the Green-e Energy Code of Conduct

Green-e Energy Code of Conduct
Green-e Energy Code of Conduct and Customer
Disclosure Requirements
Updated July 24, 2015
Center for Resource Solutions
1012 Torney Ave. 2nd Floor
San Francisco, CA 94129
www.resource-solutions.org
Contents
I.
Purpose of Document ...........................................................................................................................................4
II.
Updates to the Code of Conduct ..........................................................................................................................4
III.
Green-e Energy Processes ....................................................................................................................................4
A.
Estimated Timeline for Processes ...................................................................................................................4
B.
Agreements and Terms ...................................................................................................................................6
C.
Description of Marketing Compliance Review Process ...................................................................................7
D.
Description of Verification Process .................................................................................................................8
D1.
Verification Criteria ................................................................................................................................8
D2.
Verification Data ....................................................................................................................................8
E.
IV.
Enforcement and Censure ...............................................................................................................................9
E1.
Verification and Marketing Compliance Review ....................................................................................9
E2.
Process for Resolving Problems of Ineligible Supply............................................................................12
E3.
Timeline for Green-e Enforcement ......................................................................................................14
Marketing Disclosure Requirements ...................................................................................................................14
A.
Requirements for All Marketing ....................................................................................................................14
A1.
Logo Use and Word Mark Use .............................................................................................................15
A2.
Required Language for Describing Green-e Energy Certification ........................................................15
A3.
Requirements on the Words “Certifiable” and “Eligible” ....................................................................15
B.
Required Mailings..........................................................................................................................................16
B1.
Required Mailings: Prospective Product Content Label ......................................................................16
B2.
Required Mailings: Historical Product Content Label ..........................................................................16
B3.
Required Mailings: Welcome Packet ...................................................................................................17
B4.
Bills .......................................................................................................................................................18
C.
Product Content Labels, Prospective and Historical .....................................................................................18
C1.
Required Information for All Product Content Labels .........................................................................18
C2.
Product Content Label Templates .......................................................................................................22
C3.
Annual Update of the Prospective Product Content Label ..................................................................29
C4.
Annual Update and Delivery of Historical Product Content Label .......................................................29
D.
Price, Terms, and Conditions (PTC) ...............................................................................................................29
D1.
Delivery Requirements for the Price, Terms, and Conditions ..............................................................30
D2.
Required Information for Price, Terms, and Conditions ......................................................................30
E.
Additional Required and Restricted Language ..............................................................................................31
E1.
General Guidance on Acceptable Marketing Language .......................................................................31
E2.
Renewable Energy Certificate (REC) Disclosure Language ..................................................................32
E3.
Emissions Avoidance Value of Renewable Energy Products, Including Biomass .................................34
E4.
Statements Implying Carbon Neutrality ..............................................................................................36
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
2
E5.
Describing Products with Special Features ..........................................................................................37
E6.
Statements Implying Local or Regional Benefits..................................................................................37
E7.
Advertising Through TV, Radio, and Electronic Media ........................................................................37
E8.
All Websites .........................................................................................................................................37
F.
Sales Channels/Subscription Mechanisms ....................................................................................................39
F1.
Rules that Apply to All Sales Channels/Subscription Mechanisms ......................................................39
F2.
All Sales Channels: Participant Must Directly Control All Marketing Materials ...................................40
F3.
Sales Channel: Websites ......................................................................................................................40
F4.
Sales Channel: Bill Inserts/Paper Sign-up Forms .................................................................................41
F5.
Sales Channel: Door-to-Door Cold Marketing .....................................................................................41
F6.
Sales Channel: Relationship and Warm Marketing ..............................................................................41
F7.
Sales Channel: Electronic Media ..........................................................................................................41
F8.
Sales Channel: Customer Service Center .............................................................................................41
G.
Special Requirements on Brokers .................................................................................................................42
H.
Special Requirements for Certified Wholesale Sales.....................................................................................42
I.
Utility and Developer Requirements for California Enhanced Community Renewables Program (SB43) ....42
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
3
I.
Purpose of Document
This document is part of the Green-e Energy Certification and Logo Use Agreement, a contract
between contract holders referred to as “participants” in the Green-e Energy program and
Center for Resource Solutions, the administrator of the Green-e Energy program. This
document serves to describe the processes, timing, and disclosure requirements of Green-e
Energy certification. Relevant definitions are provided in the Green-e Glossary.
