Source: EURLEX
Language: en
Format: md

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| European flag | Official Journal  of the European Union | EN  C series |

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|  | C/2025/3236 | 18.6.2025 |

COMMUNICATION FROM THE COMMISSION

providing updated information to determine the shares of the European Union supply of final products and their main specific components originating in different third countries under Regulation (EU) 2024/1735 on establishing a framework of measures for strengthening Europe’s net-zero technology manufacturing ecosystem (Net-Zero Industry Act)

(C/2025/3236)

TABLE OF CONTENTS

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| --- | --- | --- |
| I. | INTRODUCTION | 2 |

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| --- | --- | --- |
| II. | SHARES OF THE UNION SUPPLY ORIGINATING IN DIFFERENT THIRD COUNTRIES | 3 |

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| --- | --- | --- |
| III. | SHARES OF THE UNION SUPPLY ORIGINATING IN ALL THIRD COUNTRIES | 6 |

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| --- | --- | --- |
| IV. | METHODOLOGY FOR EVALUATING THE SHARES OF THE UNION SUPPLY | 9 |

|  |  |  |
| --- | --- | --- |
| a. | ‘Union supply’ | 9 |

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| --- | --- | --- |
| b. | ‘Shares of the Union supply’ | 10 |

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| --- | --- | --- |
| c. | Main data sources | 11 |

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| --- | --- | --- |
| d. | Other data sources to use in the absence of specific CN codes | 11 |

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| --- | --- | --- |
| e. | Variations in the calculation of ‘shares of the Union supply’ | 13 |

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| --- | --- | --- |
| V. | BACKGROUND TABLES | 17 |

I.   INTRODUCTION

Regulation (EU) 2024/1735 (‘the NZIA Regulation’) [(1)](#ntr1-C_202503236EN.000101-E0001) establishes a framework for ensuring that the Union has access to a secure and sustainable supply of net-zero technologies by promoting the diversification of their supply chains and enhancing the domestic manufacturing capacity of net-zero technologies.

Under Articles 25, 26 and 28 of the NZIA Regulation, non-price criteria - including the contribution to resilience - are to be applied in public procurement, renewable energy auctions and other forms of public intervention to develop and maintain an industrial basis for net-zero technologies, to secure the European Union’s (EU) energy supply and to avoid dependencies in the supply of these technologies. For the purposes of assessing the contribution to resilience, the Commission adopted, based on Article 29(2) of the NZIA Regulation, the Commission Implementing Regulation (EU) 2025/1178 [(2)](#ntr2-C_202503236EN.000101-E0002).

In this context and on the basis of that Implementing Regulation, as required by the second sentence of Article 29(2) of the NZIA Regulation, this Communication provides updated information on the shares of the Union supply originating in different third countries in the most recent year for which data is available. It covers net-zero technology final products and their main specific components (see Section II) [(3)](#ntr3-C_202503236EN.000101-E0003).

Article 13(1)(a)(i) of the NZIA Regulation requires Member States to recognise as net-zero strategic projects those net-zero technology manufacturing projects that increase the Union’s manufacturing capacity for a net-zero technology, for which the Union depends for more than 50 % on imports coming from third countries. In this context, this Communication assists Member States in assessing the eligibility of net-zero technology manufacturing projects for recognition as net-zero strategic projects under that provision. It does so by providing updated information on the shares of the Union supply originating in all third countries in the most recent year for which data is available (see Section III).

It is currently only possible to provide data on the shares of the Union supply for 25 net-zero technology final products and their main specific components. For the remaining net-zero technologies, due to a lack of detailed statistics it is not yet possible to analyse the shares of the Union supply. Consequently, the resilience contribution cannot be applied to those final products and their main specific components for which the shares of the Union supply are unavailable.

The methodology and data sources used for calculating the shares of the Union supply represent the best option available at this time. To overcome the limited statistics, the Commission is in the process of developing the additional Combined Nomenclature (CN) codes specific to net-zero technologies. These new codes will help to identify strategic dependencies in the net-zero technology sector, ultimately contributing to create a more resilient and secure supply chain. As new data becomes available, the Commission will also improve the methodology to calculate the shares of the Union supply.

The Commission will provide annually updated information on the shares of the Union supply originating in different third countries for the most recent year available through a dedicated communication. Preliminary informal data on the shares of the Union supply will be provided in the third quarter. This will be followed in the first quarter of the subsequent year by the adoption of the communication with the official data on the shares of the Union supply originating in different third countries referred to in Article 29(2) of the NZIA Regulation. This communication constitutes the source of official information for the determination of the origin in a third country of a specific net-zero technology or its main specific components as stated in Article 25 of the NZIA Regulation and in Article 7 of Commission Implementing Regulation (EU) 2025/1176 [(4)](#ntr4-C_202503236EN.000101-E0004). Annual updates of the shares of Union supply are needed in order to reflect the dynamic nature of global supply chains and the evolving shares of the Union supply impacted by factors such as changes in manufacturing capacity, shifts in trade patterns, geopolitical developments, and market dynamics.

This Communication is structured as follows:

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| --- | --- |
| — | Section II provides the shares of the Union supply originating in different third countries (relevant to Articles 25, 26 and 28 of the NZIA Regulation); |

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| --- | --- |
| — | Section III outlines the shares of the Union supply originating in all third countries (relevant to Article 13(1)(a)(i) of the NZIA Regulation); |

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| --- | --- |
| — | Section IV details the methodology used to calculate the shares of the Union supply. |

II.   SHARES OF THE UNION SUPPLY ORIGINATING IN DIFFERENT THIRD COUNTRIES

Table 1 details the shares of the Union supply from the three third countries of origin that account for the highest value of imports to the Union. It covers as many net-zero technology final products and their main specific components as possible from those listed in the Commission Implementing Regulation (EU) 2025/1178.

