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RECS Energy Certificate Association

RECS

RECS Energy Certificate Association is a non-profit foundation representing electricity market participants.

Lobbying Activity

Meeting with Wouter Beke (Member of the European Parliament)

11 Feb 2025 · Full Consumption Disclosure van elektriciteitsaankopen

Meeting with Andrea Wechsler (Member of the European Parliament) and FuelsEurope and

4 Feb 2025 · EU Energy and industry policy

Meeting with Kris Van Dijck (Member of the European Parliament)

10 Dec 2024 · Energy - full consumption disclosure

Response to European Sustainability Reporting Standards

5 Jul 2023

RECS (www.recs.org) is happy to share its views on European sustainability reporting standards. These standards must ensure the prevention of double counting of environmental benefits in corporate sustainability claims. This specifically applies to environmental benefits resulting from energy consumption. RECS is pleased that, through the CSRD ((EU) 2022/2464) and this related delegated act, more of the environmental claims made by energy consumers will be regulated through a legislative enforcement mechanism. RECS membership counts over 100 energy companies, including some of Europes biggest energy generators and traders. Under RED-2 ((EU) 2018/2001) Art. 19, GOs are established as the proof for consumers of the unique origin of a given unit of energy. Therefore, it would make sense to ensure that corporate reporting on energy consumption is properly proven by cancelled guarantees of origin. Concretely, RECS calls changes to Annex 1 of the delegated act so that: 1. The measuring and reporting of attributes using the location-based method be down-graded and only done to provide indicative information on the attributes of total energy generation in that location. 2. If a corporate is not actively buying and cancelling GOs to demonstrate the origin of their purchased energy, they must report the residual mix for that location. AR25 (p.87, Ax. 1) allows corporates reporting on their energy consumption to choose whether to calculate and express their targets using in either the market-based or location-based methodology. This creates a significant threat that could undermine the GO system as the EUs tool for robust energy tracking. Any location-based calculation and reporting should be indicative only. The formal calculation and reporting of energy use and related emissions should be done using the market-based method. In addition to the above, RECS calls for this reporting standard to be fully based on EU legislation, and not independent and voluntary international standards such as the GHG Protocol. Referring to the 2015 version of the GHG Protocols Scope 2 Guidance is particularly problematic as it is currently under revision. Its governing organisations, the WRI, and the WBCSD have no democratic oversight or delegated role within EU climate and energy action. Furthermore, they publicly acknowledge that the GHGP scope 2 guidance needs modernising, along with the governance and processes underlying that modernisation. These reporting standards should instead refer to Commission Recommendation (EU) 2021/2279 on the use of the Environmental Footprint methods to measure and communicate the life cycle environmental performance of products and organisations. In particular, corporate reporting should be required to adhere to the provisions of para 4.4.2 of that Commission Recommendation which sets out how electricity used from the grid should be modelled as precisely as possible giving preference to supplier-specific data and minimum criteria to ensure the quality of that data. The 3 key criteria set out in that recommendation are equally relevant in this reporting standard. Namely, the need to: 1. convey attributes 2. demonstrate a unique claim 3. be as close as possible to the period to which the contractual instrument is applied. The European GO system has proven its reliability and robustness over 20 years of development, to the point that almost a billion GOs are managed every year. This system, and the market that relies upon it, allows consumers to choose exactly what energy they want to consume. Corporates operating within the EU should be expected to prove the origin of the energy they buy through GOs. Therefore, the market-based method should be the basis of reporting scope-2 corporate emissions in the EU. Any location-based calculation and reporting of EU corporate scope-2 emissions should be indicative and for comparison purposes only.
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

10 Jun 2022 · guarantees of origin (RED, CBAM) - staff level