Low Carbon Solar
State of Sustainability ResearchPrepared for the Global Electronics Council in support of EPEAT criteria development
Report prepared by: Anthesis LLC

Date: April 1, 2021

Disclaimer
Anthesis LLC has exercised due and customary care in preparing this report but has not, save as specificallystated, independently verified information provided by others. No other warranty, express or implied, is madein relation to the contents of this report. The use of this report, or reliance on its content, by unauthorised
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Low Carbon Solar
State of Sustainability ResearchPrepared for:Prepared by:

Ultra Low Carbon Solar Alliance

Anthesis LLC

Michael Parr

Jim Fava

Executive Director

Executive Director

mparr@ultralowcarbonsolar.org

jim.fava@anthesisgroup.com

Dawn Rittenhouse

John Heckman

Project Manager

Executive Director

drittenhouse@hillstaffer.com

john.heckman@anthesisgroup.com

Global Electronics Council

Skye Lei

Patricia Dillon

Principal Consultant

Senior Director

skye.lei@anthesisgroup.com

pdillon@globalelectronicscouncil.org
Nancy Gillis
Chief Executive Officer
ngillis@globalelectronicscouncil.org

Websites:
https://ultralowcarbonsolar.org/
https://globalelectronicscouncil.org/

https://www.anthesisgroup.com/us/

Table of contents
Disclaimer ......................................................................................................................................................... 2
Table of contents ................................................................................................................................................. 4
Table of figures .................................................................................................................................................... 5
Abbreviations ....................................................................................................................................................... 6
Executive Summary.............................................................................................................................................. 7
Acknowledgements.............................................................................................................................................. 7
Introduction ......................................................................................................................................................... 8
What is Ultra Low-Carbon Solar & Why is it Important? .................................................................................. 8
Upstream Embodied Carbon ............................................................................................................................ 9Market Signals ................................................................................................................................................ 10
Background on Solar Module Technologies ....................................................................................................... 12
Photovoltaic Module Production Processes ................................................................................................... 13
Photovoltaic Module Life Cycle Data Availability ........................................................................................... 13
Enabling Procurement of Ultra Low Carbon Solar ............................................................................................. 14
Certification Pathways.................................................................................................................................... 15
Roles of GEC and EPEAT ................................................................................................................................. 15
Path Forward ..................................................................................................................................................... 16
Criteria Development Process ........................................................................................................................ 16
Voluntary Consensus Process Principles ........................................................................................................ 17
Appendix 1: Applicable Standards, Labels and Voluntary Agreements ............................................................. 18
Appendix 2. Comparison of existing LCA and EPD standards and guidelines applicable to solar photovoltaics. 19

Table of figures
Figure 1. Global Solar PV Installed Capacity 2000-2020 (Source: Our World in Data, Global Change Data) .......................... 9
Figure 2 World Solar PV Gross Additions (Source: DNV-GL, 2020) ............................................................................................. 9
Figure 3. Life Cycle Greenhouse Gas Emissions from Solar Photovoltaics (Source: NREL) ................................................... 10
Figure 4 Carbon footprint of different PV systems indicating the solar module carbon emission dominance. Balance ofsystem (BOS) includes typically includes inverters, mounting structures, cable and connectors 8 ......................................... 12
Figure 5 Expected ULCS Certification Pathways ........................................................................................................................ 15
Figure 6 Expected Process for ULCS Designation Creation ....................................................................................................... 16