Table 1

Shares of the Union supply from the three third countries of origin with the highest value of imports, 2023

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Sub-category of net-zero technology | Final product | Main specific component | Share from top third country supplier [country] | Share from second-largest third country supplier [country] | Share from third-largest third country supplier [country] | Methodology |
| PV technologies | Solar PV systems |  | 79  % [China] | 1  % [Japan] |  | Combination of CN codes |
| PV technologies |  | PV modules + PV cells or equivalent4 | 94  % [China] |  |  | CN codes |
| PV technologies |  | PV inverters | 50  % [China] | 3  % [Japan] | 2  % [United Kingdom] | CN codes |
| PV technologies |  | PV wafers or equivalent [(5)](#ntr5-C_202503236EN.000101-E0005) | 79  % [China] | 6  % [United States] | 6  % [Taiwan] | TARIC codes |
| Solar thermal technologies | Solar thermal systems |  | 2  % [China] |  |  | CN codes |
| Onshore wind technologies, Offshore wind technologies | Onshore wind turbines; Offshore wind turbines[(6)](#ntr6-C_202503236EN.000101-E0006) |  | 2  % [India] |  |  | CN codes |
| Onshore wind technologies, Offshore wind technologies |  | Towers | 9  % [Türkiye] |  |  | TARIC codes |
| Onshore wind technologies, Offshore wind technologies |  | Permanent magnets of wind turbines | 93  % [China] | 6  % [Japan] |  | ERMA |
| Battery technologies | Battery packs; battery modules; battery cells | Battery packs; battery modules; battery cells | 50  % [China] | 4  % [Korea] | 1  % [Japan] | CN codes |
| Battery technologies |  | Separators | 19  % [Korea] | 17  % [China] | 10  % [United Kingdom] | CN codes |
| Battery technologies |  | Anode active materials | 81  % [China] | 18  % [Korea] |  | IEA |
| Gravitational storage technologies | Pumped hydro storage |  | 1  % [China] |  |  | CN codes |
| Heat pump technologies | Heat pumps |  | 11  % [China] | 2  % [Japan] | 2  % [Switzerland] | CN codes |
| Electricity grid technologies | Onshore substations; Offshore substations |  | 31  % [China] | 3  % [Türkiye] | 2  % [Switzerland] | CN codes |
| Electricity grid technologies |  | 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) + Electrical conductors (including advanced conductors and high temperature superconductors) | 4  % [Türkiye] | 3  % [Switzerland] | 2  % [China] | CN codes |
| Electricity grid technologies | Power transformers | Power transformers | 9  % [Türkiye] | 6  % [China] | 2  % [Switzerland] | CN codes |
| Electricity grid technologies |  | Switchgears; Electric cabinets; Busbar systems | 5  % [Norway] | 5  % [China] | 5  % [Türkiye] | CN codes |
| Electricity grid technologies |  | Circuit breakers | 5  % [Switzerland] | 5  % [China] | 5  % [United Kingdom] | CN codes |
| Electricity grid technologies |  | Insulators | 14  % [China] | 3  % [Switzerland] | 2  % [United States] | CN codes |
| Electricity grid technologies |  | Disconnectors | 7  % [Switzerland] | 2  % [Korea] |  | CN codes |
| Nuclear fuel cycle technologies |  | Centrifuges | 2  % [Switzerland] |  |  | CN codes |
| Hydropower technologies | Hydro turbine systems |  | 1  % [China] |  |  | CN codes |
| Hydropower technologies |  | Hydro turbine runners + Distributors with guide vanes | 4  % [Türkiye] | 2  % [India] | 1  % [Switzerland] | CN codes |
| Transformative industrial technologies for decarbonisation | Industrial induction heaters / furnaces | Industrial induction heaters / furnaces | 4  % [United Kingdom] | 2  % [Korea] | 1  % [Türkiye] | CN codes |
| Transformative industrial technologies for decarbonisation |  | Graphite or carbon electrodes for electric furnaces | 15  % [China] | 8  % [India] | 2  % [Japan] | CN codes |

Notes:

|  |  |
| --- | --- |
| — | Columns 4-6 indicate the shares of Union supply. The values indicated are rounded to the nearest integer number. |

|  |  |
| --- | --- |
| — | Shares below 1 % are not indicated. |

|  |  |
| --- | --- |
| — | In bold with light orange shading: net-zero technologies with a share of the Union supply of over 50 % or over 40 % and having increased by at least 10 percentage points on average for two consecutive years. |

|  |  |
| --- | --- |
| — | Net-zero technology final products that are the output of a factory fulfil the criteria to be considered main specific components, thus they are included in both columns. |

|  |  |
| --- | --- |
| — | When a cell in Table 1 includes multiple net-zero technologies separated by ‘;’ it means that the share applies to each net-zero technology. The ‘+’ symbol indicates that the share applies to all net-zero technologies combined. |

|  |  |
| --- | --- |
| — | The ‘CN codes’ methodology refers to the use of the Combined Nomenclature codes as indicated in Section IV ‘ Main data sources’ . |

|  |  |
| --- | --- |
| — | The ‘TARIC codes’ methodology refers to the use of TARIC codes as indicated in Section IV ‘ Other data sources to use in the absence of specific CN codes’ . |

|  |  |
| --- | --- |
| — | The ‘Combination of CN codes’ methodology refers to the combination of multiple CN codes associated with several components, as described in Section IV  ‘Variations in the calculation of “shares of Union supply” ’  subsections (i) and (ii). |

|  |  |
| --- | --- |
| — | The ‘IEA’ methodology refers to the use of the results of the International Energy Agency’s analysis as indicated in Section IV  ‘Other data sources to use in the absence of specific CN codes’. |

|  |  |
| --- | --- |
| — | The “ERMA” methodology refers to the results of European Raw Materials Alliance analysis as indicated in Section IV  “Other data sources to use in the absence of specific CN codes’. |

|  |  |
| --- | --- |
| — | PV = photovoltaic, HVDC = high voltage direct current, HVAC = high voltage alternating current. |

|  |  |
| --- | --- |
| — | China = People’s Republic of China. |

III.   SHARES OF THE UNION SUPPLY ORIGINATING IN ALL THIRD COUNTRIES

Table 2 provides information on the shares of the Union supply from all third countries of origin of as many net-zero technology final products and main specific components as possible from those listed in the Commission Implementing Regulation (EU) 2025/1178. The purpose is to support Member States in the process of selecting net-zero strategic projects as specified in Article 13(1)(a)(i) of the NZIA Regulation.

