Skip to main content

Reflection papers

AIB Reflection Paper on the RES Directive II (20 June 2015)

The Association of Issuing Bodies (AIB) provides the infrastructure and information to support the reliable operation of electricity energy source disclosure in EU Member States, its principal objective being to protect the interests of existing and future electricity consumers.

Consequently, we acknowledge and endorse the aims of the Commission in empowering European consumers by providing more choice in an integrated, competitive European energy market, and providing them with greater energy security and reduced carbon emissions. In this Reflection Paper, we set out our suggestions for provisions regarding guarantees of origin (GOs) and energy source disclosure in the future Renewables Directive referred to recently by the Commission as an action item (“Renewable Energy Package: including a new Renewable Energy Directive for 2030; best practices in renewable energy self-consumption and support schemes; bioenergy sustainability policy”).

In summary, we encourage the Commission, in revising the current Renewables Directive, to make provision for:

  1. Disclosing the source of all consumed electricity to consumers by GOs, regardless of the energy source and the technology employed, and according to a set of common rules
  2. Using GOs as a way of providing to consumers evidence of the carbon emissions associated with the production of the electricity they consume and
  3. Setting out GOs and Electricity Disclosure in a single Directive, because GOs and Electricity Disclosure are essentially components of the same mechanism.

The main aims of these proposals are to: create a level playing field for renewable, nuclear and fossil power, empower consumers to affect the carbon content of their electricity consumption, and to foster GO market development by harmonising national rules.

As the current purpose of GOs is consumer empowerment and information, that is what the Reflection Paper addresses. Consideration of RES support schemes and targets is a wholly different topic, and should therefore be addressed separately.

In our preparations for the implementation of Directive 2001/77/EC, when the purpose of a GO was not fully clear, we developed the European Energy Certificate System (EECS) to be able to support either unified or separate certificates for disclosure, support and targets. In the event, the use of a GO under Directive 2009/28/EC was limited to electricity disclosure, and that is all that EECS currently supports. However, should the Commission wish to adjust the scope and purpose of GOs, then we believe that EECS is well placed to support this from a technical perspective.

Further, we foresaw a future need to expand EECS beyond renewable electricity, and hence it was designed to support renewable, fossil, and nuclear source electricity; and other means of conveying energy, such as solid, gaseous and liquid fuels.

To discuss or comment on this response, please contact the Secretary General, Liesbeth Switten (info(at)

AIB publishes Reflection Paper on the forthcoming RES Directive AIB-2015-WGIA-RP01 - Reflection Paper on future RES Dir - final.pdf (839kb) Download

Presentation reflection paper

Click below to view a presentation of the reflection paper.

View on Youtube