Commission Implementing Regulation (EU) 2025/1178of 23 May 2025on laying down rules for the application of Regulation (EU) 2024/1735 of the European Parliament and of the Council as regards the list of net-zero technology final products and their main specific components for the purposes of assessing the contribution to resilience

Commission Implementing Regulation (EU) 2025/1178 of 23 May 2025 on laying down rules for the application of Regulation (EU) 2024/1735 of the European Parliament and of the Council as regards the list of net-zero technology final products and their main specific components for the purposes of assessing the contribution to resilience THE EUROPEAN COMMISSION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Regulation (EU) 2024/1735 OJ L, 2024/1735, 28.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1735/oj. of the European Parliament and of the Council of 13 June 2024 on establishing a framework of measures for strengthening Europe’s net-zero technology manufacturing ecosystem and amending Regulation (EU) 2018/1724, and in particular Article 29(2), first subparagraph, thereof, Whereas: (1) Regulation (EU) 2024/1735 establishes a common legal framework aimed at strengthening the Union’s resilience and security of supply of net-zero technologies, by promoting diversification of their supply chains and enhancing the domestic manufacturing capacity of net-zero technologies. (2) In accordance with Articles 25, 26 and 28 of Regulation (EU) 2024/1735, where there is evidence of a significant dependency on third countries with regard to the Union’s supply of net-zero technologies, non-price criteria, such as the contribution to resilience, are to be applied in public procurement, renewable energy auctions or other forms of public intervention. For the purposes of assessing the contribution to resilience, the Commission is to adopt an implementing act providing a list of the net-zero technology final products and their main specific components. The list serves to assess the contribution to resilience. (3) The Annex to Regulation (EU) 2024/1735 includes a list of net-zero technology final products and specific components primarily used for the production of net-zero technologies. (4) The main specific components included in the list provided in the Annex to this Regulation should include only those specific components primarily used for the production of net-zero technologies that are essential to ensure the Union’s resilience, in line with the provisions on access to markets set out in Articles 25 to 28 of Regulation (EU) 2024/1735. (5) Specific components primarily used for the production of net-zero technologies should be considered as essential to ensure the effective implementation of the resilience contribution in public procurement, renewable energy auctions and other forms of public intervention if they contribute significantly to the final product’s value, or if they are critical in supporting the resilience of the overall supply chain. (6) In order to give Member States sufficient time to prepare for the requirements relating to the resilience contribution, the application of this Regulation should be deferred. (7) In accordance with Article 29(2), second subparagraph, of Regulation (EU) 2024/1735, the Commission is to provide updated information on the shares of the Union supply originating in different third countries for net-zero technologies and their main specific components.

(8) The measures provided for in this Regulation are in accordance with the opinion of the committee established by Article 45(1) of Regulation (EU) 2024/1735, HAS ADOPTED THIS REGULATION:

Article 1

The list of net-zero technology final products and their main specific components to assess the contribution to resilience is set out in the Annex.

Article 2

This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 30 December 2025. This Regulation shall be binding in its entirety and directly applicable in all Member States. Done at Brussels, 23 May 2025. For the Commission The President Ursula von der Leyen

Annex

ANNEX List of net-zero technology final products and their main specific components for the purposes of assessing the contribution to resilience The term equivalent refers to similar steps or key enabling technologies needed for thin-film, organic, tandem or other PV technologies. Batteries as defined in Article 3(13), (14) and (15) of Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries. The term electric road systems (also known as dynamic charging) refers to equipment along the road that supplies power to vehicles while they are in motion. This final product includes both conductive and inductive charging. The term heater refers to low (up to 200 oC) and medium (200 to 500 oC) temperature applications. The term furnace refers to high (500 to 1000 oC) and very high (above 1000 oC) temperature applications. Sub-categories of net-zero technologiesFinal productsMain specific componentsSolar technologiesPhotovoltaic (PV) technologies Solar PV systems PV grade polysilicon PV grade silicon ingots or equivalent PV wafers or equivalent PV cells or equivalent Solar glass PV modules PV inverters PV trackers and their specific mounting structures Solar thermal electric technologies Concentrated solar power (CSP) plants CSP reflectors CSP trackers and their specific mounting structures CSP receivers (point or line) Solar thermal technologies Solar thermal systems Solar thermal collectors (including flat-plate, evacuated tube, concentrating systems and air collectors) Solar thermal absorbers Solar glass Solar thermal trackers and their specific mounting structures Other solar technologies PV-thermal collectors (PVT) Onshore wind and offshore renewable technologiesOnshore wind technologies Onshore wind turbines Nacelles (assembly) Rotor hubs Main, yaw and pitch bearings Direct drive drivetrains (including generator) and/or gearbox drivetrains (including generator) Permanent magnets of wind turbines Gearboxes of wind turbines Blades Towers Offshore wind technologies Offshore wind turbines Nacelles (assembly) Rotor hubs Main, yaw and pitch bearings Direct drive drivetrains (including generator) and/or gearbox drivetrains (including generator) Permanent magnets of wind turbines