Table 2

Shares of the Union supply from all third countries of origin for net-zero technology final products and main specific components, 2023

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Sub-category of net-zero technology | Final product | Main specific component | Share of Union supply from third countries | Methodology |
| PV technologies | Solar PV systems |  | 85  % | Combination of CN codes |
| PV technologies |  | PV modules + PV cells or equivalent5 | 96  % | CN codes |
| PV technologies |  | PV inverters | 62  % | CN codes |
| PV technologies |  | PV wafers or equivalent [(7)](#ntr7-C_202503236EN.000101-E0007) | 100  % | TARIC codes |
| Solar thermal technologies | Solar thermal systems |  | 2  % | CN codes |
| Onshore wind technologies, Offshore wind technologies | Onshore wind turbines; Offshore wind turbines |  | 3  % | CN codes |
| Onshore wind technologies, Offshore wind technologies |  | Towers | 10  % | TARIC codes |
| Onshore wind technologies, Offshore wind technologies |  | Permanent magnets of wind turbines | 99  % | ERMA |
| Battery technologies | Battery packs; battery modules; battery cells | Battery packs; battery modules; battery cells | 59  % | CN codes |
| Battery technologies |  | Separators | 46  % | CN codes |
| Battery technologies |  | Anode active materials | 100  % | IEA |
| Gravitational storage technologies | Pumped hydro storage |  | 2  % | CN codes |
| Heat pump technologies | Heat pumps |  | 22  % | CN codes |
| Electricity grid technologies | Onshore substations; Offshore substations |  | 52  % | CN codes |
| Electricity grid technologies |  | 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) + Electrical conductors (including advanced conductors and high temperature superconductors) | 16  % | CN codes |
| Electricity grid technologies | Power transformers | Power transformers | 22  % | CN codes |
| Electricity grid technologies |  | Switchgears; Electric cabinets; Busbar systems | 20  % | CN codes |
| Electricity grid technologies |  | Circuit breakers | 25  % | CN codes |
| Electricity grid technologies |  | Insulators | 27  % | CN codes |
| Electricity grid technologies |  | Disconnectors | 12  % | CN codes |
| Nuclear fuel cycle technologies |  | Centrifuges | 3  % | CN codes |
| Hydropower technologies | Hydro turbine systems |  | 2  % | CN codes |
| Hydropower technologies |  | Hydro turbine runners + Distributors with guide vanes | 10  % | CN codes |
| Transformative industrial technologies for decarbonisation | Industrial induction heaters / furnaces | Industrial induction heaters / furnaces | 11  % | CN codes |
| Transformative industrial technologies for decarbonisation |  | Graphite or carbon electrodes for electric furnaces | 29  % | CN codes |

Notes:

|  |  |
| --- | --- |
| — | Columns 4-6 indicate the shares of Union supply. The values indicated are rounded to the nearest integer number. |

|  |  |
| --- | --- |
| — | Shares below 1 % are not indicated. |

|  |  |
| --- | --- |
| — | In bold with light orange shading: net-zero technologies with a share of the Union supply of over 50 % or over 40 % and having increased by at least 10 percentage points on average for two consecutive years. |

|  |  |
| --- | --- |
| — | Net-zero technology final products that are the output of a factory fulfil the criteria to be considered main specific components, thus they are included in both columns. |

|  |  |
| --- | --- |
| — | When a cell in Table 2 includes multiple net-zero technologies separated by”;’ it means that the share applies to each net-zero technology. The ‘+’ symbol indicates that the share applies to all net-zero technologies combined. |

|  |  |
| --- | --- |
| — | The ‘CN codes’ methodology refers to the use of the Combined Nomenclature codes as indicated in Section IV ‘ Main data sources’ . |

|  |  |
| --- | --- |
| — | The ‘TARIC codes’ methodology refers to the use of TARIC codes as indicated in Section IV ‘ Other data sources to use in the absence of specific Combined Nomenclature codes’ . |

|  |  |
| --- | --- |
| — | The ‘Combination of CN codes’ methodology refers to the combination of multiple CN codes associated with several components, as described in Section IV  ‘Variations in the calculation of “shares of Union supply” ’  subsections (i) and (ii). |

|  |  |
| --- | --- |
| — | The ‘IEA’ methodology refers to the use of the results of the International Energy Agency’s analysis as indicated in Section IV  ‘Other data sources to use in the absence of specific CN codes’ . |

|  |  |
| --- | --- |
| — | The ‘ERMA’ methodology refers to the results of European Raw Materials Alliance analysis as indicated in Section IV  ‘Other data sources to use in the absence of specific CN codes’ . |

|  |  |
| --- | --- |
| — | PV = photovoltaic, HVDC = high voltage direct current, HVAC = high voltage alternating current. |

|  |  |
| --- | --- |
| — | China = People’s Republic of China. |

IV.   METHODOLOGY FOR EVALUATING THE SHARES OF THE UNION SUPPLY

a.   
‘Union supply’

To evaluate the shares of the Union supply of net-zero technologies, the ‘Union supply’ for a given year is calculated as defined in Equation 1:

|  |
| --- |
| Equation 1  Formula |

where:

|  |  |
| --- | --- |
| — | Production is the value of production within the Union; |

|  |  |
| --- | --- |
| — | Imports is the value of imports to the Union from all third countries; |

|  |  |
| --- | --- |
| — | Exports is the value of exports from the Union to all third countries. |

This approach corresponds to the ‘available supply’ concept, which takes into account the total value of a product available in the Union, including domestic production and imports and subtracting exports [(8)](#ntr8-C_202503236EN.000101-E0008). This formulation is widely used in economic literature and has been chosen for the purposes of this Communication due to its relevance in the context of long-term contracts, which are common in the industries concerned. Specifically, the assumption underlying this approach is that imports and exports are interdependent, and that any disruption to imports would also impact exports. The Union's role as a transit region, where certain goods are imported and then re-exported to other countries, also explains the decision to include both imports and exports in the calculation of supply. By considering both, this approach provides a more accurate representation of domestic demand.

