Maaike Beenes, Senior Sector Specialist, Holland Solar ‘From good intentions to tangible steps’

Over the past year, solar energy companies have faced unpredictable and fluctuating policy both at the national and European levels. For example, European RBC legislation that was already being implemented by companies is now being changed in significant ways. Other issues like low energy prices and grid congestion also impact the business case for solar. These conditions have had an impact on capacity for topics like RBC. Yet Beenes is struck by how committed most companies remain to the goals of the International RBC Agreement for the Renewable Energy Sector. “During the due diligence training in March 2025, the trainer remarked: ‘It’s great to see how engaged the participants are’, compared to workshops she had given to companies from other sectors. This shows that despite the challenges, this topic is clearly alive.”

Due diligence baseline assessment provides direction

An important first milestone in the Agreement was the baseline assessment of due diligence policies among participating companies. Solar energy companies achieved an average score of just 33%, which was lower than their wind sector counterparts. “That score seems low,” Beenes acknowledges. “In part, it reflects the fact that most solar companies in the Agreement are relatively small, and did not have a lot of formal policies in place when joining the Agreement. Even though in some cases companies were already addressing issues, just not in formal policy documents. There is a lot of low hanging fruit, like formalising existing practice, that will lead to a higher score. The baseline served as a starting point. Companies now better understand where they stand and can take more targeted action. Significant progress is required in the later stages of the due diligence process, such as measuring and communicating impact. Encouragingly, nearly all companies are motivated to take those next steps.”

From ambition to action

In summer 2024, Holland Solar published a position paper on Circularity and RBC Growth Path. “In this paper, we propose non-price criteria that should be required of all companies in the sector on topics related to circularity and RBC. We also suggest how these criteria can be strengthened over time. Applying these criteria is important because it helps create a level playing field and prevent a race to the bottom on price that prevents companies from taking steps on sustainability,” Beenes explains. “Not everything has to be perfect tomorrow, but there must be a clear direction.”

A key proposal in the position paper is the incorporation of qualitative criteria into subsidies and public procurement. “Based on our input, the Dutch Ministry of Climate Policy and Green Growth is now investigating the introduction of a maximum CO₂ footprint requirement for solar panels in the SDE++ subsidy scheme. That would be a significant advancement.”

European legislation: opportunity and challenge

Another major development is the EU legislation banning products made using forced labour, which will be implemented in 2027. “The sector is eagerly anticipating this law,” says Beenes. “It is an important part of improving human rights in supply chains and will contribute to a level playing field However, many questions remain. “A lot is still unclear about exactly how the ban will be implemented. Especially smaller companies need clear guidance. The same applies to European CSR legislation like the CSRD and CSDDD. Here the Agreement plays a role in helping companies prepare, through knowledge-sharing and practical sessions.”

Moving forward together

The workstreams and collective projects within the Agreement are important to facilitate knowledge sharing and collective action members. “Collaboration is key,” she stresses. “These spaces also help bridge the gap between the expertise NGOs have and what companies are working on. It makes dialogue even more important. What I hope for in the coming year,” she continues, “is that companies will increasingly find each other. If you share the same supplier, you might be able to take joint action. It may be difficult or even impossible to achieve change alone, but together, you can have an impact.”

It is all about moving forward

Beenes notes that the RBC discussion is broadening. “Where it used to be mainly about forced labour, which is of course one of the most urgent issues to address, now there’s also attention to topics like worker welfare and biodiversity in solar parks, indicating growing maturity.” And that’s necessary because the challenges persist: “The solar energy sector depends on imports, with all the associated risks. Companies want to take action, and the Agreement really helps with that. In the end, it’s all about moving forward — even if it’s one small step at a time.” Beenes concludes: “Sometimes it is difficult to find the perfect solution, especially in cases where companies have little leverage over issues deep in their supply chain. But even in those cases it is important to keep taking steps in the right direction. And as a sector, we must keep moving.”