Gearboxes of wind turbines Blades Towers Foundations/floaters Other offshore renewable technologies Tidal stream energy technologies Wave energy technologies Battery and energy storage technologiesBattery technologies Batteries Battery packs Battery modules Battery cells Cathode active materials Anode active materials Electrolytes Separators Current collectors (including thin copper, aluminium, nickel and carbon foils) Battery management systems (BMS) Battery thermal management systems (BTMS) Electrochemical storage technologies Ultracapacitors/supercapacitors Redox flow energy storage Electrolytes Separators Collectors Electrode plates Gravitational storage technologies Pumped hydro storage Reversible hydro turbines and pump runners Distributors with guide vanes Thermal energy storage technologies Thermal energy storage systems Sensible heat storage and latent heat storage mediums (including phase change materials and molten salts) Thermochemical storage materials Compressed/liquefied gas energy storage technologies Compressed air energy storage Liquid air energy storage Other energy storage technologies Flywheel energy storage Flywheel rotors Heat pumps and geothermal energy technologiesHeat pump technologies Heat pumps Heat pumps Four-way valves Scroll compressors/heat pump rotary compressors Geothermal energy technologies Geothermal power plants Geothermal direct use systems Heat exchangers resistant to geothermal corrosive operating conditions Submersible pumps resistant to geothermal corrosive operating conditions Hydrogen technologiesElectrolysers Alkaline electrolysers (AEL) Stacks Separators (diaphragm or membranes tailored for water electrolysis) Bipolar plates and end plates Electrodes Proton exchange membrane electrolysers (PEMEL) Stacks Membrane electrode assemblies (3-layer)/catalyst-coated membranes Porous transport layers/gas diffusion layers Bipolar plates and end plates Anion exchange membrane electrolysers (AEMEL) Stacks Membrane electrode assemblies (3-layer)/catalyst-coated membranes Porous transport layers/gas diffusion layers Bipolar plates and end plates Solid-oxide electrolysers (SOEL) Stacks Electrolyte and electrodes High-temperature gaskets/sealings Interconnectors/meshes and end plates Hydrogen fuel cells Proton exchange membrane fuel cells (PEMFC) Stacks Membrane electrode assemblies (3-layer)/catalyst-coated membranes Porous transport layers/gas diffusion layers Bipolar plates and end plates Solid-oxide fuel cells (SOFC) Stacks Electrolytes and electrodes High-temperature gaskets/sealants Interconnectors/meshes and end plates Other hydrogen technologies Hydrogen transmission and distribution networks Hydrogen compressors Hydrogen refuelling stations Pipelines for hydrogen transmission and distribution Hydrogen storage facilities Onboard hydrogen storage tanks Hydrogen stationary storage tanks Plants for the conversion and extraction of hydrogen into and from ammonia Ammonia crackers Sustainable biogas and biomethane technologiesSustainable biogas technologies

Sustainable biogas plants Anaerobic digesters/fermentation tanks Sustainable biomethane technologies Sustainable biomethane plants Anaerobic digesters/fermentation tanks Biomethane upgrading units CCS technologiesCarbon capture technologies Absorption capture Adsorption capture Membranes capture Solid cycles capture Cryogenics capture Direct air capture CO2 compressors Carbon storage technologies Electricity grid technologiesElectricity grid technologies Onshore substations Offshore substations Cables and lines for electricity transmission and distribution, and cables connecting net-zero technologies to the electricity grid (overhead lines, underground and undersea cables, including HVDC and HVAC) Switchgears Circuit breakers Protection relays Power transformers Disconnectors Busbar systems Electric cabinets Offshore substations Inverters Converters Electricity transmission and distribution towers Electricity transmission and distribution towers Electrical conductors (including advanced conductors and high-temperature superconductors) Insulators Cables, lines and associated accessories for electricity transmission and distribution, and cables connecting net-zero technologies to the electricity grid (overhead lines, underground and undersea cables, including HVDC and HVAC) Cables and lines for electricity transmission and distribution, and cables connecting net-zero technologies to the electricity grid (overhead lines, underground and undersea cables, including HVDC and HVAC) Electrical conductors (including advanced conductors and high-temperature superconductors) Insulators Power transformers Power transformers Transformer cores Transformer windings Transformer tap changers Electric charging technologies for transport Electric vehicle supply equipment Electric road systems Shore-side electricity supply equipment Overhead contact lines Electric air transport supply equipment Electric vehicle supply equipment Shore-side electricity supply equipment Electric air transport supply equipment Technologies to digitalise the grid and other electricity grid technologies High- and medium-voltage power electronics equipment and components (including DC technology) Flexible alternating current transmission system (FACTS) technologies Smart meters/advanced metering and control infrastructures High- and medium-voltage power electronics equipment and components (including DC technology) Flexible alternating current transmission system (FACTS) technologies Smart meters/advanced metering and control infrastructures Nuclear fission energy technologiesNuclear fission energy technologies Nuclear fission power plants Fuel elements Reactor vessels Primary piping and valves Steam turbines Steam generators Safety systems Monitoring, instrumentation and control systems Nuclear fuel cycle technologies Nuclear fuel cycles Centrifuges Gas handling and flow control systems Chemical processing equipment Waste vitrification equipment Transportation, storage and disposal cylinders, containers and casks

