Perspective | Compliance Guidelines for Wind Turbine Hybrid Tower Supply and Recommendations for Dispute Resolution
Published:
2026-01-04
In recent years, as China’s “dual-carbon” strategy has been deepened, the wind power industry—playing a crucial role as a key component of clean energy—has entered a period of rapid development. Against the backdrop of continuous advancements in wind power technology, the structure of wind turbine towers is undergoing a significant shift from traditional steel towers to concrete towers (hereinafter referred to as “hybrid towers”). Thanks to their advantages—including greater structural height, superior stability, and longer service life—concrete towers are particularly well-suited for low-wind-speed regions and applications involving high tower structures, making them a critical component of the next-generation wind power technology. However, the rapid growth of the hybrid-tower industry has also given rise to numerous legal challenges and compliance risks. On the one hand, the supply of hybrid towers involves multiple complex stages—from design and production to transportation, installation, and maintenance—resulting in long supply chains, high technological barriers, and substantial capital investments; individual project contracts often amount to hundreds of millions of yuan. On the other hand, the legal framework, technical standards, and regulatory policies in this field remain incomplete, exposing enterprises to significant legal risks during their operations. According to incomplete statistics, over the past three years, the number of disputes in the wind power hybrid-tower sector has grown by an average of 50% annually, with the average value of each dispute exceeding 50 million yuan. Moreover, the types of disputes have become increasingly diverse and complex. Consequently, compliance has become critically important throughout the supply chain of wind power hybrid towers.
Preface
In recent years, as China’s “dual-carbon” strategy has been deepened, the wind power industry—playing a crucial role as a key component of clean energy—has entered a period of rapid development. Against the backdrop of continuous advancements in wind power technology, the structure of wind turbine towers is undergoing a significant shift from traditional steel towers to concrete towers (hereinafter referred to as “hybrid towers”). Thanks to their advantages—including greater structural height, superior stability, and longer service life—concrete towers are particularly well-suited for low-wind-speed regions and high-tower applications, making them a critical component of the next-generation wind power technology. However, the rapid growth of the hybrid tower industry has also given rise to numerous legal challenges and compliance risks. On the one hand, the supply of hybrid towers involves multiple complex stages, including design, production, transportation, installation, and maintenance; the industrial chain is long, the technological barriers are high, and capital investment is substantial, with individual project contracts often reaching hundreds of millions of yuan. On the other hand, the legal framework, technical standards, and regulatory policies in this field remain incomplete, exposing enterprises to considerable legal risks during their operations. According to incomplete statistics, over the past three years, the number of disputes in the wind power hybrid tower sector has grown by an average of 50% annually, with the average value of each dispute exceeding 50 million yuan. Moreover, the types of disputes have become increasingly diverse and complex. Consequently, compliance has become critically important throughout the supply process of wind power hybrid towers.
I. Compliance Issues and Common Disputes in the Wind Turbine Hybrid Tower Supply Sector
The wind turbine hybrid tower supply business has become one of the fastest-growing segments in the wind power industry. The primary business models include the EPC general contracting model, equipment supply contract model, and operation & maintenance service contract model. As the wind power industry evolves toward larger-scale and offshore projects, the scale of hybrid tower supply projects continues to expand, technological complexity is steadily increasing, and corresponding legal risks are also on the rise.
Currently, hybrid wind turbine towers—concrete-steel composite tower sections—are rapidly gaining momentum as they align with the industry trend toward larger and taller wind turbines. However, the sector also faces significant challenges, including the nascent development of a standardized framework, insufficient collaboration across the supply chain, and frequent quality-related incidents. As a result, compliance management and dispute resolution within the supply chain have become critically important. Specifically, issues such as environmental compliance, quality compliance, safety compliance, and contractual compliance require heightened attention from enterprises.
Although the China Concrete and Cement Products Association has already released standards such as the “Technical Specifications for the Production of Concrete Tower Sections for Wind Turbine Units” (T/CCPA 54-2024) and the “Technical Requirements for Key Materials Used in the Installation of Steel-Concrete Hybrid Tower Sections for Wind Turbine Units” (T/CCPA 62-2025), the overall standard system still lags behind the pace of technological development, often leading to disputes over the proper application of these standards in practice.
Second, regulatory policies are becoming increasingly stringent. Authorities such as the Shandong Energy Regulatory Office have begun conducting inspections of hybrid-tower wind power construction projects. "Four Noes and Two Directs" Supervisory inspections, including the implementation of posted supervision and even temporary work stoppages in specific areas for identified safety hazards, underscore the regulatory authorities’ high level of concern for the safety of mixed-tower construction.
II. Analysis of Typical Cases
1. Case One: In a 200 MW wind power hybrid-tower supply project in a certain province, Developer Company A signed a concrete tower cylinder supply contract with Supplier Company B, stipulating that the tower cylinders would be 110 meters high. Company B manufactured and delivered the tower cylinders as agreed. During the installation process, Company A discovered that the heights of some tower cylinder sections deviated from the specified dimensions, exceeding the allowable tolerance range and causing difficulties in installation. Company A requested Company B to replace the nonconforming tower cylinders and compensate for the delay in the project schedule. However, Company B argued that the deviations were within a reasonable range and refused to assume full responsibility, leading to a dispute between the two parties.
