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 Type | Status |
|---|---|
| Top Priority | |
| Type Certificate | |
| Spectrum Bands | |
| Import Changes (HS Codes) | |
| Standard Changes | |
| Product Changes | |
| Label Changes |