II.
Updates to the Code of Conduct
Green-e Energy reserves the right to periodically update this document in accordance with the
Green-e Energy Certification and Logo Use Agreement.
III.
Green-e Energy Processes
A.
Estimated Timeline for Processes
Below is an estimated timeline for the major processes related to Green-e Energy certification.
Except where specific dates are listed, all timing is indicative; actual deadlines will be made
available to participants each year.
Green-e Energy Important Dates
Month
January
Week
Activity / Deadline
1
Invoicing: Deadline: Payment due for the year’s participation, for
existing products, by January 1.
4
Quarterly Advisory Committee Call
Verification: Submission of new and renewal Tracking Attestations for
generators used in the previous year’s certified sales are requested in
order to be included in the Green-e verification software. Tracking
Attestations may also be submitted with the annual verification
submission, however such facilities will need to be manually entered
into the software by participants. Attestations can be accessed at
http://www.green-e.org/verif_docs.html.
1
Spring Marketing Compliance Review (MCR): Materials request
posted on Green-e website, deadline for affected products
announced.
3
Verification: DEADLINE: Unaudited reporting due. Green-e Energy
Certified Product Mix Change Worksheet due.
February
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
4
4
Verification: Training webinar for all participants, and separate
training for all auditors (details provided in advance).
MCR: DEADLINE: Materials must be provided to Green-e for affected
products. Green-e will review materials and respond, after which
participant will have 30 days to complete required changes.
March
1
Verification: Materials provided to participants (Audit Protocol,
Getting Started Guide) by Green-e; verification software open.
Invoice: ENFORCEMENT: Notice of contract breach if participant has
not yet paid annual fees for existing products.
Product Content Label: DEADLINE: The current year’s Prospective
Product Content Label must be sent to all customers in automatic
renewing subscriptions, and posted on product website by this time.
April
1
Verification: DEADLINE: Submit repowering and co-firing applications
for facilities used toward previous year’s sales, if any such facilities
used.
Invoice: ENFORCEMENT: Existing products with unpaid annual fees
may be terminated.
May
June
4
Quarterly Advisory Committee Call
1
Verification: DEADLINE: All requests for an extension of the
verification submission deadline are due.
1
Verification: DEADLINE: All verification materials and data must be
submitted through the verification software (unless extension
granted). This deadline is typically the first business day in June.
Contract: ENFORCEMENT: If all required verification materials are not
submitted, participant will receive a breach of contract letter and have
30 calendar days to submit required materials.
July
1–4
Verification: Late fees accrue each business day verification materials
are not submitted after the initial verification submission deadline.
1
Contract: ENFORCEMENT: If all product verification materials are not
submitted by 30 calendar days after the early June verification
deadline, product may be terminated.
4
Quarterly Advisory Committee Call
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
5
August
1
Autumn Marketing Compliance Review: Materials request posted on
Green-e website, deadline for affected products announced.
Historical Product Content Label: DEADLINE: Historical Product
Content Label for prior year must be sent to customers and updated
on participants’ websites by this time. Green Pricing Programs with
different Product Content Label distribution requirements provided by
their Public Utilities Commission / oversight body must have
requested extension by now; see Section IV. C.1. Required Information
for all Product Content Labels for more information.
October
4
MCR: DEADLINE: Materials must be provided to Green-e for affected
products. Green-e will review materials and respond, after which
participant will have 30 days to complete requested changes.
4
Quarterly Advisory Committee Call
November 1
2
B.
Records Update: Please check in with Green-e about changes in your
product or company for the coming year, such as changes in customer
type, product type, or new service territory, or changes to company
contact or address.
Invoicing: Annual renewal fee invoices mailed to all current
participants. Payment is due January 1 of the following year.
