C(2025)2901

EXPLANATORY MEMORANDUM

1.CONTEXT OF THE DELEGATED ACT

On 29 June 2024, Regulation (EU) 2024/1735 on establishing a framework of measures for strengthening Europe’s net-zero technology manufacturing ecosystem and amending Regulation (EU) 2018/1724 (the Net-Zero Industry Act or NZIA) entered into force. This regulation establishes a framework to ensure the EU’s access to a secure and sustainable supply of net-zero technologies by scaling up their manufacturing capacity and supply chains.

To support its implementation, Regulation (EU) 2024/1735 empowers the European Commission to draft a delegated act to amend the Annex, which lists the final products and specific components that are considered to be primarily used for the production of net-zero technologies. The goal of the present delegated regulation is to amend the Annex and to identify, for each sub-category of net-zero technologies, the components that are primarily used for these technologies.

All components that are listed in the present delegated regulation are considered to be primarily used for the production of net-zero technology final products. The relevant provisions in Regulation (EU) 2024/1735 and particularly the provisions in Chapter II (‘Enabling conditions for net-zero technology manufacturing’) therefore apply to them. Specific components not included in the present delegated regulation may still fall within the scope of Regulation (EU) 2024/1735 if, on the basis of evidence provided to a national competent authority, the project promoter can prove (for example, via market studies or off-take agreements) that the specific components are primarily used for the production of net-zero technologies.

As required by Article 46(7) of Regulation (EU) 2024/1735, the list of the primarily used components set out in the present delegated regulation is based on a comprehensive assessment and on a methodological analysis of the supply chains, taking into particular account commercial availability, the appropriate level of detail and technological developments. The assessment aimed at identifying, to the extent possible, the final products and specific components that are manufactured and traded by a company, that are essential for the production of net-zero technologies, and that can therefore reasonably be considered to be “always primarily used”. The assessment is provided in Staff Working Document SWD yyyy/xxxx [SWD 2025/932 – PO please complete the reference] 1 , which outlines the methodology that has been set up on the basis of the relevant aspects of Regulation (EU) 2024/1735. In particular, the methodology sets out some practical ways to implement the criteria outlined in Regulation (EU) 2024/1735, such as ‘specific’, ‘commercial availability’, ‘always primarily used’ and ‘essential’. The methodology is then applied to all net-zero technologies in order to identify final products and specific essential components that can reasonably be considered to be primarily used for net-zero technologies.

2.CONSULTATIONS PRIOR TO THE ADOPTION OF THE ACT

The decision to amend the Annex to Regulation (EU) 2024/1735 in order to identify, for the net-zero technologies, final products and the components that are primarily used for these technologies has been subject to a thorough consultation process. The Commission consulted in-house experts, stakeholders from net-zero technologies sectors and Member States at various stages of the preparation of the delegated act. In particular, the Commission drafted the present delegated regulation in consultation with the Expert Group on Net-Zero Technologies and Supply Chains (E03968).

During the Expert Group’s first meeting, the Commission presented the methodology for selecting the components and explained its application using three examples: solar photovoltaic, ocean energy and geothermal energy technologies. Online informal meetings were also held with Member States, allowing more technical discussions on net-zero technologies. Following this first set of meetings, the methodology and its initial application were amended to take into consideration the positions of the Member States.

The draft Delegated Act was published in January 2025 for a 4-week feedback period. Stakeholders provided 158 submissions. These came in majority from business associations and companies. Stakeholders suggested additional components to be added to the list and in some cases also suggested alternative terminologies to already included components. All the inputs received were carefully analysed by the Commission. A second Expert group meeting was also organised to gather inputs from Member States. Following this, the draft Delegated Act was amended accordingly, and around 50 components were added to the list.

3.LEGAL ELEMENTS OF THE DELEGATED ACT

Article 46(7) of Regulation (EU) 2024/1735 empowers the Commission to adopt a delegated act in accordance with Article 44 to amend the Annex based on the list of net-zero technologies in Article 4 of Regulation (EU) 2024/1735, in order to identify the sub-categories within net-zero technologies and the list of specific components used for those technologies.

The present delegated regulation includes two articles: an article to amend the Annex and an article containing the entry into force provisions.

The Annex provides, for each net-zero technology, the updated sub-categories and a list of final products and specific components used for the net-zero technologies. The list of final products only serves an explanatory purpose and aims to provide more context to the list of specific components used for net-zero technologies.

