Significant examples of tendering mechanism have been used to support deployment of RES-E on three significant occasions within the European Union: the UK's Non-Fossil Fuel Obligation (NFFO), the Irish Alternative Energy Regulation (AER) and the French EOLE programme. They have yet to be applied to support RES-H and given the trend away from their use in the RES-E sector it seems unlikely that they will receive political support in application to RES-H. Discussion is included here for completeness.