b.   
‘Shares of the Union supply’

To evaluate the shares of the Union supply of net-zero technologies originating in all third countries, the ‘share of the Union supply’ is generally defined as the ratio between the value imported from all third-country suppliers and the Union supply, as illustrated in Equation 2a:

|  |
| --- |
| Equation 2a  Formula |

where:

|  |  |
| --- | --- |
| — | Share of the Union supply  all  is the share of the Union supply from all third countries. |

|  |  |
| --- | --- |
| — | Imports is as defined in Equation 1; |

|  |  |
| --- | --- |
| — | Union supply is as defined in Equation 1. |

The shares of the Union supply of net-zero technologies originating in different third countries are generally calculated as the ratio between the value of imports to the Union originating in a specific third country and the Union supply, as illustrated in Equation 2b. In particular, the shares of the Union supply originating in different third countries have been calculated for the three third countries with the highest value of imports to the Union.

|  |
| --- |
| Equation 2b  Formula |

where:

|  |  |
| --- | --- |
| — | Formula  is the share of the Union supply from the n-largest third country supplier. |

|  |  |
| --- | --- |
| — | Formula  is the value of imports to the Union originating in the third country with the n-largest value of imports to the Union; |

|  |  |
| --- | --- |
| — | Union supply is as defined in Equation 1. |

However, in some cases it is necessary to apply alternative formulations of Equations 2a,b – please see Section IV.d for alternative equations.

c.   Main data sources

Article 29(2) of the NZIA Regulation states that for net-zero technology final products and their main specific components the country of origin shall be determined in accordance with Regulation (EU) No 952/2013 [(9)](#ntr9-C_202503236EN.000101-E0009). According to that provision, the shares of the Union supply provided in Sections II and III have been calculated - whenever feasible – based on the following:

|  |  |
| --- | --- |
| — | Combined Nomenclature (CN) codes for import and export statistics, using the COMEXT database [(10)](#ntr10-C_202503236EN.000101-E0010) ,  [(11)](#ntr11-C_202503236EN.000101-E0011) ,  [(12)](#ntr12-C_202503236EN.000101-E0012). |

|  |  |
| --- | --- |
| — | PRODCOM classification for production statistics, using the PRODCOM database [(13)](#ntr13-C_202503236EN.000101-E0013) ,  [(14)](#ntr14-C_202503236EN.000101-E0014). |

The COMEXT and PRODCOM databases, which are official, reliable, and publicly available statistical sources, are considered the most suitable tools for calculating the shares of the Union supply originating in third countries. These databases provide a comprehensive and accurate overview of trade flows and production data, ensuring a robust and precise analysis for calculating the shares of the Union supply.

CN codes are the primary method used to calculate the shares of supply and are used as a source of evidence by default. However, not every net-zero technology final product or main specific component has a specific CN and PRODCOM code (see Table 3 for the list of CN and PRODCOM codes that have been used to determine the shares of the Union supply). This limitation is evident when comparing the list of net-zero technologies for which the shares of supply can be identified via CN codes (see Table 1 and Table 2) with the list of net-zero technology final products and main specific components in the Commission Implementing Regulation (EU) 2025/1178. Although this includes a list of 230 net-zero technology final products and main specific components, the shares of the Union supply can be calculated for just 21 net-zero technologies if the calculation is based solely on CN codes. To expand the use of the CN code methodology, the Commission is introducing new CN codes specific to net-zero technologies. The Commission is also increasing the level of detail of PRODCOM codes with the aim of achieving one-to-one correspondence between PRODCOM codes and CN codes for net-zero technologies. While it will take time for these improvements to become operational, they are expected to deliver substantial benefits in the medium and long term.

If the CN code methodology cannot be used for the above reason, other data sources are used to calculate the shares of the Union supply of other net-zero technology final products and main specific components.

d.   Other data sources to use in the absence of specific CN codes

When the shares of the Union supply of net-zero technology final products and their main specific components cannot be calculated solely by using CN codes, additional reliable data sources are used. For net-zero technologies that lack a specific CN code, the TARIC (Integrated Tariff of the European Union) database is consulted to check whether a specific TARIC code exists. Where available, those TARIC codes may provide valuable data on imports via the Commission's Directorate-General for Taxation and Customs Union’s (TAXUD) surveillance database (see Table 4) [(15)](#ntr15-C_202503236EN.000101-E0015).

As TARIC codes focus on import statistics, two considerations need to be borne in mind in using them:

|  |  |
| --- | --- |
| — | Exclusion of export statistics: for net-zero technologies that only have associated TARIC code, export statistics are not tracked. This method of calculating the Union supply shares therefore excludes exports, meaning that the calculation gives a more conservative result. |

|  |  |
| --- | --- |
| — | Estimation of production statistics: PRODCOM codes, which provide production statistics, are primarily developed for products with associated CN codes. Therefore, for net-zero technologies that only have an associated TARIC code, production data is estimated based on manufacturing capacities. Manufacturing capacity data collected by the Commission to monitor progress in meeting the benchmarks referred to in Article 5 of the NZIA Regulation (see NZIA Article 42(1)) is used as a proxy for production. Where needed, an appropriate conversion from quantity to value of production can be applied. Since production is lower than full manufacturing capacity, to assume that production equals manufacturing capacity means that this also represents a conservative approach to evaluating the shares of the Union supply. |

The resulting equation for the conservative approach to evaluate the shares of the Union supply of net-zero technologies that only have associated TARIC codes is as follows:

|  |
| --- |
| Equation 3a,b  Formula  Formula |

where:

|  |  |
| --- | --- |
| — | Imports is as defined in Equation 1; |

|  |  |
| --- | --- |
| — | Manufacturing capacity is the value of manufacturing capacity within the Union; |

|  |  |
| --- | --- |
| — | Formula  is as defined in equation 2b. |

When the shares of the Union supply of net-zero technology final products and their main specific components could not be calculated using CN codes or TARIC codes, the Commission has temporarily relied on other data sources. In those cases, data from the International Energy Agency’s (IEA) Energy Technology Perspectives 2024 report and the European Raw Materials Alliance’s (ERMA) Rare Earth Magnets and Motors: A European Call for Action report are key references [(16)](#ntr16-C_202503236EN.000101-E0016)
,
 [(17)](#ntr17-C_202503236EN.000101-E0017)
,
 [(18)](#ntr18-C_202503236EN.000101-E0018).