Abbreviations
CdTe

Cadmium-telluride

CIS / CIGS

Copper-indium-selenide / Copper-indium-gallium-selenide

c-Si

Crystalline silicon

DU

Declared unit

EAC

Energy Attribute Certificate

EPD

Environmental product declaration

ESL

Estimated service life

FU

Functional unit

HJT

Heterojunction technology

ISOInternational Organization for Standardization

LCA

Life cycle assessment

LCI

Life cycle inventory

LCIA

Life cycle impact assessment

micro-Si

Micromorphous siliconmono-Si

Monocrystalline silicon

multi-Si

Multicrystalline silicon

PCR

Product category rules

PV

Photovoltaic

RSL

Reference service life

Si

Silicon

SoG-SiSolar grade silicon

SOSR

State of Sustainability Research

VCP

Voluntary Consensus Process

Wp

Watt peakExecutive Summary
The purpose of this State of Sustainability Research (SOSR) is to provide information on the
background, applicable previous work, likely requirements, and initial concepts for establishing an
Ultra-Low Carbon Solar designation (ULCS). The SOSR is intended to form the foundation for thedevelopment of criteria on ULCS for the EPEAT ecolabel, which is managed by the Global Electronics
Council. The desired outcome of this process is to enable procurers of solar PV modules to specify low
embodied carbon based on a life cycle assessment (LCA) framework and implemented in a mannerthat establishes confidence. The SOSR provides background information on the manufacturing
processes associated with the dominant solar PV technologies, past work about solar PV module
manufacturing carbon intensity, and a survey of voluntary standards and other references that are
intended to be incorporated into the ULCS criteria development process.

Acknowledgements
This paper greatly benefited from the expert guidance and editorial input from several key
representatives of the following organizations:
1366 Technologies
First Solar
Global Electronics Council
Hanwha Q CELLS Co. Ltd
Hemlock Semiconductor Operations, LLC
Meyer Burger
Michigan State University
NorSun SA
Norwegian Crystals
REC Group
REC Silicon ASA
Ultra-Low Carbon Solar Alliance
U.S. Environmental Protection Agency
U.S. National Renewable Energy Laboratory
Wacker Chemie AG

7

Introduction
The Global Electronics Council (GEC) proposes the development of criteria to identify low embodied
carbon solar photovoltaic (PV) products that will be eligible for an Ultra-Low-Carbon Solar (ULCS)
designation through the EPEAT ecolabel.
The purpose of this State of Sustainability Research (SOSR) is to provide background on embodied
carbon in PV products and manufacturing processes, market drivers for low embodied carbon, andinitial concepts for establishing the designation. The SOSR is intended to form the foundation for thedrafting of ULCS criteria and a transparent designation for ULCS products. The desired outcome of thisprocess is to distinguish solar modules with low embodied carbon based on a life cycle assessment(LCA) -informed framework and implemented in a manner that establishes confidence.
The Ultra Low Carbon-Solar Alliance shares GEC’s goal of using market preferences to encourage
supply chain decarbonization and looks forward to collaborating on this effort.

What is Ultra Low-Carbon Solar & Why is it Important?
Decarbonization of electricity generation is one of the most important efforts to prevent the worst
consequences of global climate change. Fossil fuel-based electricity generation is a primary source ofgreenhouse gasses (GHGs), with solar PV being one of the most important replacements for fossilbased power. The global solar PV market has been growing rapidly to address this issue and to meetthe increasing demand for green power. Solar generating capacity has grown nearly 2500% globally
since 2000, and it was estimated to reach 774 GW cumulatively by the end of 2020 (Figure 1)1. Since
2015, solar represents more than two-thirds of all electrical capacity additions by the private sector in
the US2.
Annual additions of solar PV are expected to triple by 2030 and continue to increase (Figure 2)3. In
response to this expansion, buyers of solar modules are concerned with the upstream or embodied
carbon related to the manufacture of PV modules. Differences in PV supply chain emissions can havea substantial impact on the greenhouse gas emissions avoided by solar projects. The use of materials
with lower embodied carbon and energy efficient manufacturing process in PV modules can reduce
the life cycle carbon footprint of solar systems by 40 percent or more4. The reduction is primarily
dependent on the carbon intensity of the electricity grid powering the production process of wheremodule components are produced. As an illustrative example, in comparison to manufacturing on a
predominately coal-fired energy grid (i.e., 65% coal), polycrystalline Silicon solar PV manufactured on
an average North American grid can potentially help to avoid more than 1 billion metric tons of supply
chain emissions cumulatively over the next 10 years (2021-2030) of projected solar PV deployment. 5

1 Hannah Ritchie and Max Roser (2020) - "Renewable Energy". Published online at OurWorldInData.org. Retrieved from:'https://ourworldindata.org/renewable-energy' [Online Resource]
2 SEIA/Wood Mackenzie Power & Renewables U.S. Solar Market Insight 2020 Q4, https://www.seia.org/smi
3 DNV-GL, Energy Transition Outlook 2020, https://eto.dnv.com/2020/index.html
4 Dajun Yue, Fengqi You and Seth B.Darling (2014). “Domestic and overseas manufacturing scenarios of silicon-based

photovoltaics: Life cycle energy and environmental comparative analysis.” Argonne National Laboratory and Northwestern
University. Solar Energy, Volume 107, September 2014, Pages 380.
5 Dr. Annick Anctil, Michigan State, unpublished research, updating Yue, You and Darling 2014 study resulting in reduction oflife cycle savings from ~ 50% to ~41%.
8

