of electricity for module production and rather the country’s electricity mix has to be used to prevent double counting or misallocation of lifecycle impacts. In addition, it should be considered whether ESG (environment, social and governance) criteria should be taken into account for the assessment of manufacturing and the manufacturer in order to promote an ecological, social and transparent way of doing business in the EU.

The original report can be accessed here