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From 30 December 2025, every EU member state has to apply non-price criteria to at least 30 percent of the renewable capacity it auctions each year, or to at least 6 GW, under Article 26 of the Net-Zero Industry Act and Implementing Regulation (EU) 2025/1176. Life-cycle carbon footprint is the first of the eight environmental sustainability criteria a member state can select. The first auctions written to these rules open this year, and a project developer who cannot show a footprint certificate for the exact module type has nothing to enter where the tender asks for it.
France shows what that looks like in a market that already scores carbon. The ECS assessment, issued by Certisolis, is measured against a threshold of 550 kg CO2eq per kWc set by the French Energy Regulatory Commission (CRE), and the PPE2 energy policy has strengthened those requirements further. Italy and Germany treat product carbon footprint certification as a reference for market access. Ireland, whose auctions have been priced-only until now, is consulting on how to score the same criteria.
Low-carbon solar procurement runs on verified footprint data. LONGi's silicon wafer and module products held 64 carbon footprint certifications worldwide at the end of 2025, issued under five separate verification systems.
The 64 certifications span five separate verification systems
A product carbon footprint certificate reports the emissions of one declared module type across its lifecycle, from silicon feedstock to end-of-life treatment, and a third party checks the calculation. Five systems matter for European buyers: the French ECS assessment, the French PEP ecopassport, Environmental Product Declarations published under EN 15804 in programmes such as the International EPD System and EPD Italy, ISO 14067 product carbon footprint certificates, and the certificate of the China General Certification Center (CGC) issued under the Chinese industry standard SJ/T 11926-2024. Each certificate is registered against a specific product code, which is what allows an asset owner to report a supplier value instead of a regional average.
The LONGi 2025 Sustainability Report breaks the number down. Silicon wafer products hold 25 French carbon footprint certifications. Module products hold 24 French certifications, 8 international Environmental Product Declarations, 3 French PEP ecopassport certifications, 2 ISO 14067 certificates and 2 product carbon footprint certificates from the CGC. One of the eight EPDs, registered with the International EPD System under EN 15804+A2 (EPD-IES-0025918:001), covers five HPBC 2.0 module codes, including the Hi-MO X10 line. The registration number goes straight into a tender file, in place of a general product description.
Certification is moving upstream as well. Three polysilicon suppliers obtained French carbon footprint certifications in 2025, and 23 suppliers completed ISO 14067 certification. Polysilicon is the single largest emission source inside a module, so a certified supplier changes the number the module itself can declare.
A certificate beats an industry average because it names its source
Most of the emissions in a solar module are bought in, not produced in the module factory. Scope 3 accounted for 90.4 percent of LONGi's total value chain footprint in 2025, and purchased goods and services made up around 84 percent of Scope 3 in 2024. Industry default factors flatten all of that into a single number that describes no particular supplier.
A certificate reports what a named supplier actually did. LONGi's Scope 3 intensity per tonne of purchased goods is down 39.2 percent against 2020. The company drew 52.4 percent of its electricity from renewable sources in 2025, and operational emissions from Scope 1 and Scope 2 fell 7.86 percent year on year. None of that reaches the buyer's own reporting through a default value.
The cost of a default value shows up late in a project. Scope 3 category 1 reporting requires a named document, and a module that turns out to be uncertified for the target market has to be replaced after the system design is already fixed.
An auction that scores carbon footprint cannot be answered with an industry average. The document that clears it is registered to one module code, the code that appears in the bill of materials, and procurement decisions in a low-carbon market are made on that evidence. A module without it does not reach the bid.
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