§9EEG

Paragraph 9 of the German Renewable Energy Act (Erneuerbare-Energien-Gesetz, EEG) is a regulatory framework that defines the controllability and grid integration of renewable energy systems. It outlines the technical requirements for providing a reliable energy supply and mandates the use of smart metering and control systems for certain systems.

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What is paragraph 9 EEG?

Paragraph 9 (§9 or Section 9) of the Renewable Energy Act (Erneuerbare-Energien-Gesetz) EEG is a modification of the act that places new technical requirements on the operation of renewable energy generation plants from January 2025 onwards, specifically regarding monitoring, control and grid stability. It aims to ensure that renewable energy generation plants are efficiently integrated into the grid without risking grid stability. By specifying intelligent monitoring and remote control functions, grid operators can react flexibly to fluctuations in renewable energy generation. This is particularly important when intermittent renewable energy sources such as solar or wind energy increase in the electricity mix.

More specifically, Paragraph 9 specifies:

1. Power generation and combined heat and power (CHP) plants with an installed capacity of more than 2 kilowatts (kW), or those equipped with controllable devices, must integrate smart metering and remote control technologies. This ensures that grid operators or authorized authorities can monitor the feed-in in real time and adjust the output remotely if necessary. The required equipment typically includes an intelligent metering system (iMSys) and a control unit to enable compliance.

2. An exception only applies to plug-in solar systems with an output of up to 2 kW and 800 VA inverter power. All other systems must meet the new requirements for smart metering and control systems.

3. Wind turbines must be equipped with on-demand night-time identification systems to reduce unnecessary lighting in air traffic, with specific rules applying to both onshore and offshore installations. 

Legal framework and requirements

The amendment to the Renewable Energy Act also sets out new technical requirements under Paragraph 9. It mandates the integration of smart meters and remote control technologies with the aim to minimize the impact on end customers by optimizing self-consumption and efficiently managing grid feed-in. 

Let’s take a closer look at the technical requirements for §9 EEG. 

Technical controllability 

The general goal of the amendment is to ensure real-time monitoring and remote adjustment of feed-in via the smart meter infrastructure for all systems, regardless of their size. Until this happens in terms of technical controllability, Paragraph 9 EEG mandates the following transitional measures:

• Systems above 100 kW: Must be equipped with technical devices that enable distribution system operators (DSOs) to control the feed-in either fully or partially by remote control.
• Systems between 25 kW – 100 kW: Must install conventional control technology. If the system falls under the feed-in tariff, tenant surcharge or is a CHP plant, the feed-in must be limited to 60%.
• Systems between 2 kW – 25 kW: If the system falls under the feed-in tariff, tenant surcharge or is a CHP plant, the feed-in must also be limited to 60%.

All new systems that meet at least one of the following criteria – having an installed capacity of more than 2 kW or at least one controllable system with a consumption of more than 4.2 kW (in accordance with Section 14a EnWG) – must be equipped with a smart meter (iMSys) for real-time monitoring and control. Until a smart meter is installed, new systems between 2–25 kW must limit their feed-in to 60%.

Until an iMSys and a control box are installed and tested, transitional technical requirements apply. For existing systems installed before the amendment, previous regulations remain in effect. For example, household PV systems with an output of 5 kWp do not have to limit their feed-in to 60% if they were installed before February 25, 2025, even if they do not have an iMSys and a control box.

While the full smart meter rollout is still in progress, all systems over 100 kW must already enable remote feed-in reduction. Additionally, all new installations larger than 2 kW must either limit their feed-in or, for larger plants, be remotely controlled via an interim solution until smart meters and control boxes are fully implemented to comply with the amended regulation.

This ensures that grid operators can monitor and adjust electricity feed-in as needed, preventing surpluses and maintaining grid stability.

Obligations for grid operators and asset owners

Under the updated regulation, the responsibilities and obligations for grid operators and asset owners have changed. 

