Sustainable & Responsible Supply Chains

Solar energy is only truly sustainable if the products are made responsibly. Today, a large part of the global solar value chain – from quartz and polysilicon to ingots, wafers, cells and modules – is concentrated in China, including in regions where state-imposed forced labour has been documented. At the same time, the carbon footprint of a solar module depends heavily on where and how it is produced.

Ending forced labour

The EU Forced Labour Regulation (Regulation (EU) 2024/3015) bans products made with forced labour from the EU market and applies in full from 14 December 2027. Its database of risk areas and products, the guidelines and the Union Network against Forced Labour Products are being prepared now. ESMC calls for:

• an exhaustive database of risk regions and products, built and run by the Commission itself – listing Xinjiang and potentially other regions in China as risk areas, and covering the solar value chain from quartz and silicon to ingots, wafers, cells and modules,
• a sector-specific approach for solar PV, whose comparatively concentrated supply chain makes effective enforcement feasible,
• clear due diligence guidelines – including for cases where forced labour is state-imposed and independent audits are not possible – and close cooperation with like-minded partners such as the United States,
• reliable traceability, such as the forthcoming Solar PV Passport and independently verified data, instead of voluntary schemes that cannot guarantee clean supply chains.

Lower carbon footprint and circularity

ESMC advocates mandatory environmental requirements for solar products rather than voluntary schemes. In public support and procurement under the NZIA, sustainability criteria should reward:

• a low carbon footprint, building on proven schemes such as the one France has applied since 2011,
• compliance with EU environmental legislation and limits on hazardous substances,
• recyclability – for example PFAS-free back sheets and antimony-free solar glass,
• responsible business conduct and due diligence along the entire supply chain.

This work is led by the ESMC Working Group on Sustainable Solar PV Supply Chains.