Although paragraph 2 underwent some changes (in bold), the Commission’s proposal to remove the right of Member States not to issue GOs to the generation of electricity that benefits from a support scheme was deleted from the final text. Thus, it is still up to the Member States to determine this. In our 

, we explore a scenario where German-supported GO volumes come onto the market. The amended paragraph reads:

To that end, Member States shall ensure that a guarantee of origin is issued in response to a request from a producer of energy from renewable sources 

including gaseous renewable fuels of non-biological origin such as hydrogen

unless Member States decide, for the purposes of accounting for the market value of the guarantee of origin, not to issue such a guarantee of origin to a producer that receives financial support from a support scheme. Member States may arrange for guarantees of origin to be issued for energy from non-renewable sources.

In paragraph 7, the Parliament added requirements to provide lifecycle GHG emissions on the GO, with an ISO calculation method, greater time granularity, and locational matching. The first two requirements were removed from the trilogue text, while the 

. As a result, the information contained on an EAC remains the same as in RED II, unless the issuer opts for greater granularity:

the energy source from which the energy was produced and the start and end dates of production, 

(i) in case of renewable gas, including gaseous renewable fuels of non-biological origin, and renewable heating and cooling, at an hourly or subhourly interval;

(ii) for renewable electricity, in accordance with the imbalance settlement period as defined in Article 2, point (15) of Regulation (EU) 2019/943.’;

the identity, location, type and capacity of the installation where the energy was produced;

whether the installation has benefited from investment support and whether the unit of energy has benefited in any other way from a national support scheme, and the type of support scheme;

the date on which the installation became operational; and

the date and country of issue and a unique identification number.

Simplified information may be specified on guarantees of origin from installations of less than 50 kW.

Yet, for renewable gases, GOs, indicating life-cycle greenhouse gas emissions will be made mandatory when entering information into the Union database. The database aims to ensure the tracing of liquid and gaseous transport fuels that are eligible for being counted towards the share of renewable energy in the transport sector in any Member State. This creates a legal link between the GO and the Proofs of Sustainability registered in the Database.

Paragraph 11 remained unchanged: Member States cannot recognise GOs issued outside of the EU, unless the EU has an agreement for mutual recognition in place.

“Member States shall not recognise guarantees of origins issued by a third country except where the Union has concluded an agreement with that third country on mutual recognition of guarantees of origin issued in the Union and compatible guarantees of origin systems established in that third country, and only where there is direct import or export of energy.”

The Parliament added a requirement on the Commission to clarify what is needed for a third country to achieve mutual recognition; however, this did not make it to the final text. Nonetheless, some European countries (Portugal, Estonia, the Czech Republic, Croatia and Luxembourg) already 

 despite not yet having a bilateral agreement with the EU. It is unclear whether these GOs will be accepted for disclosure and cancelled cancellation within the EU in the absence of a formal agreement. By contrast, Swiss GOs stopped being accepted in the EU when the provisions of RED II came into force in 2021.

The Parliament amended paragraph 13 (changes to the RED II text in bold) so that the Commission would monitor the GO system and assess the supply/demand balance in the market (retained in the final text) with a view to rectifying any structural imbalances (removed). The final paragraph looks as follows:

 The Commission shall adopt a report assessing options to establish a Union-wide green label with a view to promoting the use of renewable energy coming from new installations. Suppliers shall use the information contained in guarantees of origin to demonstrate compliance with the requirements of such a label.

The Commission shall monitor the functioning of the guarantees of origin system and assess by 30 June 2025 the balance of supply-demand of guarantees of origin in the market and in the case of imbalances identify relevant factors affecting supply and demand.”

Trilogues concluded on May 2023. The adoption of the Directive will happen over the next three months: the vote in the Council has been postponed to June as France stalls the progress by pushing for a greater role of nuclear energy in the Directive, while the plenary in the Parliament is scheduled for September without any delays. Veyt believes that Article 19 will remain the same as post-trilogue, without any last-minute changes.

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A platform with real-time GO data and insights, reporting prices and market fundamentals for Wind, Hydro, Solar, Biomass, Biomethane and RGGOs. 

Our community offers access to webinars, discussions and updates from industry leading experts and analysts. 

Initial proposals to introduce lifecycle emissions information on GOs and to scrap Member States’ right not to issue GOs for supported production did not make the provisional agreement text of the Renewable Energy Directive during interinstitutional negotiations, among other things. This came despite both the Commission and the European Parliament initially putting forward these amendments.

Our Platform gives you unfettered access to price benchmarking, analytics, new and insights covering the green certificates markets. 

Request a trial now and someone from our team will be in touch with you to learn more about your involvement in the markets and to answer any questions you may have.

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RED: what did not change for guarantees of origin?

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