Agreements and Terms
Each participant wishing to use the Green-e Energy logo or word mark, or claim Green-e Energy
certification for any of their certified products agrees to perform these actions:
1. Conduct an annual independent verification of certified product sales and purchases,
according to the Green-e Energy annual verification process
2. Submit requested Marketing Compliance Review materials to ensure that website and
marketing materials are in compliance
3. Provide customers and prospective customers with all adequate, accurate, clear, and
required information about the certified product
4. Actively guard against double counting of certified products by:
a. Selling renewable electricity or RECs associated with specific renewable energy
generation only once
b. Taking reasonable actions to ensure that all supply is free of use claims from
others and that the renewable energy or RECs have not been sold to any other
party, including but not limited to: using clear contract language, educating
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
6
those in the chain of custody about the exclusivity of renewable claims and the
value of the REC, and reviewing online marketing materials of entities in the
supply chain of the purchased renewable electricity / RECs when possible
c. Only using “Fully Aggregated Renewables” as required by Section III (c) of the
Green-e Energy National Standard and also defined in the Green-e Glossary
5. Ensure by reporting agreements, attestations, and other contractual agreements with
generators and wholesale counterparties that generation output sold in the certified
product has not been counted as part of, or used for compliance with, any mandated
government renewable energy procurement (unless the certified product itself is used
for compliance); renewable portfolio standard or other renewable energy requirement
of local, state, or federal government; or of the utility or generator except as provided
for in the Green-e Energy National Standard Section III (D)
C.
Description of Marketing Compliance Review Process
The Marketing Compliance Review (MCR) process, conducted by Green-e, ensures that
participants offering a certified product are abiding by the Green-e Energy Code of Conduct.
MCR may be conducted on any product, including commercial or wholesale products.
During MCR, Green-e confirms that the certified-product provider is not making false or
misleading statements about their product and that they have made pricing, power, and
consumer information disclosure to customers in a standardized format. This review occurs
twice a year, in the Spring and in Autumn. Green-e may at its own discretion allow a participant
to switch to an annual MCR cycle if the participant’s MCR submissions consistently demonstrate
substantial compliance that does not require revision of materials. Participant may be switched
back at anytime on account of poor compliance.
At the beginning of February and August, Green-e contacts those participants that are required
to submit materials for that round of MCR, and provides MCR information and required
materials checklists, which are also posted on the Green-e website. Submissions are due from
participants on the last business day of February or August as applicable, and must include a
completed MCR checklist as well as samples of all requested marketing materials related to the
certified product. If Green-e requires changes to be made to Participant’s marketing materials
to ensure compliance with the Green-e Energy Code of Conduct, the participant must complete
changes in a timely manner, according to Section III.A. “Green-e Energy Important Dates”.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
7
D.
Description of Verification Process
The annual verification process requires all providers of Green-e Energy certified products to
complete an annual third-party verification audit of their renewable energy purchases and
sales.
D1.
Verification Criteria
The verification process is designed by Center for Resource Solutions and conducted by an
independent auditor selected by the participant. The verification process uses company
contracts and records, renewable energy tracking system records, Green-e Energy attestations,
invoices, and billing statements to verify the following:
1. That the participant purchased enough renewable electricity or RECs in quantity and
type to meet its customer demand for each certified product
2. That the electricity or RECs were generated by eligible renewable generators, as defined
in the Green-e Energy National Standard
3. That the information provided to customers on the product’s annual Historical Product
Content Label is accurate and consistent with that provided in the Prospective Product
Content Label for the corresponding year
4. That the renewable electricity or RECs purchased and sold by the provider were not sold
to more than one customer
5. That other requirements and criteria within the Green-e Energy National Standard are
met, including, but not limited to, requirements pertaining to emissions limits, nuclear
energy, and the prohibition on double claims
D2.
Verification Data
Verification data, verification documentation, and a report produced by the auditor are
submitted and reviewed using a web-based verification tool. Access is available to the Green-e
Energy participant and their auditor. Participants will be provided with instructions and an audit
protocol soon after the close of the year of sales to be audited (the “Reporting Year”).
Attestation forms that document changes in ownership of RECs and renewable electricity must
be submitted as part of the verification process, and can be found on the Green-e website.
