New recycling requirements for wind turbine blades: What contracting authorities need to consider from 30 June 2026

By adopting Implementing Regulation (EU) 2026/718, the European Commission has implemented a key component of the Net-Zero Industry Act (NZIA). For the first time, binding sustainability requirements will apply to the public procurement of wind turbines. The Regulation was published in the Official Journal of the European Union on 23 March 2026 and applies to procurement procedures launched from 30 June 2026.

The key aspects are outlined below.

I. Legal basis: the Net-Zero Industry Act (NZIA)

The European Net-Zero Industry Act (Regulation (EU) 2024/1735), which entered into force on 29 June 2024, establishes, in Article 25, a contribution to sustainability and resilience in public procurement procedures. Under this provision, the European Commission is required to adopt binding minimum environmental sustainability requirements by means of implementing acts where procurement procedures fall within the scope of Directives 2014/23/EU, 2014/24/EU or 2014/25/EU and concern net-zero technologies.

II. Implementing Regulation (EU) 2026/718

Implementing Regulation VO (EU) 2026/718  supplementing Regulation (EU) 2024/1735 "with regard to minumim environmental sustainability requirements for public procurement procedures concerning certain net-zero technologies" entered into force on the twentieth day following its publication and applies from 30 June 2026 (Article 3, second sentence, of Regulation (EU) 2026/718). 

The deferred date of application is intended to provide contracting authorities with sufficient time to make the necessary adjustments to their procurement procedures. 

In its current form, the Regulation is limited to onshore and offshore wind technologies, as suitable Union-wide methods and measurement procedures are not yet available for a significant number of the other net-zero technologies listed in the NZIA.

III. 70 per cent recycling rate for rotor blades

The key requirement of the Regulation is that the rotor blades of onshore and offshore wind turbines must achieve a recycling rate of at least 70 per cent (Article 2(1), first sentence). The recycling rate is calculated on the basis of the proportion by weight of recyclable material. Rotor blades account for approximately 15 per cent of the total mass of a wind turbine and consist of complex composite materials made of reinforced fibres and polymer matrices (Recital 10). According to current estimates, the volume of composite waste generated from decommissioned rotor blades is expected to reach approximately 400,000 tonnes by 2040.

The assessment of recyclability is based on European Standard EN 45555:2019. A technology readiness level of six (TRL 6) is considered sufficient in order to support innovative recycling technologies as well (Recitals 12 and 13).

IV. Time of verification: completion of contract performance

The required recycling rate for rotor blades must be demonstrated no later than upon completion of contract performance (Article 2(1), third sentence), rather than during he award procedure itself. 
This approach allows contractors to implement the requirements during contract execution and to take account of technological developments arising over the course of performance.

V. Implementation under German public procurement law

Under public procurement law, the requirement may be implemented in two ways (Article 2(2) of the Regulation):

• as a contract performance condition (Section 128(2) GWB), or
• as a technical specification within the procurement documents (Section 28 SektVO, Section 31 VgV and Section 15 KonzVgV).

Implementation must be objective, transparent and non-discriminatory and comply with the European Union’s international obligations (Article 2(3)). For contracting authorities in Germany, it is advisable to clearly document the chosen form of implementation within the procurement documents.

VI. Background 

Although wind power projects are comparatively more likely to fall within the scope of EU public procurement law (Recital 9), the Regulation specifically focuses on rotor blades, as these present the greatest recycling challenge.

Whilst 80 to 95 per cent of the total mass of a wind turbine – predominantly steel and iron – can generally be recycled, rotor blades consist of complex composite materials that are considerably more difficult to recycle (Recital 10).

The Implementing Regulation does not apply to pure lease agreements. Where land is leased to a wind farm operator without further specifications, the operator remains free to decide whether to implement a recycling quota such as that provided for in the Regulation.

Guidance on the distinction between pure lease agreements and (construction) concessions potentially subject to procurement requirements can be found, amongst other sources, in the guidance issued by the LandesEnergieAgentur Hessen (LEA).

Even in the case of pure lease agreements, wind turbine operators remain subject to extensive federal and state-law obligations concerning dismantling and recycling, including Section 35(5), sentences 2 and 3 of the German Building Code (BauGB), supplemented by the Circular Economy Act (KrWG) and the Federal Immission Control Act (BImSchG).

Against this background, DIN 4866 “Demolition and dismantling of wind turbines” is of particular relevance. The standard was adopted as a full DIN standard in the second quarter of 2026 following the conversion of DIN SPEC 4866:2020-08.

DIN 4866 defines responsibilities, procedures and assessment criteria relating to the demolition and dismantling of wind turbines and is intended to serve as a practical guidance document for clients, planners and contractors. However, it should be noted that DIN 4866 constitutes a recommended industry standard rather than a legally binding provision.

Nevertheless, indirect binding effects may arise, for example where authorities use the standard as a benchmark or where contractual provisions incorporate it as a binding performance standard.

VII. Conclusion and recommendations for action

Implementing Regulation (EU) 2026/718 marks the first time that environmental sustainability requirements have become binding in the public procurement of wind turbines.

From 30 June 2026 onwards, contracting authorities and sectoral contracting authorities should ensure that the 70 per cent recycling requirement for rotor blades is appropriately incorporated into their procurement documents, either as a contract performance condition or as a technical specification.

Further implementing acts, particularly in relation to photovoltaic products, are currently being prepared. Contracting authorities should therefore monitor developments closely.

We will keep you updated.