About
The Net-Zero Industry Act (NZIA) is one of the three key legislative initiatives of the Green Deal Industrial Plan, together with the Critical Raw Materials Act and the Electricity Market Design Reform. NZIA establishes a framework of measures to strengthen Europe's net-zero technology manufacturing ecosystem.
The aim is that the Union's overall strategic net-zero technologies manufacturing capacity approaches or reaches at least 40% of annual deployment needs by 2030. Some of the key net-zero technologies that are listed in the NZIA are:
- solar photovoltaic and solar thermal,
- onshore wind and offshore renewables,
- batteries and energy storage,
- heat pumps and geothermal energy,
- hydrogen technologies, including electrolysers and fuel cells,
- sustainable biogas and biomethane,
- Carbon capture and storage (CCS) and
- electricity grid technologies.
One of the means to accelerate the transition to climate neutrality is streamlining administrative and permit-granting processes, including single points of contact, online accessibility of information and shorter duration of the permit-granting process. The permit-granting process for net-zero technology manufacturing projects shall not exceed 12 months for projects with a yearly manufacturing capacity of less than 1 GW and 18 months for projects over 1 GW or more.
The NZIA also allows for the establishment of net-zero strategic projects. Net-zero strategic projects enjoy national ‘priority status’ under the NZIA Regulation, ensuring rapid administrative treatment and faster permitting. These projects also receive additional focus within the Net-Zero Europe Platform, including financing advice. Urgent treatment in judicial and dispute resolution procedures, and simplified assessments for specific environmental legislation derogations, are also provided if necessary. Projects can apply for this status through a dedicated application process which opened at the end of July 2024.
The NZIA also sets a union level objective of CO2 injection capacity, where an annual injection capacity of at least 50 million tonnes of CO2 shall be achieved by 2030 in storage sites. The Act imposes obligations on EU oil and gas production licensees to contribute to the Union-wide target, and the individual contributions shall be calculated pro-rata on the basis of each entity's share on the Union's crude and oil and natural gas production from 1 January 2020 to 31 December 2023. The contribution shall consist of CO2 injection capacity in a storage site permitted by the CCS Directive and available to the market by 2030. In order to meet their targeted volumes of available injection capacity, the companies may (i) invest in, or develop CO2 storage projects alone or in cooperation, (ii) enter into agreements with other oil companies or (iii) enter into agreements with third-party storage project developers or investors to fulfil their contribution.
In the Norwegian Government's position to the proposal for the NZIA, the Government stated that the obligations on oil and gas producers may be understood as imposing a financial obligation with retroactive effect that challenges fundamental principles in national and international law.
The Act also implements new mandatory rules for access to markets to help boost demand of renewables. The rules contains sustainability and resilience contribution in public procurement procedures and auctions to deploy renewable energy sources. Another objective with the NZIA is enhancing skills for quality job creation. The Act establishes Net-Zero Industry Academies to develop learning content for education and training providers in EU countries.
The Net-Zero Industry Act establishes the ‘Net-Zero Europe Platform’, a governance body that comprises the Commission and EU countries to monitor progress, discuss developments, and engage with civil society stakeholders. The platform advises on financing for net-zero strategic projects and engages in international net-zero industrial partnerships to facilitate global clean energy transition.
In January 2025, the Commission opened a series of calls for public feedback on four pieces of draft secondary legislation to implement the NZIA:
- Guidelines on strategic projects (implementing act)
- Delegated act on primarily used components under the Net-Zero Industry Act
- List of net-zero technology final products and their main specific components (implementing act)
- Implementing Act on non-price criteria
The three implementing and one delegated acts will support businesses and public authorities in identifying the types of projects that can qualify for faster permitting processes and the “net-zero strategic project” status. They will help ensure that the implementation of the NZIA is consistent and transparent across Member States, notably thanks to a series of common assessment criteria, as well as a list of the components of the key clean technologies that are automatically supported by the regulation.
These acts also set out a list of main components, the supply of which will have to be diversified as part of public procurement, auctions for green power and other support schemes, in those cases where the EU is highly dependent on a single source of their supply. For renewable energy auctions, these acts further define non-price criteria such as sustainability, resilience, cybersecurity, and timely delivery. This will be key not only to support the EU's efforts to diversify its sources of supply for technologies enabling decarbonisation, but also to foster production in the domestic clean energy sector and further attract clean investments to Europe.
Who does it impact?
EU Member States.
The Act is marked as EEA relevant by the EU and under scrutiny for incorporation into the EEA Agreement by Iceland, Liechtenstein and Norway.
Status: In force
The regulation was adopted by the Council of the European Union 27 May 2024 and entered into force 28 July 2024.
Relation to other initiatives and regulations
The NZIA represents one of the key initiatives announced by the Green Deal Industrial Plan to create a regulatory environment supporting the scale-up of the net-zero industry in the EU.
It can also with advantage be seen in connection with the European Critical Raw Materials Act. The two pieces of legislation were proposed simultaneously and are both part of the value chain for clean energy production. They share the same overarching goal to facilitate increased production and self-sufficiency in the EU of zero-emission technology products and critical raw materials, by establishing a common regulatory framework in the EU.
The regulation is also accompanied by the European Hydrogen Bank and the reform of the EU's Electricity Market Design.
Participants
Member States of the European Union.
Thommessen's comments
The Norwegian government is now in the process of clarifying the EEA relevance of the Act, and whether or not to incorporate the NZIA into the EEA Agreement. The regulation was sent out for public consultation, with a consultation deadline in the end of October 2024. The Ministry of Trade, Industry and Fisheries requested the views of the consultation bodies on the consequences the regulation is expected to have for Norwegian actors in various sectors. This was stated to be particularly relevant if the regulations is incorporated into the EEA Agreement.
Especially the CO2 injection capacity objective is a hot topic in the public discussions, as well as in the consultation responses. NZIA must be incorporated into the EEA Agreement before storage sites on the Norwegian continental shelf can be used as a part of achieving the union level objective. A statement in the preamble to the Act, saying: "When this Regulation is incorporated into the European Economic Area Agreement, the Union target of 50 million tonnes of annual operational CO2 injection capacity by 2030 will be adjusted accordingly" has also sparked some uncertainty as to which obligations that might be imposed on Norwegian oil and gas companies. It is still unclear how the target will be adjusted if the NZIA is incorporated into the EEA Agreement.
If NZIA is implemented into Norwegian law, Offshore Norge believes that the CO2 injection capacity obligation that Norway commits to must only be an addition beyond the EU's target of 50 million tons of CO2 per year by 2030. The additional target for Norway must be realistic and based on actual needs for CO2 storage from capture projects in Norway, and it is only the addition that can be allocated to the licensees in Norway based on production. CO2 storage sites on the Norwegian continental shelf must be allowed to be used to meet the EU's target of 50 million tons of CO2 per year by 2030 on commercial terms, and not allocated to the licensees in Norway.
On March 19, the Commission sent out a draft Delegated Regulation regarding provisions on the contributions of oil and gas producers to the EU's 2030 storage target for consultation. The draft addresses provisions related to the Net Zero Industry Act (NZIA), which is under consideration for incorporation into the EEA. The Commission Delegated Regulation ((EU) 2025/1477) was adopted in May and entered into force in July. The Delegated Regulation specifies how the contributions of the entities is calculated and how they will report on their progress.