Recently, the fact that four component products of Hengdian Dongci were cancelled the preferential treatment of value-added tax by France was reported by " according to PV magzazine, the French authority Certisolis announced not long ago. Due to errors in traceability information, four photovoltaic module products of Hengdian Dongci were cancelled by 5. (Note: In France, only photovoltaic module products with carbon emissions of less than 530 kilograms per kilowatt can enjoy 5.)
Hengdian Dongci admitted that there were problems in the documents and began to reduce the impact of the incident. Mehdi Boudal, sales director of Hengdian Dongci in France, Africa and the Middle East, told the media that the company had withdrawn the components from the shelves and had informed distributors that the remaining parts could continue to be sold at a 20% value-added tax rate.
At the same time, Hengdian Dongci said it would compensate for the difference in value-added tax involved in the components already installed, and planned to submit a corrected application to regain the application
. The incident may only be a "pain in the flesh" for the company, but it is a warning to China to go to Europe " that the carbon footprint requirements of the European market will be more stringent in the future. On January 1
, 2026, the EU Carbon Border Adjustment Mechanism (CBAM) ended its transition period and formally entered the charging stage. At present, the policy is mainly aimed at the carbon cost adjustment mechanism imposed on imports of cement, steel, aluminum, fertilizer, electricity and other industries with high carbon leakage risk, which is essentially a "carbon tariff".
Data show that CBAM came into force on October 1, 2023, with a transition period until 2025. During the transitional period, enterprises importing to the EU do not need to pay "carbon tax", but they need to declare it. Since 2026, enterprises entering Europe must submit annual CBAM declarations and purchase corresponding certificates to enter the EU market.
, The default carbon intensity is usually set on the basis of the average carbon intensity of the exporting country of the product , and the price increase is set proportionally on this basis . Where reliable data for the exporting country is not available, the default carbon intensity is based on the average carbon intensity of the 10 exporting countries with the highest carbon intensity for that commodity and with reliable data .
In short, the EU's default carbon intensity is very bad for importing companies.
Although photovoltaic module products are not explicitly included in the CBAM coverage list at present, key materials such as aluminium, steel and glass are all high-emission categories of high concern to the EU.
It is reported that there are voices in the EU industry calling for the inclusion of photovoltaic as a whole in the CBAM list to avoid unfair competition caused by "only raw materials but not finished products". Whether photovoltaic modules will be included in the
future is unknown, but in the context of the gradual clarity of relevant policy directions, it is necessary for Chinese photovoltaic enterprises to strengthen the capacity building of product carbon footprint accounting and data management in advance. To cope with potential institutional adjustment risks
For Chinese PV enterprises going to Europe, it is not only necessary to solve the "carbon footprint barrier", but also to deal with the increasingly severe industrial protection barriers in Europe. In May
2024, the Council of the European Union passed the Net Zero Industry Act (NZIA), which aims to promote the industrial deployment of net zero technologies needed by the EU to achieve climate goals and strengthen the EU's advantages in industrial green technologies. The bill explicitly requires that by 2030 , the manufacturing capacity of net zero technologies such as solar photovoltaic, wind energy and batteries in the EU will reach or approach 40% of the deployment demand. Although
the bill does not directly and explicitly target Chinese photovoltaic enterprises at the legal level, it has formed substantial constraints on the EU net zero industry, which is highly dependent on China, by setting up the proportion of local manufacturing, the resilience of the supply industry and the diversification of the system design, and to a certain extent, it has suppressed the development of Chinese photovoltaic enterprises in the European market.
the end of August, The Italian Ministry of Environment and Energy Security revised the "FerX Transitional Decree" and set a "non-price" pre-selection threshold, pointing out that components should not be assembled in China, and that batteries and inverters should not be of Chinese origin . And at least one other component in the list of solar technologies listed in EU Implementing Regulation (EU) 2025/1178 shall not originate in China .
Therefore, if Chinese photovoltaic enterprises want to continue to expand the European market, they must consider adjusting the supply chain layout. This will undoubtedly increase the production and manufacturing costs of Chinese photovoltaic enterprises, and even the market space of some photovoltaic enterprises will be compressed.
However, compared with NZIA's "implicit targeting", CBAM's directivity to China is more "explicit".
"Ignoring the tremendous achievements of China's green and low-carbon development, the European side has set a significantly higher basic default value for the carbon emission intensity of Chinese products and will increase it year by year in the next three years." This is not in line with China's current actual level and future development trend, and constitutes unfair and discriminatory treatment to China. On January 1, 2026, a spokesman for the Ministry of Commerce of China answered reporters'questions on the EU carbon border regulation mechanism.
Postscript
For Chinese photovoltaic enterprises, Europe is still the core overseas market that is difficult to replace in the short term. Especially in the current uncertain market prospects in the United States and the lack of effective support for emerging market demand, the European market is still the position that Chinese photovoltaic enterprises must compete for in the global competition.
Under the constraints of reality, Chinese photovoltaic enterprises can only respond under the framework of existing rules, through adjusting the supply chain layout, strengthening carbon footprint management, accelerating the transformation of green production and other actions, and constantly improve their compliance to meet the increasingly tightening institutional environment of the European Union.
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