The main points of contention in this case are as follows: First, whether the deviation in tower height constitutes a material breach of contract; second, the criteria for determining the situation when quality standards are unclear; and third, how to calculate losses incurred due to delays in the construction schedule.
According to Articles 510 and 621 of the Civil Code, if the terms of a contract are not clearly specified, they shall be performed in accordance with national standards or industry standards. In this case, since the contract did not specify an explicit tolerance range, the determination should be made by referring to the provisions on dimensional deviations set forth in the "Technical Specifications for the Production of Concrete Tower Sections for Wind Turbine Generators" (T/CCPA 54-2024). Upon inspection, it was found that the deviations in certain tower section segments did indeed exceed the tolerances permitted by the specifications, thus constituting a breach of contract by Company B. However, with respect to those tower section segments whose deviations remained within the allowable range, Company A is not entitled to refuse acceptance.
In the end, with the assistance of their lawyers, both parties in this case reached a settlement: Company B will replace free of charge the tower section segments that exceed the specified tolerances, while Company A will accept the tower section segments that remain within the tolerances. The loss of schedule will be shared by both parties proportionally, with Company B bearing the primary responsibility for such loss. In addition, the two parties have further signed a technical agreement to clearly define the specific tolerance standards for future products.
2. Case Two: Supplier C and Developer D signed a mixed-tower supply contract stipulating payment in four installments: 20% upon contract signing, 30% before shipment, 40% after on-site acceptance, and 10% upon expiration of the warranty period. Supplier C produced and shipped the goods as agreed, but Developer D, citing cash-flow difficulties, has been delaying payment of the pre-shipment installment. Faced with severe financial pressure, Supplier C, after repeated unsuccessful attempts to collect payment, decided to suspend further production, leading to heightened tension in the relationship between the two parties.
The central issue in this case is whether Company C has the right to suspend performance and how to balance the interests of both parties to facilitate the continued performance of the contract.
According to Article 526 of the Civil Code, if the parties owe each other debts and there is a sequence of performance, the party who is obligated to perform first has the right to refuse the other party’s request for performance if the first party has not yet performed its obligation. In this case, Company D’s payment of the funds prior to shipment constitutes its primary obligation. Until Company D fulfills this obligation, Company C is entitled to suspend shipment; however, it is important to note the procedural requirements for exercising the right of defense against non-performance.
In the end, through mediation by their lawyers, the two parties reached a supplementary agreement. Company D will make an initial payment of a portion of the funds (20%), and Company C will resume production; the remaining 10% of the funds will be converted into... Performance bond Payment must be made before shipment. Should Company D subsequently default on payment again, Company C shall have the right to increase the contract price and impose a penalty for breach of contract. At the same time, both parties shall establish a regular high-level communication mechanism to promptly address any issues arising during performance.
III. Compliance Recommendations for the Wind Turbine Hybrid Tower Supply Sector
Based on our analysis of legal risks in the hybrid-tower industry, we offer the following recommendations to wind power hybrid-tower enterprises:
First, establish a comprehensive compliance management system covering the entire process. Enterprises should abandon the traditional mindset of “focusing on business while neglecting compliance” and build a compliance management system that spans the entire lifecycle of a project. In particular, they must strengthen supervision and management of environmental compliance, quality compliance, and safety compliance, adhering strictly to the two red lines—“technical standards” and “administrative regulation”—to avoid project delays or administrative penalties resulting from compliance issues.
Second, we will improve the contract management system. Given the large scale and long duration of hybrid-tower projects, we will establish a standardized contract framework that clearly defines key clauses and risk-allocation mechanisms for various types of contracts. At the same time, we will strengthen the management of contract performance, particularly change management and evidence preservation, thereby laying a solid foundation for resolving potential disputes.
Third, strengthen compliance management of the supply chain. Since the hybrid tower project involves numerous suppliers, companies should establish mechanisms for supplier access and performance evaluation, clearly define the responsibilities of each party through contracts, and avoid delays or quality defects in the overall project caused by supply-chain issues.
Fourth, develop a diversified dispute-resolution strategy. Based on the project’s characteristics and the relationship between the parties, flexibly choose among litigation, arbitration, mediation, and other dispute-resolution methods. It is recommended to include dispute-resolution clauses in the contract in advance to avoid subsequent disputes. Once a dispute arises, promptly engage legal professionals to devise the optimal solution.
Conclusion
As an important component of the new energy sector, the wind turbine hybrid-tower industry is currently at a critical juncture marked by rapid development and ongoing regulatory improvements. Faced with a complex legal environment and an increasing number of industry disputes, enhancing compliance management and dispute-resolution capabilities has become a core competitive advantage for hybrid-tower enterprises. Compliance in the wind turbine hybrid-tower supply sector can provide practical guidance to both wind turbine hybrid-tower companies and legal service providers, fostering the healthy development of the industry and offering legal safeguards for the implementation of China’s new-energy strategy.
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