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Association of Issuing Bodies

AIB

Association of Issuing Bodies - guaranteeing and tracking the origin of European energy

Lobbying Activity

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Our understanding is that digital product passports (DPP) aim to make information such as product carbon footprints (PCF) more accessible and reliable. Energy disclosure is the interface between tracking emissions in the energy sector with guarantees of origin (GO) and sustainability reporting including PCFs. Firms take the information about emissions of energy procurement from their energy disclosure (electricity disclosure, gas disclosure, ) and report it in their PCFs. While doing so, it is essential to ensure prevention of double counting of the same environmental qualities. This in the first place needs to ensure renewable energy consumption claims are backed by guarantees of origin in countries where a legislative GO system is in place. Where other energy attribute tracking systems are in place, ensure that they comply with criteria of reliability and uniqueness, like those from the EN16325 standard for guarantees of origin. The benefit of cancelling GOs to prove the energy source of consumed energy, is that it secures uniqueness of a claim. The GO in fact can be seen as a digital product passport in itself, given its uniqueness is guaranteed by design: only a single party can issue GOs for a certain eligible energy quantity. In the GO lifetime stages that come after the issuance, there are multiple usage options, including possibilities for restriction rules at usage and/or transfer, where relevant. As such, it is possible to use the GO either in a mass balancing way or in a book-and-claim way. As EU-standardised machine-readable disclosure statements are lacking today, the EU-Commission could take the opportunity to define how DPP link to existing energy disclosure regulation, and consider making energy disclosure a DPP itself. In this way obstacles at the intersection of the multiple existing frameworks for tracking emissions in the energy sector and PCFs/DPP are being removed. Furthermore, it is essential to prevent Double Issuance of the Digital Product Passports, where more than one DPP would be issued to represent the same environmental qualities that are attributed to a product. Therefore, where possible, ensure government-backing of the passport issuance. While technology requirements may be installed on private sector parties, it is recommended that at least the party who confirms the eligibility of a product and initiates the creation of a DPP, is governmentally appointed as a single issuer for its geographical domain. Based on 22 years of experience from governmentally appointed issuing bodies of guarantees of origin, AIB confirms the need of a government-backed issuance framework and rules related to enforceability of using the DPP at claims, to prevent double claims of the same environmental attributes. Inspiration of how this can be done and still be harmonised, is in the European Energy Certificate System www.aib-net.org/eecs , which is largely integrated in the draft EN16325 standard for guarantees of origin. Note also the need for consistency and prevention of double counting with the flows that are registered in the Union Database in execution of the Renewable Energy Directive 2001/2018(EU) art. 31a. This is AIBs expert opinion from managing GO systems. It may not represent all members views, as some may not have decision-making authority on this topic.
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Response to Carbon footprint methodology for electric vehicle batteries

22 May 2024

The electricity modelling in section 2.4 of the draft Annex with the CFP method shows inconsistencies with far-stretched consequences for the EU energy market. It undermines established policy-embedded energy origin tracking policies in Europe. The method for determining the Carbon Footprint (CFP) of electricity consumption from the grid as the national average electricity consumption is inconsistent with other EU policy, namely with art. 19 of the Renewable Energy Directive (RED), Annex 1.5 of the Internal Energy Market Directive (IEM), section E5 of the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Standard (CSRD). It also makes it impossible for Member States to exercise their responsibilities that each unit of renewable energy shall not be accounted more than once (RED art. 19) and to ensure that green claims are substantiated (draft Green Claims Directive). In EU, counting all electricity from the grid with the same emission intensity, goes directly against the allocation displayed to consumers on the invoices of electricity suppliers, together with the corresponding CO2 emissions. It would double-count electricity from renewable sources (RES-E) for countries with high proportions of renewables production who have exported their renewable attributes through guarantees of origin (GOs). It would also undermine the efforts done by the economic operators who purchase GOs. In Europe, the energy source mix of supplied electricity is to be proven with guarantees of origin (GOs), and, untracked commercial offers are being sourced from the Residual Energy Mix (as defined in RED art.2). This follows from IEM Annex 1.5 and RED art. 19.8. Further, where often is referred to section 2.3.3 for determining the national average electricity consumption mix, this section 2.3.3 is written in a very unclear way. It is hard to unambiguously derive what the national average electricity consumption mix should be. Note that the European Commission asks the Member States to report every two years the Resulting Annual Renewable Energy Consumption, following Annex XVI of the Commission Implementing Regulation (EU) 2022/2299. The calculation method here is obviously based on GOs and the residual mix. Setting new rules that are contradictory with existing ones, and make it impossible for both economic actors and member states to execute their responsibilities in established legislation, must be avoided. AIB urges the Commission to reconsider its CFP methodology and ensure that the GO system is not undermined within the EU. AIB is open for dialogue on how the GO system can be further optimized to enhance impact. No other instrument than the GO has been able to empower consumers AND prevent double counting at the same time. These are essential core principles of an energy origin tracking system. Where GOs alone would be seen as not impactful enough, it could be explored to consider requirements like those in the RFNBO Delegated Act 2023/1184 which also provides a set of criteria for eligibility of renewable electricity for a policy purpose. While doing so, it is encouraged to refine the framework there to further close any possible gaps for double counting the same amount of RES-E. Where it comes to energy consumption outside the EU, it could be considered to allow energy attribute certificates in countries where legislation mandates and actively ensures this as a unique instrument for tracking. Development of an international standard for reliable energy origin tracking instrument could overcome political issues. The draft EN16325 guarantee of origin standard could form a valuable starting point of discussion.
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Response to European Sustainability Reporting Standards