Upstream Embodied Carbon
A solar PV module produces no direct greenhouse gases during its operation; however, solar PV does
not have a zero-carbon footprint over its entire life cycle. When accounting for indirect emissions
upstream and downstream of the module operation, life cycle greenhouse gas emissions are
dominated by upstream raw materials and manufacturing emissions, and to a lesser extent end-of-lifeemission related to decommissioning and materials management. The upstream greenhouse gas
emissions of a solar PV power plant, also known as “embodied carbon,” represent nearly 60-70% of
the total life cycle footprint of the solar modules (Figure 3)6. This carbon intensity is inherent in themodule’s raw materials and underlying manufacturing processes. For instance, solar grade polysiliconrequires energy intensive processing and purification to reach the performance requirements
demanded for solar PV applications. Life cycle assessments estimate that PV modules made withenergy from high carbon resources can have nearly twice the embodied carbon as modules producedwith lower carbon resources7 8 9.

Figure 1. Global Solar PV Installed
Capacity 2000-2020 (Source: Our World in
Data, Global Change Data)

Figure 2 World Solar PV Gross Additions(Source: DNV-GL, 2020)

6 National Renewable Energy Laboratory (2012). “Life Cycle Greenhouse Gas Emissions from Solar Photovoltaics”. NREL/FS-

6A20-56487. November 2012.
7 Fthenakis, V., und M. Raugei (2017). “Environmental life-cycle assessment of photovoltaic systems“, 2017, 209–32.

https://doi.org/10.1016/B978-1-78242-336-2.00007-0.
8 Leccisi, Enrica, Marco Raugei, und Vasilis Fthenakis (2016). “The Energy and Environmental Performance of Ground-

Mounted Photovoltaic Systems—A Timely Update“. Energies 9, Nr. 8 (8. August 2016): 622.
https://doi.org/10.3390/en9080622.
9 Louwen, Atse, Ruud E.I. Schropp, Wilfried G.J.H.M. van Sark, und André P.C. Faaij. “Geospatial Analysis of the Energy Yield

and Environmental Footprint of Different Photovoltaic Module Technologies“. Solar Energy 155 (Oktober 2017): 1339–53.
https://doi.org/10.1016/j.solener.2017.07.056.
9

Figure 3. Life Cycle Greenhouse Gas Emissions from Solar Photovoltaics (Source: NREL)

Market Signals
The growing solar PV market is already indicating the importance of reducing embodied carbon, as
illustrated by the following examples of relevant market activity.
•

France has pioneered the method for understanding embodied carbon of solar modules,
incorporating two pathways of LCA estimates in the French procurement tenders
beginning in 2016. The French tenders provide a simplified methodology as well as avalidated methodology for solar module makers to specify the embodied carbon of theirmodules.

•

Korea is piloting a procurement tender system, similar to the French system, to prioritize
projects utilizing solar PV modules with a low carbon footprint 10.

•

Companies are making substantial commitments requiring more ambitious reduction in
GHG emissions along their value chains. Toyota has pledged half their sales from EVs by2025 and GM has said most of their models will be EV by 2030. PepsiCo plans to reduce
absolute GHG emissions across its indirect value chain (Scope 3) by 40% by 2030.

•

Investors are stepping up their expectations. For example, Blackrock Inc. has clearlycommunicated its expectation of Science Based Targets and Net Zero commitments11 forits portfolio companies. Top asset managers including BlackRock and Vanguard Group Inc
have joined an investor push to limit greenhouse gas emissions to Net Zero by 2050.

