On Friday, 16 August 2024, the Ministry of Enterprises and Made in Italy (MIMIT) published, by Circular Prot. No. 0025877, the promised guidance on the Transition 5.0 plan. We set out the principles of this new incentive, among other things, in our last Circular No. 30/2024, to which we also attached the GSE guide for the various notifications. To today's circular we now attach the Ministry's 192-page guidance, which addresses numerous details of the new incentive. And it must be said at the outset: in view of the complexity, each individual investment project will ultimately have to be examined separately.
The most important points discussed in the guidance are:
- determination of the required energy saving with reference to individual production processes and with reference to the entire establishment; here, in particular, instructions are given on how to delimit the production process and, further, the „process concerned“, whereby in the extreme case even a single machine may constitute a self-contained process if an autonomous input and output can be demonstrated. This part of the guidance must certainly be studied analytically for each individual case;
- the guidance then also contains a series of worked examples for determining the required energy saving, and this part will be of interest above all to the technicians who have to prepare the „ex-ante“ and „ex-post“ certificates;
- the requirements for installations for the generation of renewable energies for own consumption are then explained, and here the chapter on photovoltaic installations is likely to be of particular interest, since in particular only modules of European production are recognised. We can only strongly recommend checking carefully the technical requirements set out in the guidance, and also the requirements regarding own consumption, before an order is placed;
- finally, according to the table of contents, explanations on the principle of do no significant harm (so-called DNSH) were also to be provided. In fact, however, the guidance offers no new insights on this point and refers to a further implementing provision which should be issued in the next few days. This point concerns all businesses which entail particular burdens on the environment;
- the circular finally contains practical guidance on the advance notifications and on the further notifications required, as well as on the checks to be expected;
- finally, the available tax credits are illustrated by means of several worked examples.
Finally, the Ministry announces that specific questions of detail are to be clarified by a further circular.
Please do not hesitate to contact us if you have any queries.
Yours faithfully,
Dott. Comm. Josef Vieider
Annex: MIMIT guidance
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