ORBIS Compliance

European Commission Publishes Article 25 NZIA Guidance on Sustainability, Cybersecurity and Supply-Chain Resilience in Public Procurement

Published /European Union

On August 31, 2026, the European Commission published Communication C/2026/4623 in the Official Journal of the European Union, providing guidance on the application of Article 25 of Regulation (EU) 2024/1735, the Net-Zero Industry Act (NZIA). The guidance explains how public authorities can apply sustainability, cybersecurity and supply-chain resilience considerations when procuring net-zero technologies.

It addresses the scope of Article 25, environmental requirements, possible cybersecurity conditions, verification of origin and resilience measures where high dependence on a particular source is identified. In specified high-dependence situations, the guidance indicates that value originating from the dominant source should not exceed 50% of the final product or 50% of the value added of its main components, and failure to demonstrate compliance may result in a burden of at least 10% of the value of affected net-zero products.

Industrial batteries may fall within Article 25 when they are themselves the subject of procurement, but the provision is not triggered solely because a battery is a component of an electric vehicle. The guidance is non-binding; Article 25(1) environmental requirements have applied since June 30, 2026.

Impact

Impact assessment: Medium. Key reasons: the Communication is non-binding but provides operational interpretation of Article 25 procurement requirements.

Who is affected?

Public procurers, net-zero technology suppliers, manufacturers and compliance teams.

Conclusion:

suppliers should assess environmental evidence, cybersecurity requirements and supply-chain origin information.

Regulatory Authority

European Commission

Regulatory Impact

Impact TypeStatus
Top Priority
Type Certificate
Spectrum Bands
Import Changes (HS Codes)
Standard Changes
Product Changes
Label Changes