10 Bellini, Emilliano (2021). “South Korea may tender 4 GW of solar PV this year”. PV Magazine. 12 January 2021. Retrieved

from: https://www.pv-magazine.com/2021/01/12/south-korea-may-tender-4-gw-of-solar-pv-this-year/
11 BlackRock (2021). “Larry Fink's 2021 letter to CEOs”. Retrieved from: https://www.blackrock.com/corporate/investor-

relations/larry-fink-ceo-letter [Online Resource]
10

Signatories to the Net Zero Asset Managers Initiative12 commit to press companies intheir portfolios to achieve net zero emissions by 2050 or sooner.
•

Large corporate buyers of solar PV are looking to make the most positive impact fromtheir procurement efforts. As an example, one of the key insights from a recent analysis
published by Salesforce13 indicates that the emissions reduction of a potential renewableenergy project can change dramatically based on its grid location and production profile.
For example, it was estimated that a West Virginia-based solar project would avoid
almost 3x the emissions than that of a California-based solar project. To maximize theemissions potential of a new renewable investment, buyers should compare different
projects’ avoided emissions rates and leverage this information to select projects in gridregions that cause the greatest avoided emissions.

•International product category rules (PCR) have been developed in Norway14 and Italy15,
providing guidelines for the development of environmental product declarations (EPD)
for a photovoltaic module, cell, wafer, ingot block or solar grade silicon, either cradle togate with options or cradle to grave for a photovoltaic module. In doing so it further
specifies underlying requirements of the life cycle assessment (LCA). There is also a
generic PCR under the French PEP Ecopassport system16, which can also be applied to PV
modules.

•

The European Union is evaluating the viability of a new policy option to mandate
disclosure requirement for the carbon footprint of PV modules and inverters in the EU
Eco-Design, Energy & Eco-Labelling – potentially followed by Green Public Procurement(GPP) recommendations for other public tenders in the EU17.

•

In the United States, the Federal Acquisition Regulation (FAR) subpart 23.704 requiresthat 95% of all electronic product acquisitions be EPEAT-registered products18.

12 https://www.netzeroassetmanagers.org/
13 Lorenzen, Megan, Max Scher, Erica Brand, Patty Dillon, Lily Donge, Pasha Feinberg, Sarah Freiermuth, u. a. “More Than a

Megawatt: Embedding Social & Environmental Impact in the Renewable Energy Procurement Process“. Salesforce White
Paper. San Francisco, CA, USA: 2020.
https://c1.sfdcstatic.com/content/dam/web/en_us/www/assets/pdf/sustainability/sustainability-more-than-megawatt.pdf.
14 The Norwegian EPD Foundation (2020). “PCR – Part B for photovoltaic modules used in the building and constructionindustry, including production of cell, wafer, ingot block and solar grade silicon”. Product Category Rules. EN 15804: NPCR
029 Version 1.0. 11 June 2020.
15 EPD Italy. “PCR for PV Module”. EPDItaly 014 – rel. 1. 03 February 2020. Retrieved from:https://www.epditaly.it/en/pcr_/pcr-for-pv-module-epditaly-014/
16 PEP EcoPassport (2015). “Product Category Rules for Electrical, Electronic and HVAC-R Products”. PEP-PCR-ed3-EN-2015 04

02. P.E.P. Association. 02 April 2015.
17 Dodd, N. and Espinosa Martinez, M.D.L.N., Solar photovoltaic modules, inverters and systems: options and feasibility of EU

Ecolabel and Green Public Procurement criteria, Preliminary report, EUR 30474 EN, Publications Office of the European
Union, Luxembourg, 2021, ISBN 978-92-76-26819-2 (online), doi:10.2760/29743 (online), JRC122430. Retrieved from:https://ec.europa.eu/jrc/en/publication/solar-photovoltaic-modules-inverters-and-systems-options-and-feasibility-euecolabel-and-green
18 Federal Acquisition Regulation (2021). “Part 23 - Environment, Energy and Water Efficiency, Renewable Energy

Technologies, Occupational Safety, and Drug-Free Workplace”. FAC Number/Effective Date: 2021-03/2-16-2021- Download
Entire FAR. Retrieved from: https://www.acquisition.gov/far/part-23
11

Recognizing the current U.S. administration’s position19 on climate change and renewableenergy goals, the ULCS criteria will further enable the US government procurement of
low-embodied carbon solar PV.
•

Additionally, U.S. state government agencies are also shifting towards low embodied
carbon materials in general. For example, the California Department of General Services(DGS) requires that construction materials purchased with state funding comply with The
Buy Clean California Act (BCCA) to reduce the carbon emissions associated with the
production of structural steel, concrete reinforcing steel, flat glass, and mineral wool
board insulation. These materials must have a Global Warming Potential that does notexceed the limit set by DGS.