The IEA’s Energy Technology Perspectives 2024 report provides 2023 data on Union production, exports and imports from different third countries (i.e. those with the largest values of imports) and from all third countries, which are used to calculate the shares of the Union supply as per Equations 2a and 2b. These figures are underpinned by the IEA’s manufacturing and trade (MaT) model, which provides a dynamic picture of global supply chains by offering insights on production levels, manufacturing capacity, and bilateral trade flows for six net-zero technologies’ final products and their key components. The MaT model integrates regional demands and applies a least-cost optimization approach to assess the annual cost-optimal balance between domestic manufacturing and imports, considering factors such as manufacturing capacities, production costs, trade costs, regional industrial and trade policies, and investment trends in emerging markets [(19)](#ntr19-C_202503236EN.000101-E0019).

ERMA's Rare Earth Magnets and Motors: A European Call for Action report leverages industry-based data to offer a detailed overview of supply chain dynamics of net-zero technologies. Through collaboration with market actors and stakeholders, ERMA grounds its assessment in direct industry knowledge and market dynamics, ensuring accuracy and reliability. Their comprehensive analytical framework considers sourcing strategies, material substitutions, and technological innovations, providing a thorough overview of supply dependencies. Though the analysis refers to 2021, leading market actors have consistently confirmed that the situation has not changed since then.

Both the IEA’s and ERMA’s reports are highly credible and robust, based on official data and authoritative sources that have been validated with key market actors in the relevant value chains. Their rigorous methodologies ensure alignment with verified trade and production figures, making them reliable complements to information derived from CN codes and TARIC codes when assessing the shares of the Union supply for net-zero technologies.

e.   Variations in the calculation of ‘shares of the Union supply’

As pointed out in Section IV (a) ‘
Union supply’
, the calculation of the shares of Union supply may feature minor variations between net-zero technologies due to differences in the availability of statistics and data sources. These slight variations are consistent and underscore the importance of using flexible yet rigorous evaluation methods tailored to the specific availability of CN codes, PRODCOM codes, TARIC codes and additional data sources related to net-zero technology final products and main specific components. In the following cases, the alternative equations below are applicable:

(i)   Final products defined as ‘systems’

When a final product is defined as a ‘system’ (e.g. solar photovoltaic systems), it is not generally possible to identify a CN code associated with it. For these products, the shares of the Union supply must be evaluated on the basis of the statistics for the system’s underlying components, which are listed in the annex of the Commission Delegated Regulation (EU) C(2025) 2901 [(20)](#ntr20-C_202503236EN.000101-E0020). For final products defined as ‘systems’, the shares of the Union supply originating in all third countries must be calculated on the basis of the cumulative value imported to the Union of all the components making up the final product, and the cumulative supply of all the components making up the final product, using Equation 4a. Similarly, the shares of the Union supply originating in the third countries with the highest value of imports to the Union must be calculated on the basis of the total value imported to the Union originating in the third countries with the highest overall import of all the components constituting the final product, and the cumulative supply of all the components constituting the system, using Equation 4b.

|  |
| --- |
| Equation 4a,b  Formula  Formula |

where:

|  |  |
| --- | --- |
| — | Formula  is the cumulative value of the imports to the Union of the components making up the final product defined as a ‘system’; |

|  |  |
| --- | --- |
| — | Formula  is the cumulative value of the production within the Union of all the components making up the final product defined as a ‘system’; |

|  |  |
| --- | --- |
| — | Formula  is the cumulative value of the exports from the Union to third countries of all the components making up the final product defined as a ‘system’; |

|  |  |
| --- | --- |
| — | Formula  is the total value imported to the Union from the third country of origin with the n-largest overall import of all the components making up the final product defined as a ‘system’. |

However, due to the limited availability of CN codes specific to net-zero technologies, ensuring that the results of Equation 4a,b are representative depends on certain conditions. The shares of the Union supply of final products calculated using this approach are only considered valid if specific CN codes are available for the main specific components that, combined, account for more than 50 % of the final product’s value, in line with Tables 5-9.

(ii)   Final products that lack specific CN codes

If a final product is not defined as a ‘system’ and still lacks a specific CN code, its share of the Union supply can be evaluated by applying Equation 4a,b to the final product’s Tier 1 main specific components [(21)](#ntr21-C_202503236EN.000101-E0021). To ensure that the results are representative, this approach can be used provided that the main specific components for which specific CN codes are available account for more than 50 % of the final product’s value, in line with Tables 5-9. If specific CN codes are not available for any Tier 1 component, the methodology may be applied to Tier 2 components.

(iii)   Net-zero technologies linked to a PRODCOM code matching multiple CN codes

The level of granularity differs between PRODCOM codes and CN codes, meaning that a direct one-to-one correspondence between these classifications is not always possible. In some cases, multiple CN codes, each associated with different net-zero technologies, may correspond to the same PRODCOM code. In these cases, the net-zero technology shares of the Union supply must be evaluated as an aggregate of the net-zero technologies associated with the PRODCOM code. This aggregation is necessary because the limited granularity of PRODCOM codes does not allow for differentiation between the individual net-zero technologies they cover.

In these cases, Equation 5 is used to evaluate the shares of the Union supply, which takes account of the fact that the terms related to imports and exports are more than those related to production. Specifically, the shares of the Union supply originating in all third countries must be calculated by taking as the numerator the cumulative value imported to the Union of all net-zero technologies associated with the shared PRODCOM code, and as the denominator the value of production within the Union linked to that single PROCOM code, plus the cumulative value imported to the Union across all net-zero technologies associated with it, minus the cumulative value exported from the Union across all net-zero technologies associated to that PRODCOM code, using Equation 5a.

