New EU guidance on renewable energy auctions and wind projects

The European Commission has recently provided further guidance on the application of the non-price criteria applicable to renewable energy auctions under the EU Net-Zero Industry Act (“NZIA”). Although the underlying legislation was adopted in 2024 and 2025, the issue has gained renewed practical significance following the Commission’s publication, on 22 July 2026, of detailed guidance on the application of the NZIA. The guidance is particularly relevant for wind energy projects relying on Chinese-origin turbines or components.

The NZIA entered into force in June 2024 and aims, among other things, to strengthen the EU’s manufacturing capacity for net-zero technologies and reduce strategic dependencies. It requires Member States to apply certain non-price criteria in renewable energy auctions. Since 30 December 2025, these criteria apply to at least 30% of the auctioned volume per year in each Member State, or 6 GW per year, whichever is lower. The detailed rules were subsequently established by Commission Implementing Regulation (EU) 2025/1176 (“regulation”), adopted in May 2025. The regulation specifies pre-qualification and award criteria relating, among other matters, to responsible business conduct, cybersecurity and data security, the ability to deliver projects fully and on time, sustainability and supply-chain resilience.

The Commission’s July 2026 guidance was published specifically in response to questions raised by national authorities and market participants since the rules became applicable. Its purpose is to promote a consistent and proportionate application of the requirements across the EU and to provide further clarity on their practical application in renewable energy auctions. For wind energy, the resilience criterion can have a direct impact on the use of Chinese technology. Under the regulation, where the relevant conditions are met, at least 75% of the final products forming part of a bid must comply with specified restrictions concerning Chinese-origin equipment. For onshore wind, this means, in particular, that the turbine itself may not originate in China, no more than three specified main components may originate in China, and the drivetrain, including the generator, may not originate in China. The Commission’s July 2026 guidance illustrates the rule by referring to a project with 100 turbines, of which at least 75 would have to comply with these requirements.

These provisions are particularly relevant because they demonstrate how the resilience requirements can have a direct commercial impact on the choice of turbine and component suppliers. A project using equipment with a high degree of Chinese-origin content may therefore be less competitive, or may face difficulties meeting applicable pre-qualification or award requirements, depending on the design of the relevant auction. Importantly, the NZIA does not impose a general prohibition on Chinese wind turbines or a blanket requirement to use European-manufactured equipment. Rather, it requires specified non-price criteria to be incorporated into relevant renewable energy auctions. The resilience criterion can consequently favour projects with more diversified supply chains and reduce the competitive advantage of bids relying heavily on Chinese-origin technology.

These developments are particularly relevant for the Hungarian wind energy market, which is entering a period of renewed expansion following the relaxation of restrictions on wind farm development and the introduction of new support mechanisms. Hungary’s first new wind capacity auction in more than a decade was launched in 2024, and the projects awarded capacity under that process are expected to contribute to an increase in installed wind capacity.

As further capacity is allocated through competitive auctions, the application of NZIA’s non-price criteria may become an increasingly relevant consideration for project developers when selecting turbine manufacturers and structuring their supply chains. The choice of turbine supplier may therefore need to be assessed not only from a technical and pricing perspective, but also in light of the origin of the turbine and its key components, the applicable resilience requirements and the potential impact on the project’s eligibility and competitiveness in the relevant auction. Developers and investors considering future Hungarian wind projects should accordingly take these requirements into account at an early stage, as changing the turbine supplier or supply-chain structure at a later stage of development may have high cost and timing implications.