An unaudited report of certified sales is due the February following the close of the Reporting
Year. The audited report and all final verification data and documentation must be submitted
through the web-based verification tool no later than (typically) the end of the first business
day in June after the Reporting Year. All verification deadlines applicable to the Reporting Year
will be provided to participants in advance of the unaudited report deadline. If all required
materials are not submitted to Green-e Energy by the applicable due date, late fees may accrue
until all materials are submitted (see Certification Fee Structure for late fee details). Specific
details of required verification materials that must be included with the audited verification
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
8
report are provided annually with the verification instructions for the Reporting Year. An
indicative, but not exhaustive, summary of these materials includes:
1. Reports from approved electronic renewable energy tracking systems
2. Complete Green-e Energy attestation documents
3. Documentation supporting any special cases or exceptions to facility or product
eligibility (for example, repowered facilities, or carbon allowance retirement reports for
generation for California)
4. Prospective Product Content Labels and Historical Product Content Labels
5. Data on electricity generation facilities and their output used in Green-e Energy certified
sales
6. Data on customers purchasing Green-e Energy certified products (aggregated by state
and customer type in most cases)
7. Billing records and contracts for renewable energy purchase and sale (provided to the
auditor only)
8. Internal reports and data related to renewable energy purchase and sale (provided to
the auditor only)
E.
Enforcement and Censure
E1.
Verification and Marketing Compliance Review
For instances in which Green-e Energy verification activities reveal significant differences
between what has been disclosed or sold to customers and what was actually delivered, the
participant is required to make affected customers whole. This may be done by purchasing
extra supply to match the disclosures made, or in some cases Green-e may approve a
notification plan to actively provide relevant customers with information about the change in
supply and offer customers a refund if they desire. Replacement supply must be re-audited
upon request by Green-e and must meet the requirements in the Green-e Energy National
Standard. Such notice of changed supply and the offer of the refund must be mailed or emailed
to customers (as described in Section IV.B2 Required Mailings: Historical Product Content
Label), rather than only appearing on the participant’s website.
Refusal to make affected customers whole and/or provide historical disclosure, or refunds as
applicable, to affected customers as required will trigger enforcement and censure activities as
described below. Examples of common supply and claims issues are described in “Examples of
Supply and Claims Issues” on p. 10.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
9
Examples of Supply and Claims Issues
The Green-e Energy National Standard lists requirements for electricity and REC supply that may be used
in certified products. Participants offering electricity products should pay special attention to geographic
sourcing requirements in Section IV.A of the Standard. Additional guidance on this topic can be found in
Green-e’s “Explanation of Green-e Energy Double Claims Policy”.





Competitive Electricity Products: A problem with supply for a competitive electricity
product arises when the participant has sourced renewable electricity or RECs outside the
eligible geographic boundary for sourcing. Such supply is not eligible for use in a certified
competitive electricity product without the electricity being wheeled into the participant’s
region.
REC Products: A problem with supply arises for REC products if the participant has not
provided required REC Disclosure Language in association with the product. Such supply
may not be eligible for use in the REC product.
Claimed RECs: A problem arises if the RECs have already been claimed, and therefore
retired, earlier in the chain of custody or by the purchaser of electricity (without RECs) from
the facility. This issue is more common with on-site solar and biomass facilities, as system
hosts or owners often want to claim some environmental benefits associated with the
renewable electricity generation and may misunderstand the rights that they are giving up
when they sell the RECs. In this case in particular, it is important to note that contractual
ownership of the RECs may not be enough to render the RECs eligible for Green-e Energy
certification. Claims on the RECs, even unintentional claims, by generators, installers,
aggregators, system hosts, or null power off takers for example, can render the RECs
ineligible for Green-e Energy certification.
Supply Must Match Marketing Disclosures: Participants must provide their customers with
information in marketing and in Product Content Labels about the resource types of the
renewables in their certified product, as well as information about the location of
generation. While the participant can purchase the RECs to supply the product after the sale
commitment to the customer is made (but before annual verification materials are due),
participants must be careful to source from the same resources and locations offered to
customers. Purchasers procuring supply after making sales commitments should contract to
purchase the same type of RECs they told their customers they would ultimately provide
them. Contracting to purchase RECs from “any Green-e Energy eligible” may result in a
purchase of supply that doesn’t match the product content you have described to your own
customers.
Buying “Green-e Energy Certified” Wholesale: Participants selling Green-e Energy certified
products may choose to procure their supply from another seller of Green-e Energy certified
renewable energy. If a Green-e Energy certified product is purchased by a participant and
then re-sold in a Green-e Energy certified product, the participant must report the supply
and subsequent sale to Green-e for verification. Otherwise, the transaction by the re-selling
participant is not certified. When procuring supply wholesale, the re-selling participant is
responsible for ensuring that the supply matches the product sold by that participant, in
characteristics such as resource type, proportions, and generation location promised to the
customer on the Prospective Product Content Label and Historic Product Content Label.