Similarly, the shares of the Union supply originating in the third country with the highest value of imports to the Union must be calculated by taking as the numerator the total value imported to the Union from the third country of origin with the highest overall value of imports across all net-zero technologies associated with the shared PRODCOM code, and as the denominator the value of production within the Union linked to it, plus the cumulative value imported to the Union across all net-zero technologies associated with that code, minus the cumulative value exported from the Union across all net-zero technologies associated with it, using Equation 5b.

|  |
| --- |
| Equation 5a,b  Formula  Formula |

where:

|  |  |
| --- | --- |
| — | Formula  is the cumulative value of the imports to the Union of all the net-zero technologies associated with the shared PRODCOM code; |

|  |  |
| --- | --- |
| — | Production is the value of production within the Union associated with the single PRODCOM code; |

|  |  |
| --- | --- |
| — | Formula  is the cumulative value of the exports from the Union to third countries of all net-zero technologies associated with the shared PRODCOM code; |

|  |  |
| --- | --- |
| — | Formula  is the total value imported to the Union from the third country of origin with the n-largest value of imports to the Union of all the net-zero technologies associated with the shared PRODCOM code. |

(iv)   Net-zero technologies linked to a CN code matching multiple PRODCOM codes

Since the level of granularity between PRODCOM codes and CN codes differs, in some cases multiple PRODCOM codes may correspond to the same CN code. In these cases, the net-zero technology’s shares of the Union supply must be evaluated as an aggregate of all the net-zero technologies associated with the ‘shared’ CN code. This is similar to the approach outlined in subsection (iii). The main difference is that, in this case, the same net-zero technology is associated with more PRODCOM codes than CN codes.

In these cases, Equation 6 is used to evaluate the shares of the Union supply, which takes account of the fact that the terms related to production are more numerous than those related to imports and exports. Specifically, the shares of the Union supply originating in all third countries must be calculated by taking as the numerator the value imported to the Union of the net-zero technology associated with the shared CN code, and as the denominator the cumulative value of production within the Union of all net-zero technologies associated with that CN code, plus the value imported to the Union for the net-zero technology associated with the shared CN code and minus the value exported from the Union for the net-zero technology associated with it, using Equation 6a.

Similarly, the shares of the Union supply originating in the third country with the highest value of imports to the Union must be calculated by taking as the numerator the value imported from the third country of origin with the highest value of imports to the Union for the net-zero technology associated with the shared CN code, and as the denominator the cumulative value of production within the Union across all net-zero technologies associated to it, plus the value imported to the Union for the net-zero technology linked to the shared CN code and minus the value exported from the Union for the net-zero technology linked to it, using Equation 6b.

|  |
| --- |
| Equation 6a,b  Formula  Formula |

where:

|  |  |
| --- | --- |
| — | Imports is the value of imports to the Union from third countries; |

|  |  |
| --- | --- |
| — | Formula  is the cumulative value of production within the Union of all the net-zero technologies associated with the shared CN code; |

|  |  |
| --- | --- |
| — | Exports is the value of exports from the Union to third countries for all net-zero technologies associated with the shared CN code. |

|  |  |
| --- | --- |
| — | Formula  is the value of imports to the Union from the third country of origin with the n-largest value of imports to the Union among all third country suppliers for all the net-zero technologies associated with the shared CN code. |

(v)   Net-zero technologies with multiple associated CN codes

In some cases, multiple CN codes are associated with a single net-zero technology. In these cases, Equation 7a,b is used to evaluate the shares of the Union supply taking into consideration all relevant CN codes.

Specifically, the shares of the Union supply originating in all third countries must be calculated by taking as the numerator the cumulative value imported to the Union across the multiple CN codes associated with the net-zero technology, and as the denominator the cumulative value of production within the Union linked to all the PRODCOM codes associated with the multiple CN codes, plus the cumulative value imported to the Union across the multiple CN codes associated with the net-zero technology, minus the cumulative value exported from the Union across the multiple CN codes associated with the net-zero technology, using Equation 7a.

Similarly, the shares of the Union supply originating in the third country with the highest value of imports to the Union must be calculated by taking as the numerator the total value imported to the Union from the third country of origin with the highest overall import across the multiple CN codes associated with the net-zero technology, and as the denominator the cumulative value of production within the Union linked to all the PRODCOM codes associated with the multiple CN codes, plus the cumulative value imported to the Union across the multiple CN codes associated with the net-zero technology, minus the cumulative value exported from the Union across the multiple CN codes associated with the net-zero technology, using Equation 7b.

|  |
| --- |
| Equation 7a,b  Formula  Formula |

V.   BACKGROUND TABLES

Table 3

Table 3 provides an overview of the CN codes and PRODCOM codes specific to net-zero technologies that have been used to calculate the shares of the Union supply originating in the third countries of origin with the highest value of imports to the Union and in all third countries, as indicated in Table 1 and Table 2 respectively.

Table 3

List of CN product description, CN codes and PRODCOM codes specific to net-zero technology final products and their main specific components, 2025