Heavy water Safety systems Monitoring, instrumentation and control systems Sustainable alternative fuels technologiesSustainable alternative fuels technologies Sustainable alternative fuels plants Thermochemical, electrochemical, chemical and biochemical/biological reactors to convert biomass, recycled carbon fuels into bio-intermediates and/or syngas Reactors and post-treatment units to convert bio-intermediates and/or syngas and recycled carbon fuels into sustainable alternative fuels Hydropower technologiesHydropower technologies Hydro turbine systems Hydro turbine runners Distributors with guide vanes Other renewable energy technologiesOsmotic energy technologiesAmbient energy technologies, other than heat pumpsBiomass technologies Pellet mills Briquetting presses Pellet dies Briquetting compaction chambers Landfill gas technologiesSewage treatment plant gas technologiesOther renewable energy technologiesEnergy system-related energy efficiency technologiesEnergy system-related energy efficiency technologies Energy management systems (EMS) Building automation systems (BAS) Automated demand response (ADR) Variable speed drives Organic Rankine cycle (ORC) power systems EMS BAS ADR Variable speed drives ORC turbines Heat and cold grid technologies Heating and cooling distribution system pipework Other energy system-related energy efficiency technologiesRenewable fuels of non-biological originRenewable fuels of non-biological origin (RFNBO) technologies RFNBO plants Reactors to convert H2 and CO2 or N2 into syngas or alcohols Reactors to convert syngas or alcohols into RFNBOs Biotech climate and energy solutionsBiotech climate and energy solutions Microorganisms and microbial strains (including but not limited to bacteria, yeasts, microalgae, fungi and archaea) that are used to pretreat and convert feedstock into biofuels, recycled carbon fuels and renewable fuels, bio-based and recycled carbon chemicals, biopolymers, bio-based materials and bio-based products Enzymes (including but not limited to amylase and cellulase) that are used to pretreat and convert feedstock into biofuels, bio-based chemicals, bio-based materials and bio-based products, or that are used to catalyse reactions in chemical processes Biopolymers Microorganisms and microbial strains (including but not limited to bacteria, yeasts, microalgae, fungi and archaea) that are used to pretreat and convert feedstock into biofuels, recycled carbon fuels and renewable fuels, bio-based and recycled carbon chemicals, biopolymers, bio-based materials and bio-based products Enzymes (including but not limited to amylase and cellulase) that are used to pretreat and convert feedstock into biofuels, bio-based chemicals, bio-based materials and bio-based products, or that are used to catalyse reactions in chemical processes Biopolymers Transformative industrial technologies for decarbonisationTransformative industrial technologies for decarbonisation Electric arc furnaces Hydrogen-ready direct-reduced iron reactors

Submerged arc furnaces Open slag bath furnaces Flash calciners Industrial electric boilers Industrial induction heaters/furnaces Industrial infrared heaters/furnaces Industrial microwave heaters/furnaces Industrial radio-wave heaters/furnaces Industrial resistive heaters/furnaces Graphite or carbon electrodes for electric furnaces Flash calciners Industrial electric boilers Industrial induction heaters/furnaces Industrial induction coils Industrial infrared heaters/furnaces Industrial infrared emitters Industrial microwave heaters/furnaces Industrial magnetrons Industrial radio-wave heaters/furnaces Radio frequency generators Industrial resistive heaters/furnaces Molybdenum electrodes for electric furnaces CO2 transport and utilisation technologiesCO2 transport technologies CO2 transport infrastructure CO2 compressors CO2 utilisation technologies Thermochemical utilisation Electrochemical utilisation CO2 electrolysers Wind and electric propulsion technologies for transportWind propulsion technologies Flettner rotors Suction wing sails Towing kites Rigid and semi-rigid wing sails Electric propulsion technologies Electric propulsion systems for road and off-road transport Electric propulsion systems for rail transport Electric propulsion systems for waterborne transport Electric propulsion systems for air transport Transport propulsion electric motors Permanent magnets of transport electric motors Transport battery packs Transport fuel cells Transport inverters Electric propulsion high voltage power distribution units Onboard chargers Onboard hydrogen storage tanks Other nuclear technologiesOther nuclear technologies (such as nuclear fusion technologies)