Background on Solar Module Technologies
Photovoltaic systems are made up of several components
including the solar modules, the frames and othermounting equipment, electrical connectors, and solar
inverters. The majority of CO2e emissions are frommodule manufacturing, thus the production of modules
will be the focus of this initial ULCS criteria development
effort (Figure 4). Additional components of the PV system
supply chain may be considered in future expansions of
this low carbon solar effort.
Solar modules are the focus of substantial basic andapplied research, resulting in an abundance of
established and novel technologies. For this effort, two
primary module technologies will be the focus:•

Crystalline silicon-based PV, including monoand multi-crystalline silicon•Thin-film PV based on Cadmium telluride (CdTe)

Figure 4 Carbon footprint of different PV systems indicating
the solar module carbon emission dominance. Balance ofsystem (BOS) includes typically includes inverters, mounting
structures, cable and connectors8

Other PV technologies, including heterojunction technology (HJT), copper indium gallium disselenide(CIGS) solar cells20 and tandem solar cells21, may be considered in future efforts. However, they are
not the focus of the current ULCS criteria development.

19 The White House. “Executive Order on Tackling the Climate Crisis at Home and Abroad”. Retrieved March 31, 2020 fromhttps://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/27/executive-order-on-tackling-the-climate-crisisat-home-and-abroad/
20 Mansfield, Lorelle (2021). “Copper Indium Gallium Diselenide Solar Cells.” National Renewable Energy Laboratory.

Photovoltaic Research: Materials Science. Retrieved February 28, 2021 from https://www.nrel.gov/pv/copper-indiumgallium-diselenide-solar-cells.html.
21 Helmholtz-Zentrum Berlin für Materialien und Energie. (2020, April 14). Tandem solar cell world record. ScienceDaily.

Retrieved February 28, 2021 from www.sciencedaily.com/releases/2020/04/200414122758.htm.
12

Photovoltaic Module Production Processes
Crystalline Silicon Modules
Crystalline silicon is the predominant technology in global PV deployment, with the Fraunhofer
Institute reporting that 95% of the PV modules produced in 2017 were crystalline silicon, such thatthe assessment reflects most global PV installations22. As per IEA PVPS Task 1223, the following
production processes are the most important elements in the production of crystalline-Si modules:
1. Metallurgical-grade Silicon production
2. Solar-grade Silicon production
3. Mono- or multi-crystalline Ingot/block production
4. Silicon wafer production
5. Photovoltaic cell production
6. Module production, including glass, laminate, and frameThin Film Modules
Thin film modules using CdTe technology are the second most common form of photovoltaic module
available on the market currently.24 They have a simpler and more resource efficient manufacturing
process in comparison to Silicon-based modules. As per ULCSA25, the primary production processcomponents for CdTe thin-film include the following:
1. Glass manufacturing
2. Semiconductor deposition
3. Cell definition
4. Module production, including glass, laminate, and frame
Because of the integrated nature of thin-film module production, these four processes can beconsidered together as a single unit-process.

Photovoltaic Module Life Cycle Data Availability
The life cycle global warming potential of crystalline silicon module is largely determined by the solargrade silicon & ingot production, due to the energy intensity of the process and the respective supply
chain of electricity8. The most recent LCA data available for solar PV module production has recently

22 Fraunhofer ISE (2020). “Photovoltaics Report”. Freiburg, Germany. 16 September 2020.
23 R. Frischknecht, P. Stolz, L. Krebs, M. de Wild-Scholten, P. Sinha, V. Fthenakis, H. C. Kim, M. Raugei, M. Stucki, 2020, “Life

Cycle Inventories and Life Cycle Assessment of Photovoltaic Systems”, International Energy Agency (IEA) PVPS Task 12, Report
T12-19:2020.
24 Department of Energy (2021). Cadmium Telluride. Office of Energy Efficiency & Renewable Energy. Retrieved from:https://www.energy.gov/eere/solar/cadmium-telluride. February 28, 2021. [Online Resource]
25 Ultra Low-Carbon Solar Alliance (2021). “Thin Film PV Supply Chain”. Retrieved from:https://ultralowcarbonsolar.org/ultra-low-carbon-solar/. February 28, 2021. [Online Resource]
13

been compiled by IEA PVPS Task 12, providing an opportunity to use the report as one of thefoundations of the ULCS criteria23. Key components of this report include:•