COMMISSION DELEGATED REGULATION (EU) …/...

of 23.5.2025

amending Regulation (EU) 2024/1735 of the European Parliament and of the Council as regards the identification of sub-categories within net-zero technologies and the list of specific components used for those technologies

(Text with EEA relevance)

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2024/1735 of the European Parliament and of the Council of 13 June 2024 on establishing a framework of measures for strengthening Europe’s net-zero technology manufacturing ecosystem and amending Regulation (EU) 2018/1724 2 and in particular Article 46(7) thereof,

Whereas:

(1)Regulation (EU) 2024/1735 established a legal framework that strengthens the Union’s resilience and security of supply in the field of net-zero technologies, by enhancing the Union’s capacity for manufacturing, deployment and innovation in that field.

(2)The Annex to Regulation (EU) 2024/1735 sets out in a non-exhaustive manner a list of specific components considered to be primarily used for the production of net-zero technologies.

(3)Specific components and specific machinery not included in that list may still fall within the scope of Regulation (EU) 2024/1735 if the project promoter can provide evidence, for example market studies or off-take agreements, to a national competent authority showing that the specific components or machinery are primarily used for the production of net-zero technologies.

(4)A comprehensive assessment, based on a methodological analysis of the supply chains of the net-zero technologies, has been carried out by the Commission. That assessment took into account in particular the commercial availability of the components, the appropriate level of detail and developments in technology.

(5)To identify specific components considered to be primarily used for the production of net-zero technologies, four criteria were applied in the assessment, namely their specific nature; their commercial availability; the fact that they are always primarily used for that production; and their essential character. As a first step, each of the net-zero technologies and, where necessary, sub-categories were further defined using the criteria listed above and in line with the definitions of those net-zero technologies in Regulation (EU) 2024/1735. As a second step, each sub-category was analysed to identify the components fulfilling the four criteria used. Components fulfilling those criteria were considered as primarily used for the production of net-zero technologies.

(6)An additional column ‘Final products’ should be added in the Annex to Regulation (EU) 2024/1735 for explanatory purposes. That additional column allows to put the elements in the list of primarily used components in context and therefore enhances the comprehensibility of the Annex.

(7)Regulation (EU) 2024/1735 should therefore be amended accordingly,

HAS ADOPTED THIS REGULATION:

Article 1

The Annex to Regulation (EU) 2024/1735 is replaced by the text in the Annex to this Regulation.

Article 2

This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 23.5.2025

For the Commission

The President
Ursula VON DER LEYEN

(1) Commission Staff Working Document – Assessment of net-zero technologies and their supply chains SWD 2025/932 [PO please complete the reference]

(2) OJ L, 2024/1735, 28.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1735/oj .

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ANNEX

List of final products and specific components considered to be primarily used for the production of net-zero technologies.