If additional disclosures to customers are required, participant is invited to work with Green-e If
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
10
Upon notification of the non-compliant item, participant must revise their marketing and/or
verification materials to address any non-compliant items, or must desist in using the Green-e
Energy logo and making reference to Green-e Energy in any of its marketing materials for
certified renewable energy within 30 days of receiving notice from Green-e. Green-e will verify
that non-compliant items have been sufficiently addressed.
If additional disclosures to customers are required, participant is invited to work with Green-e
to ensure compliance with Green-e Energy requirements before marketing materials are
printed and/or distributed. Additional disclosure to impacted customers may be required in
some instances of non-compliance. Continued non-compliance will trigger enforcement and
censure activities as described below.
a. Substantial Differences in Supply: Definition and Notification
If a participant changes a certified product’s mix at any time during a given Reporting Year in
such a way as to constitute a “substantial difference” (see 1–3 below), all affected customers of
that product for the Reporting Year (including those purchasing the product over time or
automatic renewals) must be notified. This notification is in addition to the required mailing of
the annual Historical Product Content Label. A product’s content might also change
substantially between distribution of the Prospective Product Content Label and either annual
verification of that product or when the Historical Product Content Label is distributed. Changes
that are not substantial differences do not require an updated Product Content Label to be
distributed to customers.
Products will be considered to have a substantial difference in supply in any given Reporting
Year where there is a difference from that Reporting Year’s Prospective Product Content Label
such that:
1. The type or proportion of renewable resources changes by greater than four percentage
points of the certified product’s mix1
2. A geographic location of generation, such as a state or region, is added or removed from
the mix (see below for how use of “and” and “or” affects geographic disclosure), or
3. A resource type is removed from or added to the supply
When one of the above substantial differences occurs, a completed “Green-e Energy Certified
Product Mix Change” worksheet (available on the Green-e website) detailing the change in mix
1
For example: A 100% solar product that is sold to a customer to cover 50% of their electricity usage will be considered significantly changed if
the customer receives 47% of their total electricity from certified solar and 3% from wind, as the certified product would have changed by 6%,
from 100% solar to 94% solar. However, a certified product that covers 100% of a customer’s electricity load and is made of 50% solar and 50%
wind would not be considered to have changed substantially if it changes to 53% solar and 47% wind, as this is only a change of 3% of a
resource as a percent of total load.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
11
must be submitted to Green-e no later than the due date of the unaudited report worksheet for
the year that the resource mix changed.2
Failure to submit the Green-e Energy Certified Product Mix Change worksheet before this date
will result in the participant being in breach of the Green-e Energy Certification and Logo Use
Agreement as of the date of discovery of the mix change by Green-e. At that time, the
participant will be provided a timeline for cure and will be required to procure supply to keep
the product within the original parameters of the Prospective Product Content Label or
otherwise make the customers of that product whole.
The Green-e Energy Certified Product Mix Change worksheet requires applicants to submit an
explanation of why the new mix provides more value to the customer. Such value to the
customer should be demonstrated. The argument that the new mix is a lower cost to the
purchaser will not be persuasive. Examples of persuasive reasons may include providing
customers with more local resources, or providing more of a resource type that is particularly
valued among those customers.
Green-e will review the submitted Green-e Energy Certified Product Mix Change worksheet and
communicate its decisions to the participant. In cases of changes of greater than 10 percentage
points, Green-e will first decide if such a change is in the best interest of the customer. If Greene determines that the change is in the best interest of the customer, it will take the case to the
Green-e Governance Board for further review.
Regarding changes to the generation location on a Product Content Label, it is acceptable for a
large group of states to be included in a Prospective Product Content Label if it is clear that
supply might not be drawn from all of the listed states—for example, when listing “WA, OR, or
CA” on a Prospective Product Content Label, the final resource mix and Historical Product
Content Label may include any combination of these states, and the removal of one of the
states in the Historical Product Content Label does not constitute a substantial change. If “WA,
OR, and CA” is listed on the Prospective Product Content Label, the final content mix and
Historical Product Content Label must include generation from all three of these states. Please
see the Product Content Label templates for examples.
E2.
Process for Resolving Problems of Ineligible Supply
a. Required Action When Ineligible Supply is Identified
In the event that a substantial difference in supply or ineligible supply is identified, participant
must undertake one of the following actions. Otherwise, the participant’s products will be
decertified and may be subject to other enforcement activities.