Unit process LCI data for crystalline Silicon and Thin Film PV modules•

Electricity consumption on all process levels with specific electricity mixes by region•

Supply chains of the regions modelled based on the market shares by region•

Other inputs and outputs related to material, energy, and environmental efficiencies ofthe production in the different world regions

Enabling Procurement of Ultra Low Carbon Solar
The desired outcome of this process is an ULCS designation that distinguish solar modules with low
embodied carbon based upon life cycle assessment (LCA) framework, which can be used withinprocurement processes to specify buying of ULCS modules. The ULCS designation will be based uponcriteria and approaches from existing life cycle studies, standards, and regulatory approaches. See the
Appendix 1 for a listing of all applicable standards, labels and voluntary agreements expected to beconsidered as part of ULCS designation development.
Several factors will be considered throughout the criteria development process, including but notlimited to the following:•

The suitability of the unit processes within the IEA PVPS Task 12 LCI to form the basis of
an ULCS designation•

The importance of specific process flows, e.g. recycling rates, for reusing internal
manufacturing waste.

•

The appropriate level of geographic or process resolution for energy grid mix emission
factors•

Usability on a global scale•Comparability of the information provided by multiple bidders as part of a procurement
processes.

•

Application of Energy Attribute Certificates (EAC) as renewable energy credits•

Companies ranging in size from small to large, and ones with different levels of
understanding and experience with broader environmental issues.

•

Verification that procured PV modules are conforming with modelled CO2e datao•Specifically, the method to verify accuracy of energy input carbon intensity and othercritical life cycle flow assumptions such as recycled content

The degree of connectivity of the ULCS designation with the EPEAT NSF/ANSI 457 – 2019
Sustainability Leadership Standard for Photovoltaic Modules and Photovoltaic Inverters

14

Certification Pathways
The expectation is to establish two pathways for manufacturers and suppliers to certify their PV
modules using LCA modelling results made in alignment with ISO 14040/4 and supporting standards(Figure 5). The two pathways will be developed in parallel following similar process maps and systemboundaries. The pathways will be modelled after the French government procurement regulations tooffer the following:•

Path A – Fast track that leverages standardized life cycle carbon footprint values (i.e.,
secondary data) pre-determined by countries and by unit processes and likely verified byaccredited processes to confirm origin of components•

Path B – Validated track that calculates life cycle carbon footprint based primarily on
primary data as per ISO 14040, 14044 and 14067, and reported by the manufacturer or
supplier of the PV module, including associated appropriate verification processes.

While Path B provides more flexibility to use manufacturer or supplier-specific data than Path A, italso requires third-party validated adherence to LCA standards to ensure accuracy and credibility.
Several standards already exist for LCA and EPDs for building products and specific to PV modules (seeAppendix 2 for summary and comparative information for useful and applicable standards). These will
be reviewed and evaluated with consideration of parameters that significantly affect the PV module
carbon footprint and its interpretation, such as functional unit and system boundary, production
electricity mix, recycled content, and benchmark.

Figure 5 Expected ULCS Certification Pathways

Roles of GEC and EPEATThe EPEAT ecolabel operated by the Global Electronics Council (GEC) has been identified as a suitable
platform for ULCS criteria implementation. EPEAT recently launched a Photovoltaic Modules andInverters category based on criteria in NSF/ANSI 457 – 2019 Sustainability Leadership Standard for
Photovoltaic Modules and Photovoltaic Inverters (PVMI). The existing EPEAT platform is currently
used to enable the certification and procurement of sustainable electronic products from multiple
buyers including governmental agencies and large corporations. The combination of EPEAT’s strong
position in the marketplace and existing photovoltaic category for sustainable products make it agood candidate to support the ULCS designation.
15

Path Forward
Criteria Development Process
It is expected that the ULCS criteria development and implementation process will comprise of several
key milestone represented in Figure 6. The criteria drafting and finalization process is expected totake place from April 2021 through Fall 2021. An Expert Ad Hoc Group will be formed to support thecriteria drafting process, consisting of manufacturers, suppliers, academia, government entities, andnon-profit organizations. Once the full draft criteria are complete and ready for review, it will be
submitted to a broader multi-stakeholder Technical Committee for review and agreement via a
Voluntary Consensus Process adopted by GEC. At this point, the criteria will be made available for a
30-day public consultation period anticipated to occur in Fall 2021.