	Sub-categories of net-zero technologies	Final products	Components that are primarily used for net-zero technologies
Solar technologies	Photovoltaic (PV) technologies	-Solar PV systems	-PV grade polysilicon -PV grade silicon ingots or equivalent 1 -PV wafers or equivalent1 -PV cells or equivalent1 -Solar glass -PV encapsulants -PV ribbons -PV backsheets -PV connectors -PV junction boxes -PV modules -PV inverters -PV trackers and their mounting structures
	Solar thermal electric technologies	-Concentrated solar power (CSP) plants	-CSP reflectors -CSP trackers and their mounting structures -CSP receivers (point or line)
	Solar thermal technologies	-Solar thermal systems	-Solar thermal collectors (including flat-plate, evacuated tube, concentrating systems and air collectors) -Solar thermal absorbers -Solar glass -Solar thermal trackers and their mounting structures
	Other solar technologies	-PV-thermal collectors (PVT)
Onshore wind and offshore renewable technologies	Onshore wind technologies	-Onshore wind turbines	-Nacelles (assembly) -Yaw systems -Pitch systems -Rotor hubs -Main, yaw and pitch bearings -Yaw brakes -Rotor brakes -Direct drive drivetrains (including generator) and/or gearbox drivetrains (including generator) -Permanent magnets of wind turbines -Gearboxes of wind turbines -Blades -Towers
	Offshore wind technologies	-Offshore wind turbines	-Nacelles (assembly) -Yaw systems -Pitch systems -Rotor hubs -Main, yaw and pitch bearings -Yaw brakes -Rotor brakes -Direct drive drivetrains (including generator) and/or gearbox drivetrains (including generators) -Permanent magnets of wind turbines -Gearboxes of wind turbines -Blades -Towers -Foundations / floaters
	Other offshore renewable technologies	-Tidal stream energy technologies -Wave energy technologies
Battery and energy storage technologies	Battery technologies	-Batteries 2	-Battery packs -Battery modules -Battery cells -Cathode active materials -Anode active materials -Electrolytes -Separators -Binders -Current collectors (including thin copper, aluminium, nickel and carbon foils) -Battery management systems (BMS) -Battery thermal management systems (BTMS)
	Electrochemical storage technologies	-Ultracapacitors / supercapacitors -Redox flow energy storage	-Electrolytes -Separators -Collectors -Electrode plates
	Gravitational storage technologies	-Pumped hydro storage	-Reversible hydro turbines and pump runners -Distributors with guide vanes -Large hydro butterfly valves -Large hydro spherical valves -Large hydro hollow-jet discharge valves
	Thermal energy storage technologies	-Thermal energy storage systems	-Sensible heat storage and latent heat storage mediums (including phase-change materials and molten salts) -Thermochemical storage materials
	Compressed / liquefied gas energy storage technologies	-Compressed air energy storage -Liquid air energy storage
	Other energy storage technologies	-Flywheel energy storage	-Flywheel rotors
Heat pumps and geothermal energy technologies	Heat pump technologies	-Heat pumps	-Heat pumps -Four-way valves -Scroll compressors / heat pump rotary compressors
	Geothermal energy technologies	-Geothermal power plants -Geothermal direct use systems	-Heat exchangers resistant to geothermal corrosive operating conditions -Submersible pumps resistant to geothermal corrosive operating conditions -Brine re-injection pumps
Hydrogen technologies	Electrolysers	-Alkaline electrolysers (AEL)	-Stacks -Separators (diaphragm or membranes tailored for water electrolysis) -Bipolar plates and end plates -Electrodes -Electrocatalysts optimised for electrolysers -Frames and casing for electrolyser stacks assembly -Gaskets / sealants
		-Proton exchange membrane electrolysers (PEMEL)	-Stacks -Membrane electrode assemblies (3-layer) / catalyst-coated membranes -Porous transport layers / gas diffusion layers -Bipolar plates and end plates -Electrocatalysts optimised for electrolysers -Frames and casing for electrolyser stacks assembly -Gaskets / sealants
		-Anion exchange membrane electrolysers (AEMEL)	-Stacks -Membrane electrode assemblies (3-layer) / catalyst-coated membranes -Porous transport layers / gas diffusion layers -Bipolar plates and end plates -Electrocatalysts optimised for electrolysers -Gaskets / sealants -Frames and casing necessary for electrolyser stacks assembly
		-Solid-oxide electrolysers (SOEL)	-Stacks -Electrolytes and electrodes -High-temperature gaskets / sealings -Interconnectors /meshes and end plates -Electrocatalysts optimised for electrolysers -Contact layers -Frames and casing necessary for electrolyser stacks assembly
	Hydrogen fuel cells	-Proton exchange membrane fuel cells (PEMFC)	-Stacks -Membrane electrode assemblies (3‑layer) / catalyst-coated membranes -Porous transport layers / gas diffusion layers -Bipolar plates and end plates -Gaskets / sealants -Electrocatalysts optimised for fuel cells -Frames and casing necessary for fuel cell stacks assembly
		-Solid-oxide fuel cells (SOFC)	-Stacks -Electrolytes and electrodes -High-temperature gaskets / sealants -Interconnectors /meshes and end plates -Contact layers -Electrocatalysts optimised for fuel cells -Frames and casing necessary for fuel cell stacks assembly