Grid operators

The grid operators now have access to real-time feed-in data as explained above and must ensure communication compatibility with smart meter gateways and control boxes in compliance with the technical standards. Yet anything beyond the SMGW, such as a home energy management system (HEMS), is the responsibility of the asset owner.

It is also important to note the difference between DSOs and metering service providers (MSPs). While DSOs must ensure compatibility with SMGWs and control devices, MSOs are responsible for installing and testing the smart metering system and control device. If an iMSys and a control device are installed but not tested, certain small PV systems must still limit their feed-in. MSBs will not be sanctioned until 2028 with a fine of €100 per untested system if they delay testing.

Asset owners

Asset owners, such as PV or CHP system operators, have to ensure that the required technical control technology is implemented in order to monitor and adjust the feed-in. However, they can delegate the compliance to third parties such as metering point operators. This way, instead of managing the compliance themselves, they can hand over the handling of installation and operation of the required technology.

If asset owners have multiple, small-scale installations at the same location or connected through the same grid connection point, they do not need a separate control unit for each. For improved efficiency, a single control unit, called  a control box, can be used. These devices pass on control signals from the SMGW to the connected assets or ideally to a HEMS and ensure a proper communication and feed-in adjustment.

Connection to other regulations

The amendment to Paragraph 9 EEG is closely linked to other German regulatory frameworks that also aim to impact the grid stability and operation of assets. 

§14a EnWG

Purpose: This paragraph defines regulations for controllable electricity users such as heat pumps or electric vehicle (EV) chargers. 

Impact on §9 EEG: If a power generating system is connected to the grid alongside a controllable electricity consumer defined by §14a, they are under remote control requirements. This is because if a controllable asset shares a connection with an electricity-generating asset, the grid operator might require more advanced remote control capabilities to balance consumption and generation more efficiently and dynamically. However, if no controllable asset is present, the remote control requirements are just focusing on managing feed-in.

Practical use case:

A household has a PV system and an EV charger, which are connected to the same grid connection point. The grid operator can only limit the feed-in and not the local production itself. This means that as soon as the car starts charging, the PV production will get "redirected" anyway.

However, a HEMS manages both production and consumption in a way that avoids limitations, or rather unnecessary feed-in. For example, it would directly feed in PV production in the morning (or use it for direct consumption) and delay charging the battery or car until midday to maximize PV production usage. This prevents unnecessary feed-in to the grid when it might cause problems.

In addition, energy suppliers are now required to provide smart meters to consumers, not only in respect to §14a EnWG, but also for managing PV feed-in under §9 EEG. Now there are two use cases that drive the adoption and rollout of smart meters. This ensures that consumers, including those with controllable assets, have the necessary technology to participate in the grid's demand response system. In emergency situations or when balancing supply and demand is critical, these systems allow for more dynamic and flexible management of generation and consumption, helping to stabilize the grid.

Messstellenbetriebsgesetz (Metering Point Operation Act)

Purpose: The Metering Point Operation Act established the framework in which the smart meters are rolled out, as well as the communication protocols between grid operators and assets. On top of that, metering operators are now obliged to not only install the smart meters but to also test them on a regular basis to ensure remote control is possible. 

Impact on §9 EEG: With the increased focus on smart meters in recent years, Paragraph 9 EEG ensures that they are used for secure and standardized communication between systems and grid operators. It describes the technical protection profiles and the necessary security measures for proper remote control and data exchange. Thus, grid operators must install smart metering systems (or, in the meantime, other technical equipment) that enable them to access real-time feed-in data and reduce the feed-in power at least partially remotely, depending on market and grid conditions.

In addition, metering point operators are now obliged not only to install these smart meters, but also to test them regularly to ensure that remote controllability is possible, as stipulated in §34 MsbG. This regular testing is crucial for maintaining reliable communication between the systems and the grid operators to ensure that the systems function properly under different grid conditions.

§51 EEG

Purpose: Paragraph 51 EEG is directly related to the technical controllability of systems between 2–100 kW. Once a system has installed and tested a smart meter, it is no longer subject to the 60% reduction rule. However, a new restriction applies: if electricity prices become negative, the system will no longer receive any support during this period.