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Sub-category of net-zero technology | Final product / main specific component | CN product description | CN code | PRC code |
| PV technologies | PV modules; PV cells | PV cells not assembled in modules or made up into panels;  PV cells assembled in modules or made up into panels | 8541 42 00 ,  8541 43 00 | 26112240 |
| PV technologies | PV inverters | Inverters having a power handling capacity not exceeding 7,5 kVA and exceeding 7,5 kVA | 8504 40 85 ,  8504 40 86 | 27904153 ,  27904155 |
| Solar thermal technologies | Solar thermal systems | Solar water heaters | 8419 12 00 | 27521400 |
| Onshore wind technologies; Offshore wind technologies | Onshore wind turbines; Offshore wind turbines | Wind-powered generating sets | 8502 31 00 | 28112400 |
| Battery technologies | Battery packs; Battery modules; Battery cells | Lithium-ion electric accumulators. | 8507 60 00 | 27202350 |
| Battery technologies | Separators | Separators for electric accumulators, whether or not rectangular (including square) | 8507 90 30 | 27202410 |
| Gravitational storage technologies; Hydropower technologies | Pumped hydro storage; Hydro turbine systems | Hydraulic turbines and water wheels | 8410 11 00 ,  8410 12 00 ,  8410 13 00 | 28112200 |
| Heat pump technologies | Heat pumps | Heat pumps other than air conditioning machines of heading 8415 | 8418 61 00 | 28251380 |
| Electricity grid technologies | Onshore substations; Offshore substations | Liquid dielectric transformers and other transformers having a power handling capacity exceeding 1 kVA;  Inverters and other static converters, excluding accumulator chargers and rectifiers;  Fuses and automatic circuit breakers for a voltage exceeding 1 000  V;  Isolating switches and make-and-break switches for a voltage exceeding 1 000 V;  Boards, panels, consoles, desks, cabinets and other bases, for electric control or  the distribution of electricity for a voltage exceeding 1 000  V;  Insulated wire, cable and other insulated electric conductors, whether or not fitted with connectors for a voltage exceeding 1 000  V, excluding winding wire, coaxial cable, coaxial electric conductors, ignition wiring sets and other wiring sets | 8504 21 00 ,  8504 22 10 ,  8504 22 90 ,  8504 23 00 ,  8504 32 00 ,  8504 33 00 ,  8504 34 00 ,  8504 40 85 ,  8504 40 86 ,  8504 40 95 ,  8535 10 00 ,  8535 21 00 ,  8535 29 00 ,  8535 30 10 ,  8535 30 90 ,  8537 20 91 ,  8537 20 99 ,  8544 60 10 ,  8544 60 90 | 27114120 ,  27114150 ,  27114180 ,  27114260 ,  27114330 ,  27114380 ,  27904153 ,  27904155 ,  27904170 ,  27121010 ,  27121020 ,  27121030 ,  27123203 ,  27123205 ,  27321400 |
| Electricity grid technologies | 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); Electrical conductors (including advanced conductors and high temperature superconductors) | Insulated wire, cable and other insulated electric conductors, whether or not fitted with connectors for a voltage exceeding 1 000  V, excluding winding wire, coaxial cable, coaxial electric conductors, ignition wiring sets and other wiring sets | 8544 60 10 ,  8544 60 90 | 27321400 |
| Electricity grid technologies | Power transformers | Liquid dielectric transformers and other transformers having a power handling capacity exceeding 1 kVA | 8504 21 00 ,  8504 22 10 ,  8504 22 90 ,  8504 23 00 ,  8504 32 00 ,  8504 33 00 ,  8504 34 00 | 27114120 ,  27114150 ,  27114180 ,  27114260 ,  27114330 ,  27114380 |
| Electricity grid technologies | Switchgears; Electric cabinets; Busbar systems | Boards, panels, consoles, desks, cabinets and other bases, for electric control or  the distribution of electricity for a voltage exceeding 1 000  V | 8537 20 91 ,  8537 20 99 | 27123203 ,  27123205 |
| Electricity grid technologies | Circuit breakers | Fuses and automatic circuit breakers for a voltage exceeding 1 000  V | 8535 10 00 ,  8535 21 00 ,  8535 29 00 | 27121010 ,  27121020 |
| Electricity grid technologies | Disconnectors | Isolating switches and make-and-break switches for a voltage exceeding 1 000  V | 8535 30 10 ,  8535 30 90 | 27121030 |
| Electricity grid technologies | Insulators | Electrical insulators of any material | 8546 10 00 ,  8546 20 00 ,  8546 90 10 ,  8546 90 90 | 23192500 ,  23431030 ,  27901230 |
| Nuclear fuel cycle technologies | Centrifuges | Machinery and apparatus for isotopic separation and parts thereof | 8401 20 00 | 28993910 |
| Hydropower technologies | Hydro turbine runners; Distributors with guide vanes | Parts of hydraulic turbines and water wheels including regulators | 8410 90 00 | 28113200 |
| Transformative industrial technologies for decarbonisation | Industrial induction heaters / furnaces | Induction furnaces and ovens | 8514 20 10 | 28211353 |
| Transformative industrial technologies for decarbonisation | Graphite or carbon electrodes for electric furnaces | Carbon electrodes, carbon brushes, lamp carbons, battery carbons and  other articles of graphite or other carbon with or without metal, of a kind used for furnaces | 8545 11 00 | 27901330 |

Notes:

CN = Combined Nomenclature [(22)](#ntr22-C_202503236EN.000101-E0022), PRC = PRODCOM [(23)](#ntr23-C_202503236EN.000101-E0023). CN code and its product description refers to the CN 2025 classification [(24)](#ntr24-C_202503236EN.000101-E0024).

Table 4

Table 4 provides a list of the TARIC codes specific to net-zero technologies used to calculate the shares of the Union supply originating in the third countries of origin with the highest value of imports to the Union and in all third countries, as indicated in Table 1 and Table 2 respectively.

Table 4

List of TARIC product description and TARIC codes specific to net-zero technology main specific components, 2025

|  |  |  |  |
| --- | --- | --- | --- |
| Sub-category of net-zero technology | Final product / main specific component | TARIC product description | TARIC code |
| PV technologies | PV wafers or equivalent | Wafers of the type used in crystalline silicon photovoltaic modules or panels | 3818001011 ,  3818001019 |
| Onshore wind technologies; Offshore wind technologies | Towers | Utility scale tubular steel wind towers | 7308200011 |

Tables 5-9

Tables 5-9 show the shares of the main specific components in the final product’s value (i.e. the sum of the value of the underlying components) for the following nine sub-categories of net-zero technologies: photovoltaic (PV) technologies, solar thermal technologies, onshore wind technologies, offshore wind technologies, battery technologies, electrochemical storage technologies, heat pump technologies, electrolysers and hydrogen fuel cells.

