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Policy15 March 20264 min read

What the Net-Zero Industry Act Means for Energy Infrastructure Developers

By Pelorc Team

The European Union's Net-Zero Industry Act (NZIA) has fundamentally reshaped the landscape for energy infrastructure procurement across the continent. Since entering into force in June 2024, the regulation has introduced a new set of criteria that procurement authorities must apply when evaluating bids for clean energy projects — and developers who fail to adapt risk being shut out of an increasingly competitive market.

What is the Net-Zero Industry Act?

The NZIA is an EU regulation designed to scale up domestic manufacturing capacity for clean technologies. It sets a benchmark target of producing at least 40% of the EU's annual deployment needs for strategic net-zero technologies within the Union by 2030. The Act covers a broad range of technologies including solar photovoltaic, onshore and offshore wind, batteries and storage, heat pumps, electrolysers, carbon capture, and grid technologies.

But the NZIA is not just a manufacturing policy. It has direct and significant implications for how public tenders in the energy sector are evaluated, scored, and awarded. For developers and EPC contractors, this means a new set of rules to understand and evidence in their bids.

Key Provisions Affecting Tender Evaluation

Article 6 of the NZIA establishes sustainability and resilience criteria that contracting authorities are required — not merely encouraged — to incorporate into their procurement processes for net-zero technology projects. These criteria carry a minimum combined weighting of 15% to 30% in tender evaluations, depending on the technology and procurement type.

The sustainability criteria under Article 6 assess environmental performance across the lifecycle of the technology being procured. This includes carbon footprint of manufacturing processes, recyclability and durability of components, and resource efficiency. Bidders must provide verifiable evidence, not simply declarations, of their supply chain's environmental credentials.

Article 8 introduces pre-qualification requirements that can be applied before tender evaluation even begins. These allow contracting authorities to require bidders to demonstrate cybersecurity compliance, data security provisions, and the capacity to deliver projects in line with stated timelines. Critically, Article 8 also allows authorities to assess supply chain concentration risk — effectively penalising bids that rely on a single non-EU source for critical components.

The resilience criteria, also under Article 6, focus on supply chain diversification. If more than 65% of a specific net-zero technology consumed in the EU originates from a single third country, contracting authorities can apply a resilience contribution score. This means developers sourcing key components — such as solar panels, battery cells, or wind turbine generators — from a concentrated supply chain may receive lower evaluation scores, even if their price is competitive.

What This Means for Developers

For developers and EPC contractors bidding on European energy infrastructure projects, the NZIA introduces three critical changes to business as usual.

First, new scoring criteria must be addressed. Bids that previously competed primarily on price and technical merit now face additional evaluation dimensions. Sustainability and resilience scores can account for a significant portion of the total evaluation — enough to swing the outcome of a competitive tender. Developers need to understand how each procuring authority is interpreting and weighting these criteria, as implementation varies across member states.

Second, evidence requirements have expanded substantially. It is no longer sufficient to state that your supply chain is diversified or your manufacturing processes are sustainable. The NZIA requires verifiable documentation: lifecycle assessments, certificates of origin for key components, supply chain mapping documents, and carbon footprint calculations aligned with EU methodologies. Assembling this evidence package is time-consuming and requires coordination across multiple tiers of the supply chain.

Third, supply chain resilience documentation has become a strategic differentiator. Developers who can demonstrate multi-source procurement strategies, EU-based manufacturing partnerships, or contractual commitments with manufacturers investing in European production capacity will score higher under resilience criteria. This is a significant shift from a procurement culture that historically prioritised lowest cost.

Variations Across Member States

While the NZIA provides a regulatory framework at the EU level, implementation details are determined by individual member states and their contracting authorities. France, for example, has moved quickly to integrate NZIA criteria into its CRE (Commission de Regulation de l'Energie) tender rounds for solar and wind projects. Germany's Federal Network Agency (Bundesnetzagentur) has taken a more cautious approach, consulting with industry on how resilience criteria should be weighted against cost competitiveness.

This variation means developers operating across multiple jurisdictions must track implementation at the national and even regional level — a significant intelligence burden for bid teams already stretched thin.

How Pelorc Helps

Pelorc's platform is designed for exactly this kind of regulatory complexity. Our tender analysis engine identifies NZIA-relevant criteria in procurement documents, flags evidence requirements, and maps them against your company's existing certifications and supply chain documentation. When you upload a tender document, Pelorc highlights the sustainability and resilience scoring criteria, estimates your competitive position based on your company profile, and identifies gaps in your evidence package before you commit resources to a full bid.

In a market where regulatory requirements are evolving rapidly and the cost of a non-compliant bid is measured in months of wasted effort, structured pre-screening is not a luxury — it is a competitive necessity.


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