	Other hydrogen technologies	-Hydrogen transmission and distribution networks	-Hydrogen compressors -Hydrogen refuelling stations -Pipelines for hydrogen transmission and distribution -Hydrogen sensors -Hydrogen valves
		-Hydrogen storage facilities	-Onboard hydrogen storage tanks -Hydrogen on-tank valves -Hydrogen stationary storage tanks
		-Plants for the conversion and extraction of hydrogen into and from ammonia	-Ammonia crackers
Sustainable biogas and biomethane technologies	Sustainable biogas technologies	-Sustainable biogas plants	-Anaerobic digesters / fermentation tanks -Enzymes and microorganisms for sustainable biogas production -Catalysts for sustainable biogas production
	Sustainable biomethane technologies	-Sustainable biomethane plants	-Anaerobic digesters / fermentation tanks -Enzymes and microorganisms for sustainable biomethane production -Biomethane upgrading units -Catalysts for sustainable biomethane production
CCS technologies	Carbon capture technologies	-Absorption capture -Adsorption capture -Membranes capture -Solid cycles capture -Cryogenics capture -Direct air capture	-Solvents optimised for carbon capture -Sorbents optimised for carbon capture -CO2 compressors
	Carbon storage technologies
Electricity grid technologies	Electricity grid technologies	-Onshore substations -Offshore substations	-Cables and lines for electricity transmission and distribution, and cables connecting net-zero technologies to the electricity grid (overhead lines, underground and undersea cables, including HVDC and HVAC) -Switchgears -Circuit breakers -Protection relays -Power transformers -Disconnectors -Insulators -Surge arrestors -Capacitors -Reactors -Busbar systems -Electric cabinets -Offshore substations -Inverters -Converters
		-Electricity transmission and distribution towers	-Electricity transmission and distribution towers -Electrical conductors (including advanced conductors and high-temperature superconductors) -Insulators -Surge arrestors -Busbar systems
		-Cables, lines, and associated accessories, for electricity transmission and distribution, and cables connecting net-zero technologies to the electricity grid (overhead lines, underground and undersea cables, including HVDC and HVAC)	-Cables and lines for electricity transmission and distribution, and cables connecting net-zero technologies to the electricity grid (overhead lines, underground and undersea cables, including HVDC and HVAC) -Cable accessories, including cable joints, cable terminations and connectors -Electrical conductors (including advanced conductors and high-temperature superconductors) -Insulators
		-Power transformers	-Power transformers -Transformer cores -Transformer windings -Transformer tap changers
	Electric charging technologies for transport	-Electric vehicle supply equipment -Electric road systems 3 -Shore-side electricity supply equipment -Overhead contact lines -Electric air transport supply equipment	-Electric vehicle supply equipment -Electric vehicle charging connectors -Shore-side electricity supply equipment -Electric air transport supply equipment -Electric air transport charging connectors
	Technologies to digitalise the grid and other electricity grid technologies	-High- and medium-voltage power electronics equipment and components (including DC technology) -Flexible alternating current transmission system (FACTS) technologies -Smart meters / advanced metering and control infrastructures	-High- and medium-voltage power electronics equipment and components (including DC technology) -Flexible alternating current transmission system (FACTS) technologies -Substation automation systems -Smart meters / advanced metering and control infrastructures
Nuclear fission energy technologies	Nuclear fission energy technologies	-Nuclear fission power plants	-Control rods and other neutron poison systems -Core catcher -Control rod drive mechanisms -Fuel elements -Reactor vessels -Reactor internals -Coolant/moderator and related purification systems -Pressurisers -Reactor coolant pumps / gas circulators -Primary piping and valves -Steam turbines -Steam generators -Nuclear heat exchangers -Secondary system components -Safety systems -Monitoring, instrumentation and control systems -Refuelling machines -Nuclear measurement and detection systems -Other components subject to the nuclear safety codes and standards
	Nuclear fuel cycle technologies	-Nuclear fuel cycles	-Centrifuges -Gas handling and flow control systems -Chemical processing equipment -Waste vitrification equipment -Transportation, storage and disposal cylinders, containers and casks -Heavy water -Safety systems -Monitoring, instrumentation and control systems -Other components subject to the nuclear safety codes and standards
Sustainable alternative fuels technologies	Sustainable alternative fuels technologies	-Sustainable alternative fuels plants	-Catalysts for sustainable alternative fuels production -Enzymes and microorganisms for sustainable alternative fuels production -Thermochemical, electrochemical, chemical, and biochemical / biological reactors to convert biomass, recycled carbon fuels into bio-intermediates and/or syngas -Reactors and post-treatment units to convert bio-intermediates and/or syngas and recycled carbon fuels into sustainable alternative fuels