7 Jul 2023

AIB (www.aib-net.org) welcomes the opportunity to comment on the draft European Sustainability Reporting Standards. It is essential for these standards to effectively prevent the double counting of environmental benefits in corporate sustainability claims, particularly when it comes to benefits derived from energy consumption. Please see attached document for more details. Thank you.
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Response to Revision of EU rules on Gas

3 Apr 2022

This is an expert opinion of AIB based on its experience in managing GO systems but not necessarily reflecting the opinion of all members, who may not have the mandate to decide on this topic. AIB appreciates the focus on empowering consumers through facilitating transparency regarding the origin of gases they consume. AIB continues to be of the opinion that Guarantees of Origin (GOs) offer the only reliable, cost effective and accurate means of reliably informing consumers and significantly driving the energy system towards sustainability, through market functioning. GOs for gases need to be strengthened with clear rules for origin disclosure towards consumers. Recognising the GO as the single instrument of proof for origin claims, is paramount to avoid double disclosure of the same attributes. AIB welcomes the supplier obligation to disclose the origin of gases and the rule to base this on GOs for renewable gases through art.16 and annex 1.5 of the draft revision of the Gas Directive. However we see some risks and gaps for a reliable disclosure framework. In general, AIB proposes to: 1. Acknowledge the guarantee of origin as the unique proof of the origin of gas towards consumers 2. Expand disclosure rules beyond energy suppliers, to all consumers who claim to consume energy with specific attributes 3. Rely only on GO cancellation for disclosure towards consumers for all energy carriers 4. Consistent residual mix determination and usage. Harmonise calculation methods, clearly define system perimeter boundaries. Timely availability of data for this calculation is essential. Ensure residual mix as only basis for the mix of energy consumption for which no GOs are cancelled Specifically, with regards to the proposal in Annex 1.5 of the draft revised Gas Directive, the risks below should be mitigated. We also point at interferences with the Renewable Energy Directive (REDII) and the proposal for its revision (REDIII). Risk: Double claims of renewable/low carbon gas are not forbidden nor prevented 5. Disclosure for all energy sources: Make disclosure of the origin on the bill mandatory for all gases. This way close the door for using other ways to claim consumption of renewable / low-carbon gas consumption and double claims of the same origin 6. Import from outside the EU-regulated area: - Don’t allow to use aggregate figures for imported gas from outside the Union: this entails a double-counting risk. - Allow import of GOs (only) from countries where national legislation ensures them to be the sole proof of the represented attributes. (interference with art. 19.11 of REDII) 7. Prevent cross-purpose double counting: If separate certification systems are maintained for different legislative purposes, clearly state that certification by National or Voluntary Schemes does not qualify for disclosure of origin towards consumers unless accompanied with GO cancellation 8. Harmonised market instrument: Facilitate coherence in gas tracking. Recognise the GO as unique proof of origin in any system that connects production with the point of consumption 9. Union Database: - Clarify whether and how the origin of gases introduced in the UDB can be disclosed to consumers and its relationship to GOs - Clarify how the GO system and the UDB interact in a way which minimizes the risk for fraud and errors 10. Reliability and efficiency in the relationship between GOs, and National and/or Voluntary Schemes (N/VS): Seek efficiency in the interaction between GO Issuing Bodies and National/Voluntary Scheme operators related to the data certification and recording and their reliability. GOs are the only instrument that can guarantee uniqueness of the origin 11. System boundaries: Clarify similarities and differences in tracking for network-transported and vehicle-transported gases Note: Following the dialogue between AIB and ERGaR on shared core activities, ERGaR explicitly supports §7 and §9 above, whereas AIB supports §3 of the ERGaR reaction
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Response to Prolongation of the optional reverse charge mechanism and the Quick Reaction Mechanism

