© 2023 The Authors. Published by Elsevier Ltd on behalf of International Solar Energy Society. This is an open access article under the CC BY license (http://creativecommons.org/licenses/by/4.0/). This document is the Accepted version of a Published Work that appeared in final form in Solar Energy. To access the final edited and published work see https://doi.org/10.1016/j.solener.2023.04.001 As announced in the European Green Deal, it is critical to decarbonise the European Union energy system in order to reach climate objectives by 2030 and 2050. According to the REPowerEU plan, photovoltaics (PV) is expected to play a major role in this. Therefore, it is crucial to ensure that newly installed PV modules in the EU are affordable and competitive on the one hand and environmentally friendly on the other. Bearing in mind that the environmental hotspots for PV modules mainly occur during the manufacturing phase, the aim of the paper is to develop a fully-fledged and adapted methodology for calculating the carbon footprint of PV modules, with particular regard to the manufacturing and shipping phases, following a cradle-to-gate approach based on the Product Environmental Footprint Category Rules for PV modules. The implications of requirements for the carbon footprint of PV modules, under the existing legal framework of the Ecodesign Directive, are also discussed.