Figure 6 Expected Process for ULCS Designation Creation16

Voluntary Consensus Process Principles
Following the criteria development process, there will be a multi-stakeholder Technical Committee
involved in the review of the ULCS criteria. The multi-stakeholder Technical Committee will follow the
VCP adopted by GEC, adhering to the following principles:

Openness

The process is open to participation by interested parties. Such parties areprovided meaningful opportunities to participate in criteria development on a
non-discriminatory basis. The procedures or processes for participating in criteria
development and for developing the criteria are transparent.

Balance ofInterests

The process includes a balance of stakeholders such as manufacturers, suppliers,
policy representatives, purchasers, and environmental and social impact experts.
Balance means that no single interest type shall comprise more than one third of
the consensus body. Processes that fail to achieve or maintain such balance must
provide acceptable evidence that they have undertaken special effort to do so andmust have included at least some representation of each stakeholder type.

Due Process

The process must include documented and publicly available policies andprocedures, adequate notice of meetings and other activities, sufficient time toreview drafts and prepare views and objections, access to views and objections ofother participants, and a fair and impartial process for resolving conflicting views.

Appeals
Process

A process must be available for the impartial handling of procedural appeals.

Consensus

Consensus is defined as general agreement, but not necessarily unanimity, andincludes a process for attempting to resolve objections by interested parties. Allcomments must be fairly considered, each objector must be advised of thedisposition of his or her objection(s) and the reasons why, and the consensus bodymembers must be given an opportunity to change their opinion after reviewing
the comments.

17Appendix 1: Applicable Standards, Labels and Voluntary Agreements
Life Cycle Assessments (LCA) guidance has also been developed – both broadly, and more focused on
PV systems:•

ISO 14067 Greenhouse gases — Carbon footprint of products•

ISO 14040/44 Environmental management — Life cycle assessment•

IEA PVPS Task 12 — Life Cycle Inventories and Life Cycle Assessments of Photovoltaic Systems•

IEA PVPS Methodology — Guidelines on Life Cycle Assessment of Photovoltaic Electricity

There are a number of labels and voluntary agreements that have been developed globally. A few ofthe more recognized are:•

NSF 457 — Sustainability Leadership Standard for Photovoltaic Modules and Photovoltaic
Inverters•

EPEAT Ecolabel — Based on NSF 457

On a broader perspective, there are a number of systems that provide guidance for development of
Product Category Rules.
•

PEFCR — Products Environmental Footprint Category Rules•

PCR EPD Norway – The Norwegian EPD Foundation search database•

EPD Italy — PCR for PV Panel: EPDItaly 014 – rel. 1•

UL PCR — Verify Environmental Product Declarations by using existing PCRs created by otherprogram operators•

European PCR — The International EPD System search database•

PCR for PV Module — PCR for PV Panel: EPDItaly 014 – rel. 1•

GHG Protocol Product Standard – Product Life Cycle Accounting and Reporting Standard toevaluate full lifecycle GHG emissions of a product•

PEP Ecopassport PCR — PEP is an environmental identity card•

IEC TR 62726:2014 Ed. 1.0 – Guidance on quantifying greenhouse gas emission reductions

18

Appendix 2. Comparison of existing LCA and EPD standards and guidelines applicable to solar photovoltaics.
PEFCRaFrenchtenderb

EN
15804cNorwayPCRd

IEA PVPS Task 12e

EPEAT/NSF
457f

UL PCRg

ISO 14067h

Italy PCRi

Korea
tenderj

Functional unit

kWh DC

kWp

-

Wp

kWh

kWh

-

-

kWh

kWp

Reference flow

-

-

-

kWp

kWp

-

-

-

-

System boundary

kWp
Roofmounted PV
systemexcludinginverter andAC cabling

PV module
excludingframe-

PV module

PV system (roof residential, roof
commercial and ground mountutility scale)PV system-

