As previously set out, SolarPower Europe welcomes the European Commission’s proposal on an EU market ban for products made using forced labour. SolarPower Europe is deeply aligned with the European Commission’s goal to tackle the issue of forced labour, and we continue to unequivocally condemn forced labour, and any abuse of human rights.
The draft legislation marks an important milestone for sectors across the economy and represents real value for the functioning of the internal market. As a sector currently dependent on non-EU supplies, the solar industry is a highly conscious of the importance of responsible supply chains.
SolarPower Europe supports the European Commission’s efforts to ensure products manufactured in or entering the EU market are not produced, extracted, or harvested with the use of forced labour. When it comes to the energy sector in particular, such an initiative is fundamental to ensure that any energy transition is not only a just transition but is also compliant with human rights obligations.
As an industry, we are delivering on our responsibilities and committed to keeping the supply chain in line with ESG (Environmental, Social, and Governance) standards (including UNGPs and OECD Guidelines). Consistent with this, many of our members are conducting human rights and environmental due diligence. Collectively, SolarPower Europe and its members have launched the Solar Stewardship Initiative (www.solarstewardshipinitiative.org) to address complex issues around managing supply chains that individual companies cannot effectively tackle alone.
SolarPower Europe welcomes the opportunity to participate in this public consultation on the European Commission proposal for a Regulation of the European Parliament and of the Council on prohibiting products made with forced labour on the Union market.
In order to deliver an effective regulation that delivers what it sets out to do, and works in practice, we advocate for the following principles in the highlighted document. A snapshot summary can be found below.
SolarPower Europe Position Paper on the Forced Labour Product Ban
Supporting the goal of ensuring products in the EU are free of forced labour. Maintaining a coherent approach with EU due diligence legislation. Ensuring legal certainty. Standardising import requirements.
Read the position paper now
Centrality of due diligence and effective enforcement
The European Commission should ensure due diligence is the main principle guiding enforcement by the national authorities to both ensure that the actual human rights violations are detected early on and reduce overall administrative burden on companies.
An implementation process ensuring business and legal certainty
We welcome the Commission’s commitment to prepare implementation guidelines for both national authorities and economic operators. These guidelines should be sector specific and be issued within 10 (and not 18) months from the Regulation’s entry into force in line with average contracting lead times. This will allow solar companies to comply with the legislation within the proposed 24-month grace period.
Import requirements should be manageable and standardised
To date, the EU does not have a significant domestic solar PV module and material supply and depends on imports to support the ambitious EU targets defined in the RePowerEU and the Green Deal. Beyond the fundamental need of having to accelerate the efforts to re-develop a PV manufacturing base in the EU, (see SolarPower Europe letter) the EU also must ensure that the import process is not overloaded with bureaucracy and red tape for the companies involved. The implementation guidelines should provide a standardised set of documents, defined in cooperation with the industry, needed for PV products and components under review
Legislative and policy coherence
While the centrality of due diligence emerges from the Proposal, the interplay between the upcoming Corporate Sustainability Due Diligence Directive (CSDDD) and this Regulation should be further clarified to avoid duplication of obligations.
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