AIB - Association of Issuing Bodies

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.

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.

The Association of Issuing Bodies (AIB) welcomes the opportunity to comment on the revision of the European Sustainability Reporting Standards (ESRS) in particular on the provisions related to renewable energy reporting under AR18 for paragraph 26. AIB would like to highlight the importance of consistency between the ESRS framework and the existing EU framework for energy attribute tracking and disclosure. 1.

In the annex, AIB outlines technical and regulatory considerations necessary for a coherent European framework to track energy origin and associated emissions to the point of consumption. -- Operational experience shows that fragmented or parallel tracking approaches: Create systemic risks of inconsistency and double counting; Undermine cross-border market integrity; and Increase administrative complexity for market…

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.

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.

AIB applauds that the proposed change in the Annex II point p, keeps the integration of guarantees of origin (GOs) in the backing of the renewable energy claim, as the prime example to be followed by all policies that enhance renewable energy consumption.

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.