25 Mar 2022

AIB applauds the foreseen extension of the derogation from 199(a) regarding supplies of gas and electricity certificates. Where Member States have implemented this, it has proven to be an effective tool in the prevention of MTIC fraud regarding guarantees of origin (GOs). We propose to extend the derogation foreseen in Art.199(a)1.f to heating and cooling. GOs are the electronic instruments under the Renewable Energy Directive 2018/2001/EC (REDII) which have the sole function of providing evidence to a final customer that a given share or quantity of energy was produced from renewable sources. REDII extended the scope of GOs in Article 19 to cover gas (including hydrogen) as well as heating and cooling. It also sets the GO as the sole instrument for disclosure of renewable origin of electricity, where before other means of tracking could, in principle, also have been used. However, currently Art.199(a)1.f does not include certificates which are issued for heating and cooling. Therefore it is proposed to extend the derogation foreseen in Art.199(a)1.f to supplies of certificates issued for heating and cooling.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

This is an expert opinion of AIB based on its experience in managing GO systems but not necessarily reflecting the opinion of all members, who may not have the mandate to decide on this topic. GOs can serve as a basis for harmonised European certification and labelling of energy. For efficiency and effectiveness the AIB feels that the concept of GOs can be strengthened in the following ways: 1. Ensure harmonised reliable disclosure of origin of energy both for suppliers and consumers: a. Harmonise disclosure rules and harmonise calendar for reporting and publication of suppliers’ energy mix b. Clarify the requirements for the disclosure of origin of supplied electricity, gas, hydrogen, H/C by including it in Article 19.8 the Directive, c. Consistent disclosure rules for all energy carriers for which GOs are issued. Due to energy conversion, the credibility of a GO for one energy carrier is dependent on the GO for any other energy carriers. d. Where GO is issued, don’t allow the same energy to be disclosed without cancellation of that GO e. Exclusive use of RE-DISS Best Practice Recommendations f. Expand disclosure legislation beyond energy suppliers, to all consumers who claim to consume energy with specific attributes. g. Rely ONLY on GO cancellation for disclosure towards consumers for all energy carriers h. Consistent residual mix determination and use. Harmonise calculation methods, clearly define system perimeter boundaries. Timely availability of data for this calculation is key. i. Ensure residual mix as only basis for the mix of energy consumption for which no GOs are cancelled 2. European GO System management a. Single harmonised set of rules and transfer mechanism: i. Member States should be encouraged to raise efficiency in handling reliable international transfers of GOs. Common standards for GOs and a single harmonised reliable mechanism for cross-border transfer of GOs are recommended. However the delay in the revision of EN16325 is paralysing the development of the GO system. Any future revisions needed to the EN16325 will cost too much time. Therefore AIB recommends to remove the reference to EN16325 from the Directive. ii. Flexible adaptation to changing circumstances is as important as standardisation. Issuing Bodies have proven to be able to set-up, implement, maintain and operate a voluntary standard in a non-profit contractual framework b. It is important to clarify that in order to facilitate consumer choice, procedures for issuing and cancelling GOs for disclosure can both reflect the physical energy flows, and disconnect the GOs from the physical flows, BUT never at the same time 3. Clarify: a. 12/18 months GO lifetime and its implication on disclosure b. Avoid double counting attributes of energy that’s self-consumed, consumed on the site of a production device, private grids, CDS, where GOs are issued for it c. GOs for vehicle-transportable energy carriers d. Interplay of GOs and certification for target compliance, sustainability, ETS: assure the same RES attributes can only be claimed once towards energy consumers e. Clarify that a GO can contain more data than in art. 19.7 of REDII (e.g. hourly GOs) f. Use of H/C GOs is not limited within a given H/C network: how disclose origin of H/C of which the GO was exported? g. Energy carrier conversion: rules for GO handling (expiry date)
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

As the lead enabler for energy certifcation in Europe (707 TWH of renewable energy certified in 2019) the Association of Issuing Bodies applauds further strengthening and harmonisation of the energy certification system(s). In any case the validity /expiry rule for guarantees of origin (GOs) in article 19.3 of the Directive 2018/2001/EU needs to be cleaned up and harmonised over all member states. Divergence in interpretation and implementation causes confusion and inefficiency in the GO system management and in the market.
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Meeting with Dominique Ristori (Director-General Energy)

29 Sept 2017 · renewable energy policy

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

20 Sept 2016 · Renewable energy; guarantees of origin

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

13 Jul 2016 · Renewable Energy policies and the internal energy market