‍Impact on operators: The duration of the suspension of subsidies during periods of negative prices does not shorten the entire subsidy period. Instead, the excluded hours are added to the total period for which the system is entitled to subsidies. This regulation ensures that while technical controllability provides more flexibility in feed-in, the financial incentives are adapted to market conditions. A crucial driver for asset owners to start managing their feed-in intelligently with an energy management system.

Challenges and optimization potential

Adapting to a new amendment can be challenging for different stakeholders. 

Challenges for asset owners

Asset owners, especially those with PV systems or CHP systems, must ensure that their systems meet the regulatory requirements of Section 9 EEG. The challenge is to meet these requirements, especially for older systems or those without the necessary infrastructure. Older “dumb” plants that are not intelligently integrated into the system will find it more difficult to meet these new requirements. However, these older systems are also incentivized to opt in to the new regime, as doing so allows them to receive additional remuneration. Another crucial point is the curtailment of PV plants. When solar power output exceeds demand or when negative electricity prices occur, excess energy is fed into the grid, resulting in financial losses as the remuneration for the electricity fed into the grid is reduced or eliminated altogether. Asset owners thus need to find ways to minimize curtailment, intelligently manage their feed-in and optimize their own consumption.

Installers also play a key role in ensuring compliance. They are responsible for ensuring that all installed assets are connected in a way that they meet the regulatory requirements. In addition, installers communicate with the DSO to confirm that all legal requirements for the installation have been met to ensure smooth integration into the grid.

Challenges for grid operators and energy providers 

Grid operators and energy suppliers also meet challenges when adapting to Paragraph 9 of the EEG. The new requirements for smart metering and remote feed-in control mean that grid operators must be equipped for real-time monitoring and control of many decentralized renewable energy sources. Enabling this involves significant investment in infrastructure and technology to ensure grid stability and avoid overloads, especially with increasing fluctuations in renewable energy generation. 

Energy suppliers must ensure that they are able to manage these changes in energy flows efficiently and ensure a reliable supply without interruptions.

Opportunities for smart solutions 

One of the key ways for asset owners to overcome these challenges is through the integration of smart solutions, particularly HEMS. These allow system owners to monitor and optimize their self-consumption in real time, reducing the need to feed into the grid during periods of excess energy production or negative energy prices. With a HEMS, system owners can prioritize self-consumption and direct surplus solar power to a battery, EV or other household loads.This not only ensures compliance with regulations, but also helps to minimize financial loss due to power outages, which can lead to increased reliance on expensive grid power or even interruptions to essential household functions.

Advanced energy management systems can also automate many of the processes required to comply with §9 EEG, such as the integration of SMGWs/control boxes and remote feed-in control, as required by grid operators to ensure grid stability. These systems can automatically adjust the feed-in power when grid conditions demand it and ensure that only the permitted amount of energy is fed into the grid. For system owners with older or smaller systems, third-party providers can offer tailor-made solutions for asset owners, ensuring smooth compliance and integration into the existing infrastructure while minimizing operational effort.

Future outlook and expert insights

With Paragraph 9 EEG, Germany is facing important challenges in tackling the digitalization and electrification of energy systems. The transition to smart meters, SMGWs and remote control enables setups that are designed and constructed in a grid-friendly manner. The next phase is to introduce holistic energy management solutions that maximize the utilization of different assets like PV, EVs and battery storage. In an episode of ‘Watt’s up with energy?’, Carsten Schäfer, Senior Product Manager Platform at gridX, explains: 

“The focus is on digital solutions that allow you to optimize and take full advantage of the options available to ensure your energy consumption is as local as possible. Aiming to maximize self-consumption, reduce the need for grid feed-in while avoiding grid constraints and maintaining grid benefits. HEMS, with its digital interfaces, ensures this by making the most efficient use of your resources. Essentially, it's about increasing energy independence”.