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Requirement · LM-16

Require suppliers of in-scope net-zero technology products to submit a self-declaration or equivalent document demonstrating compliance with the origin requirements.

Suppliers of net-zero technologies under EU public contracts must comply, and this is not law yet.

Why it matters

This is a Commission proposal: it is not law yet, and it can change before it is.

  • It is Art. 34(4) (new Art. 25a(4) of Regulation (EU) 2024/1735), in the Industrial Accelerator Act. as of 2026-08-17
  • The act gives its timing as: From entry into force. as of 2026-08-17
  • It names 3 industries by name: Batteries and solar, Clean tech and Power. as of 2026-08-17
  • Compliance is checked by self-declaration, per tender. as of 2026-08-17
Addressee Suppliers of net-zero technologies under EU public contractsAct COM(2026) 100 final, 2026/0068 (COD)Article Art. 34(4) (new Art. 25a(4) of Regulation (EU) 2024/1735)Class Businesses

The rule

New — no predecessor
Trigger

Bidding into procurement covered by (new) Annex II of Regulation (EU) 2024/1735

Obligation

Require suppliers of in-scope net-zero technology products to submit a self-declaration or equivalent document demonstrating compliance with the origin requirements.

Who is affected

Addressee
Suppliers of net-zero technologies under EU public contracts
Class
Businesses
Sectors
Names Batteries and solar, Wind, heat pumps, hydrogen, Power and heat
Applies
From entry into force

Burden drivers

D1 — 1 of 7 marks fire on this provision.

Source text

Verbatim

Contracting authorities shall require economic operators supplying products falling within the scope of this Article to submit a self-declaration, or an equivalent document, demonstrating compliance with the requirements set out in this Article

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