In December 2020, the European Council [1] endorsed a new binding European Union (EU) target for a net domestic reduction in greenhouse gas emissions of at least 55% by 2030, compared to the 1990 level. Renewable energies will certainly play an important role in policies in the short and medium term; to date, the 2018 Renewable Energy Directive [2] establishes a binding renewable energy target for the EU for 2030 of at least 32%. Within this framework, photovoltaics (PV) is expected to be a major contributor, therefore it is crucial to ensure that newly installed PV products in the EU are environmentally-friendly and do not create new future burdens on the environment. The aim of the paper is to assess the feasibility of requirements on the carbon footprint of PV modules under the already existing legal framework of the Ecodesign Directive.