BWO Discussion Paper: Adjustments for the national implementation of the Net Zero Industry Act (NZIA) in Germany

The German Offshore Wind Energy Association (BWO) supports the Net Zero Industry Act's (NZIA) goal of a strong and resilient value chain in Europe. This must be strengthened to ensure competitiveness not only within the EU but also internationally. This requires clear, simple, and unbureaucratic regulations that simplify and reduce investment costs.

The position paper identifies key levers for the Federal Government in national implementation and provides recommendations for action on their design:

  • Phased application: The application of the NZIA criteria should initially be limited to a subset of offshore wind auctions in order to gain experience and minimize the risk of undesirable developments.
  • Practical criteria: The criteria themselves must be designed to be unbureaucratic, predictable, and investment-friendly. They should build on existing national systems, and the number of non-price criteria should be limited.
  • Strengthening resilience: A resilience criterion should be introduced as a mandatory prequalification for manufacturers to reduce dependencies in the supply chain.
  • Flexibility in times of bottlenecks: In order not to jeopardize the further expansion of offshore wind energy, clear scenarios for supply bottlenecks and price increases must be defined and flexibility in the auction design must be enabled.
  • Ensuring cybersecurity: The implementation of the NZIA requirements in the area of ​​cybersecurity should be carried out in close coordination with existing regulations (e.g. NIS2 Directive) in order to avoid duplication and minimize administrative burden.
  • Pragmatic proof of component origin: Proof of component origin should only be provided at the time of project implementation in order to avoid early and potentially disadvantageous lock-in to certain manufacturers.
  • Quantitative assessment: Wherever possible, the criteria should be assessed quantitatively to increase transparency and legal certainty.
  • Clear responsibilities: Before the auctions start, the responsibilities for compliance with the criteria and the corresponding penalties must be clearly defined in order to increase planning security for project developers.

The entire position paper can be found here:

Position paper: Adjustments for the national implementation of the Net Zero Industry Act in Germany