An Label takes shape by adding a flag on the EECS certificate that refers to a set of criteria that is maintained outside of EECS.
How Labels complement the European Energy Certificate System
Some suppliers sell renewable energy under Label, which further defines the supplied energy according to (e.g.) the type of technology, date of commissioning of the plant, receipt of public support, criteria on social or environmental friendliness, additionality, etc. A Label informs consumers on aspects of their interest that may go beyond legal minimum requirements.
An Label Scheme Operator guarantees its criteria are being verified in relation with energy production to which it attaches its quality label, while the result of that verification is recorded as a flag on the EECS Certificate. Hereto the Label Scheme Operator has an agreement with both the AIB and the issuing body/ies of the EECS Certificates on which the label flag is recorded.
How the European Energy Certificate System supports Labels
The use of transferable certificates makes Label Schemes much simpler and more efficient, as renewable energy production has already been verified and audited.
The information on the certificates can be used to confirm that source of the energy is what the supplier has promised. Also, an organisation which is independent of the supplier (perhaps a label operator) can confirm that the types and quantity of certificates cancelled reflect the suppliers promises.
Labels are not certificates in themselves: labels categorise certain types of energy sources (i.e. fuels) or supplier products under a specific sustainability scheme according to a set of agreed criteria; and an indication of such can be placed on each qualifying certificate. These Labels have been defined and governed by organisations independent of suppliers.
Their connection with EECS Certificates avoids confusion and double counting that could result from separate handling of the Labels from the energy attribute tracking system that EECS constitutes.
(See also Fuel Mix Disclosure.)
The RES Directive (2018/2001/EC and art.17 of its predecessor 2009/28/EC) requires biofuels and bioliquids to be distinguished according to whether or not they fulfil particular sustainability criteria. However, this provision does not link Guarantees of Origin to sustainability criteria: a GO that does not satisfy such criteria can still be issued. The Directive allows factual information on aspects of sustainability to be added to a GO (article 19(7) says "...must specify at least..."), although it does not explicitly require GOs to record the sustainability of the energy source. Hence EECS supports the differentiation of GO according to sustainability criteria.
Besides the legal requirements for sustainability arising from the RES Directive, further sustainability schemes - particularly those which apply to biomass fuels - are of market relevance.
Requirements imposed by other stakeholders
There are other reasons why it is useful to differentiate GO according to sustainability criteria:
- Market participants would like GO to identify eligibility for green power labels. This reliable, convenient way of satisfying environmental claims might lead to more diversified product portfolios
- The E-TRACK II project has recommended that GO-like tracking instruments be replaced by GO, which should also record compliance with the additional criteria applied by these other tracking instruments
- In some Domains, such information is already contained in EECS.
Role of the AIB
The EECS Rules support regulations for governance and verification of Labels, identification of eligible plant and energies, and the technical changes to the registries etc.
The core expertise of AIB members is tracking of information, and criteria and production-related verification should be assured by such qualified and authorised institutions.
The sustainability criteria proposed by the Directive should be implemented by the EU (or its member states) respectively. Voluntary quality labeling schemes and certificate types have usually procedures in place for verifying the respective criteria.
Such information is administered by EECS according to the requirements of the respective verification process imposed by the governance rules of the sustainability, certificate or labeling scheme. EECS certificates include verified information on whether the respective electricity volumes qualify for the scheme, and this information is transferred with the certificates.
- EECS certificates record whether the respective energy qualifies for a particular Label
- A Label Scheme wishing to be recognised under EECS should apply to the AIB, with the support of a current member, stating the procedure for verification of compliance with the Label Scheme criteria. The procedure is available in EECS Subsidiary Document 09 - Independent Criteria Schemes.
- Members of AIB need not issue certificates under a Label Scheme or display label-related information, but must retain Label-related information for imported certificates in their registry and transfer this with related EECS certificates
- Responsibility for verifying compliance with Label Scheme criteria lies with the Label Scheme Operator.