The Bundesverband Windenergie Offshore (BWO) urges the German government to adopt a pragmatic approach to implementing the Net-Zero Industry Act (NZIA), aiming to support a resilient and competitive offshore wind supply chain in Europe without overburdening the sector with unnecessary red tape.
“The NZIA offers the opportunity to strengthen the offshore wind value chain in Europe. However, for it to be effective, implementation must be agile and practical,” states Stefan Thimm, Managing Director of BWO.
In its position paper released on August 21, BWO identifies specific “adjustment levers” essential for the national rollout of the NZIA in Germany. The association emphasizes that clear, investment-friendly rules are necessary to avoid risks of under-subscription in auctions and to maintain project delivery timelines.
One of BWO’s central recommendations is to apply non-price criteria to only a portion of the annual auction volume, proposing a cap of 6 GW instead of a 30% share, as long as the overall auction volume exceeds 20 GW. This selective application would distribute risk more evenly across the sector. “Spreading criteria over a partial volume helps protect the supply chain from potential disruptions,” explains Thimm.
BWO strongly supports the introduction of the resilience criterion as a mandatory prequalification requirement for manufacturers. This approach, the organization argues, would foster long-term supply chain reliability while avoiding overcomplexity for project developers. At the same time, flexibility must be granted to account for supply shortages or unexpected price hikes. The association calls for clear scenarios and actionable provisions to allow developers to adapt procurement strategies when necessary.
In terms of documentation and proof of component origin, BWO advocates for verification at the project realization stage rather than at the auction phase. The association warns that requiring early commitments to specific suppliers could limit competition and strain component manufacturers. Instead, a self-commitment at the bidding stage—combined with robust verification during execution—would strike a better balance between compliance and investment certainty.
“If the additional criteria simply increase bureaucracy and costs without delivering tangible resilience gains, the NZIA will fail to meet its objectives,” Thimm warns. He argues that existing national frameworks, such as those outlined in the WindSeeG, should be used as a basis to streamline implementation.
The association also proposes that quantitative metrics should be used wherever possible to assess compliance with the criteria, as they improve transparency and speed up evaluation processes. It cautions against using relative assessments based on the “highest bidder,” which it considers legally uncertain and potentially counterproductive.
On the issue of compliance enforcement, BWO urges authorities to apply penalties proportionally and only when delays or breaches are clearly attributable to the developer. The association highlights the importance of clearly assigning responsibilities among developers, grid operators, and suppliers. It also calls for defined “force majeure” scenarios to avoid unfair penalties in cases of disruptions beyond developers’ control.
“Our paper outlines ways to facilitate investment while strengthening supply security at the same time,” concludes Thimm. With offshore wind expected to play a central role in Europe’s decarbonization strategy, BWO warns that poorly designed implementation of NZIA could stifle progress rather than accelerate it.