These tables serve as a basis for calculating the shares of the Union supply of final products defined as ‘systems’ and of final products without specific CN codes. This is done by verifying whether CN codes exist for the main specific components that, when combined, account for more than 50 % of the final product’s value. Given that the components’ contribution to the final product’s overall value can vary depending on project-specific factors and market conditions, Tables 5-9 provide approximate reference values for 2023 estimated by the Joint Research Centre [(25)](#ntr25-C_202503236EN.000101-E0025). These figures are intended solely for the purpose outlined above and should not be interpreted as general cost breakdowns.

Each component’s share is expressed as a percentage of the total final product’s value, reflecting not only the transformation costs from one Tier to the next but also the cumulative value of all underlying components. This means, for instance, that the share of battery cells includes not only the assembly of its underlying components, but also the entire value embedded within cathode active materials, anode active materials, electrolytes, separators and current collectors. Simply summing the shares of all main specific components could lead to a total exceeding 100 % due to overlapping value contributions, whereas the shares of Tier 1 components should always be less than or equal to 100 %. Where the sum of the shares of value totals less than 100 %, the difference represents the value of other components that are not classified as main specific components.

Table 5

Cost distribution of the main specific components in solar technologies’ final products

|  |  |  |  |
| --- | --- | --- | --- |
| Sub-categories of net-zero technologies | Final products | Main specific components | Shares of value (%) |
| Photovoltaic (PV) technologies | Solar PV systems[(26)](#ntr26-C_202503236EN.000101-E0026) | PV grade polysilicon | 5 |
| PV grade silicon ingots or equivalent | 9 |
| PV wafers or equivalent | 15 |
| PV cells or equivalent | 28 |
| Solar glass | 6 |
| PV modules | 58 |
| PV inverters | 13 |
| PV trackers and their specific mounting structures | 19 |
| Solar thermal technologies | Solar thermal systems | Solar thermal collectors (including flat-plate, evacuated tube, concentrating systems and air collectors) | 35 |
| Solar thermal absorbers | 20 |
| Solar glass | 10 |

Table 6

Cost distribution of the main specific components in onshore wind and offshore renewable technologies’ final products

|  |  |  |  |
| --- | --- | --- | --- |
| Sub-categories of net-zero technologies | Final products | Main specific components | Shares of value (%) |
| Onshore wind technologies | Onshore wind turbines[(27)](#ntr27-C_202503236EN.000101-E0027) | Nacelles (assembly) | 44 |
| Rotor hubs | 5 |
| Main, yaw and pitch bearings | 5 |
| Direct drive drivetrains (including generator) and/or gearbox drivetrains (including generator) | 25 |
| Permanent magnets of wind turbines | 1 |
| Gearboxes of wind turbines | 7 |
| Blades | 26 |
| Towers | 25 |
| Offshore wind technologies | Offshore wind turbines[(28)](#ntr28-C_202503236EN.000101-E0028) | Nacelles (assembly) | 40 |
| Rotor hubs | 6 |
| Main, yaw and pitch bearings | 5 |
| Direct drive drivetrains (including generator) and/or gearbox drivetrains (including generator) | 24 |
| Permanent magnets of wind turbines | 6 |
| Gearboxes of wind turbines | 0 |
| Blades | 13 |
| Towers | 7 |
| Foundations / floaters | 34 |

Table 7

Cost distribution of the main specific components in battery technologies’ final products and energy storage technologies’ final products

|  |  |  |  |
| --- | --- | --- | --- |
| Sub-categories of net-zero technologies | Final products | Main specific components | Shares of value (%) |
| Battery technologies | Batteries | Battery packs | 100 |
| Battery modules | 80 |
| Battery cells | 70 |
| Cathode active materials | 25 |
| Anode active materials | 15 |
| Electrolytes | 10 |
| Separators | 10 |
| Current collectors (including thin copper, aluminium, nickel and carbon foils) | 7 |
| Battery management systems (BMS) | 5 |
| Battery thermal management systems (BTMS) | 5 |
| Electrochemical storage technologies | Ultracapacitors / supercapacitors | Electrolytes | 60 |
| Redox flow energy storage | Separators | 15 |
| Collectors | 15 |
| Electrode plates | 10 |
| |  |  | | --- | --- | | Note: | the shares of final product’s values are expressed relative to the battery pack. | | | | |

Table 8

Cost distribution of the main specific components in heat pump technologies’ final products

|  |  |  |  |
| --- | --- | --- | --- |
| Sub-categories of net-zero technologies | Final products | Main specific components | Shares of value (%) |
| Heat pump technologies | Heat pumps | Heat pumps | 100 |
| Four-way valves | 3 |
| Scroll compressors / heat pump rotary compressors | 25 |

Table 9

Cost distribution of the main specific components in hydrogen technologies’ final products

|  |  |  |  |
| --- | --- | --- | --- |
| Sub-categories of net-zero technologies | Final products | Main specific components | Shares of value (%) |
| Electrolysers | Alkaline electrolysers (AEL) | Stacks | 43 |
| Separators (diaphragm or membranes tailored for water electrolysis) | 4 |
| Bipolar plates and end plates | 9 |
| Electrodes | 18 |
| Proton exchange membrane electrolysers (PEMEL) | Stacks | 40 |
| Membrane electrode assemblies (3-layer) / catalyst-coated membranes | 14 |
| Porous transport layers / gas diffusion layers | 10 |
| Bipolar plates and end plates | 9 |
| Solid-oxide electrolysers (SOEL) | Stacks | 14 |
| Electrolytes and electrodes | 4 |
| Interconnectors / meshes and end plates | 9 |
| Hydrogen fuel cells | Proton exchange membrane fuel cells (PEMFC) | Stacks | 62 |
| Membrane electrode assemblies (3-layer) / catalyst-coated membranes | 40 |
| Porous transport layers / gas diffusion layers | 6 |
| Bipolar plates and end plates | 6 |
| Solid-oxide fuel cells (SOFC) | Stacks | 21 |
| Electrolytes and electrodes | 4 |
| Interconnectors / meshes and end plates | 8 |

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ELI: http://data.europa.eu/eli/C/2025/3236/oj

ISSN 1977-091X (electronic edition)

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