PV system

PV module
includingframeLife cycle stages

Cradle tograve

Cradle togate

Cradleto grave

Cradle tograve

Cradle to grave

Cradle tograve

Cradle to grave

Cradle to grave

Cradle togate

Ecoinvent

EcoinventLCI DB ver
3.5

Can be supplierspecific andrequires guaranteeof origin or onsite
generation or directconnection to
generator

National mix,
national residual
mix, or supplierspecific withguarantee of origin
or residual mix

IEA
Electricity
information 2018:World
grosselectricity,
by source

All transport

All transport-

Rules provided

Rules provided-

Background data

EFcompliant

Production electricity
mix

Can besupplierspecific andrequiresguarantee oforigin or
onsitegeneration

Transport data

All Transport

Data quality

Rules
provided

EcoinventNational mix
Transport toproduction
facility

-

-

Rules
provided
Rules
providedEcoinvent

Ecoinvent, Gabi,othersEcoinventNationalmix

The electricity consumption on allprocess levels is modelled withspecific electricity mixes
corresponding to these world
regions (Europe, China, Americas,
APAC)

All
Transport

All transport

Rules
providedunit process data provided in LCI
reportCradle togate or
Cradle tograve

Refers to
PEFCR or IEAPVPS Task 12

Regionalor
nationalmix.
Supplierspecificmix withguarante
e oforigincan bereported
separately.
Alltransport
Rules
provided-

19

PEFCRa

Frenchtenderb

Allocation

Rules
provided-

Recycled content

Rules
providedMax 25-34%

Reporting

Rules
provided

By
component

Impact Categories

Verification

ILCD

Yes

GWP100

Yes for
Method 2

EN15804cRules
providedFollows
allocation rules
Rules
provide
d

ILCD

Yes

NorwayPCRd

IEA PVPS Task 12e

Rules
provided
Follows
allocation
rules

unit process data provided in LCI
reportBy
component

ILCD

Yes

EPEAT/NSF
457f

UL PCRg
Rules
provided
Rules
providedunit process data provided in LCI
reportRules
provided

Rules provided

ISO 14067h

Italy PCRi

Korea
tenderj

Rules provided

Rules provided-

Follows allocation
rules

Follows allocation
rules

-

Rules provided

Rules provided

By
component

ILCD

ILCD, Traci,
CML, or LIME

Traci,
CML,
others

IPCC GWP-100

IPCC (2013) GWP100

GWP100(IPCC 2007)-

Yes or peerreviewed
journalpublication

Yes

Optional

Yes

Yes for
Method 2

Rules provided

Rules provided<670 to>830 kg
CO2eq/kWp

-

SVHC

-

BenchmarkRepresentati
ve product50-1150 kg
CO2-eq/kWp

-

-

-

Representativ
e product

Chemical content

-

-

SVHC

IEC 62474-

SVHC and IEC
62474

Rules
provided
SVHC
and
other
countryspecific(Table 4)

Notes:
a - https://ec.europa.eu/environment/eussd/smgp/ef_pilots.htm "Product Environmental Footprint Category Rules (PEFCR) PHOTOVOLTAIC MODULES USED IN PHOTOVOLTAIC POWER SYSTEMS FOR ELECTRICITY
GENERATION Version 1.1"
b - https://www.cre.fr/ "Cahier des charges de l’appel d’offres portant sur la réalisation et l’exploitation d’Installations de production d’électricité à partir de l’énergie solaire « Centrales au sol »", Annexe 2
c - https://standards.cen.eu/dyn/www/f?p=204:110:0::::FSP_PROJECT,FSP_ORG_ID:70014,481830&cs=1538D502078F136C61227E09322AB3FD9d - https://www.epd-norge.no/getfile.php/1313823-1591956540/PCRer/NPCR%20029%202020%20Part%20B%20for%20photovoltaic%20modules%20final%20version%20approved%20110620.pdf
e - https://iea-pvps.org/key-topics/task-12-methodology-guidelines-on-life-cycle-assessment-of-photovoltaic-electricity-3rd-edition/20

f - https://www.techstreet.com/standards/nsf-ansi-457-2019?product_id=2091842
g - https://www.ul.com/offerings/product-category-rules-pcrs
h - https://www.iso.org/standard/71206.html
i - https://www.epditaly.it/en/pcr_/pcr-for-pv-module-epditaly-014/
j - https://www.knrec.or.kr

21