Hydropower technologies	Hydropower technologies	-Hydro turbine systems	-Hydro turbine runners -Distributor with guide vanes -Large hydro butterfly valves -Large hydrospherical valves -Large hydro hollow-jet discharge valves
Other renewable energy technologies	Osmotic energy technologies
	Ambient energy technologies (other than heat pumps)
	Biomass technologies	-Pellet mills -Briquetting presses	-Pellet dies -Briquetting compaction chambers
	Landfill gas technologies
	Sewage treatment plant gas technologies
	Other renewable energy technologies
Energy system-related energy efficiency technologies	Energy system-related energy efficiency technologies	-Energy management systems (EMS) -Building automation systems (BAS) -Automated demand response (ADR) -Variable speed drives -Organic Rankine cycle (ORC) power systems	-EMS -BAS -ADR -Variable speed drives -ORC turbines
	Heat and cold grid technologies	-Heating and cooling distribution system pipework	-Pipe fitters and couplers
	Other energy system-related energy efficiency technologies
Renewable fuels of non-biological origin	Renewable fuels of non-biological origin (RFNBO) technologies	-RFNBO plants	-Reactors to convert H2 and CO2 or N2 into syngas or alcohols -Reactors to convert syngas or alcohols into RFNBO -Catalysts, enzymes and microorganisms for RFNBO production
Biotech climate and energy solutions	Biotech climate and energy solutions	-Microorganisms and microbial strains (including but not limited to bacteria, yeasts, microalgae, fungi, and archaea) that are used to pretreat and convert feedstock into biofuels, recycled carbon fuels and renewable fuels, bio-based and recycled carbon chemicals, biopolymers bio-based materials and bio-based products -Enzymes (including but not limited to amylase and cellulase) that are used to pretreat and convert feedstock into biofuels, bio-based chemicals, bio-based materials and bio-based products, or that are used to catalyse reactions in chemical processes -Biopolymers	-Microorganisms and microbial strains (including but not limited to bacteria, yeasts, microalgae, fungi, and archaea) that are used to pretreat and convert feedstock into biofuels, recycled carbon fuels and renewable fuels, bio-based and recycled carbon chemicals, biopolymers bio-based materials and bio-based products -Enzymes (including but not limited to amylase and cellulase) that are used to pretreat and convert feedstock into biofuels, bio-based chemicals, bio-based materials and bio-based products, or that are used to catalyse reactions in chemical processes -Biopolymers
Transformative industrial technologies for decarbonisation	Transformative industrial technologies for decarbonisation	-Electric arc furnaces -Hydrogen-ready direct-reduced iron reactors -Submerged arc furnaces -Open slag bath furnaces -Flash calciners -Industrial electric boilers -Industrial induction heaters / furnaces 4 -Industrial infrared heaters / furnaces -Industrial microwave heaters / furnaces -Industrial radio-wave heaters / furnaces -Industrial resistive heaters / furnaces	-Graphite or carbon electrodes for electric furnaces -Flash calciners -Industrial electric boilers -Industrial induction heaters / furnaces -Industrial induction coils -Industrial infrared heaters / furnaces -Industrial infrared emitters -Industrial microwave heaters / furnaces -Industrial magnetrons -Industrial radio-wave heaters / furnaces -Radio frequency generators -Industrial resistive heaters / furnaces -Molybdenum electrodes for electric furnaces
CO2 transport and utilisation technologies	CO2 transport technologies	-CO2 transport infrastructure	-CO2 compressors
	CO2 utilisation technologies	-Thermochemical utilisation -Electrochemical utilisation	-Catalysts tailored for CO2 conversion processes -CO2 electrolysers
Wind and electric propulsion technologies for transport	Wind propulsion technologies	-Flettner rotors -Suction wing sails -Towing kites -Rigid and semi-rigid wing sails
	Electric propulsion technologies	-Electric propulsion systems for road and off-road transport -Electric propulsion systems for rail transport -Electric propulsion systems for waterborne transport -Electric propulsion systems for air transport	-Transport propulsion electric motors -Permanent magnets of transport electric motors -Transport battery packs -Transport fuel cells -Transport inverters -Electric propulsion high voltage power distribution units -Onboard chargers -Charge ports -Onboard hydrogen storages tanks -Current collectors (including pantographs)
Other nuclear technologies	Other nuclear technologies (such as nuclear fusion technologies)

(1) The term ‘equivalent’ refers to similar steps or key enabling technologies needed for thin-film, organic, tandem or other PV technologies.

(2) Batteries as defined in Article 3(13), (14) and (15) of Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries.

(3) The term ‘electric road system’ (also known as dynamic charging) refers to equipment along the road that supplies power to vehicles while they are in motion. That final product includes both conductive and inductive charging.

(4) The term ‘heater’ refers to low (up to 200 °C) and medium (200 to 500 °C) temperature applications. The term ‘furnace’ refers to high (500 to 1 000 °C) and very high (above 1 000 °C) temperature applications.

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