1. Procure eligible replacement supply
2 For
example, a Green-e Energy Certified Product Mix Change worksheet for a product sold in 2016 must be received by Green-e in February
2017 in accordance with the Reporting Year 2016 Verification Timeline.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
12
2. Notify customers and allow them the option of canceling without penalty and offer a
refund to the impacted customers, in the amount of the premium they paid beyond
their standard electricity service for the certified product, for the period of time the
certification was misrepresented
If the Historical Product Content Label delivered to customers differs from the data submitted
and audited during the annual verification process by one percentage point or more, then
participant must work with Green-e to amend the product and/or redistribute an updated
Historical Product Content Label and may also be required to offer a refund.
b. Required Action in the Event of Decertification
If problems with supply result in product decertification or if the participant decides to
voluntarily decertify a product, participant must provide customers with a notification
approved by Green-e Energy that contains the following information:
1. The Green-e Energy certified product they are purchasing has lost Green-e Energy
certification and is no longer certified as of the date of decertification
2. An offer to customers allowing them to cancel the product that was previously
certified, free of charge, starting on the date of decertification by Green-e Energy (if
relevant)
3. The Green-e website, www.green-e.org, with instructions that the customer can find
alternative Green-e Energy certified products through the Green-e website
This Green-e Energy–approved notification must be sent to all customers who received a
product that did not meet Green-e requirements or was decertified, and the customers must be
notified within 60 days of the date of the Green-e notification of decertification. Proof that
notification has been sent must be provided to Green-e within 75 days of the date of
decertification. Such proof includes, but is not limited to: a copy of the letter of notification,
email confirmation of notification, a statement from a mailing service, etc. If a compliant and
satisfactory notification is not sent on time, participant must offer a refund to affected
customers for the premium customers paid for the product above their normal electricity rates
for the period in which the customer thought they were receiving a certified product but were
not.
c. Green-e Enforcement
If Green-e does not receive proof of customer notification or if any of the above actions have
otherwise not taken place, Green-e may at its discretion notify customers of the product, the
Better Business Bureau, the Advertising Self-Regulatory Council, and/or the Attorneys General
serving the states in which the product is sold of the failure of the participant to complete the
contractual obligations in the Green-e Energy Certification and Logo Use Agreement. The
participant and product formerly certified will also be listed on the Green-e Energy website as
decertified due to non-compliance. Green-e reserves the right to distribute market advisories
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
13
and press releases describing the noncompliance of participant to news outlets to inform
affected customers and stakeholders of the situation.
E3.
Timeline for Green-e Enforcement
In the event that the deadline for annual invoice payment, MCR materials submission, or
audited verification materials submission is missed, then the following timeline takes effect:
1. Participant receives notification of breach of contract with details of the deadline
missed, number of days to cure and the actions required to cure
2. If the audited verification submission deadline is missed, starting on the first
business day after missed deadline, late fees begin to accrue. See Certification Fee
Structure for more information
3. The contract may be placed on suspension at any time after the deadline is missed if
Green-e has reason to believe that the required payments or documents cannot be
submitted
4. If new information about the reason for missing the submission date comes to light,
Green-e may reassess whether the contract was breached or the amount of time
before the contract is terminated
5. After 30 calendar days (or 15 calendar days in the case of a missed audited
verification submission deadline), if the required cure activities are not performed,
then the contract associated with the missed deadline may be terminated by
Green-e
During Green-e review of MCR and verification materials, Green-e may identify areas of the
participant’s materials that require additional information, documentation, or changes. In such
cases, Green-e will provide participant with a reasonable deadline to provide required followup based on the nature and degree of the follow-up actions required.
IV.
Marketing Disclosure Requirements
A. Requirements for All Marketing
All marketing must be clear and accurate regarding what is certified and what is not certified,
what is being sold to the customer, and any environmental benefits thereof.
All required documentation and marketing materials must reference the certified product with
a consistent name of both the product and the participant. Changes in product name must be
reported to Green-e in writing within a commercially practicable amount of time.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
14
A1.
Logo Use and Word Mark Use
Participant is only allowed to use the Green-e Energy logo and word mark in conjunction with
products that meet all eligibility requirements outlined in the current Green-e Energy National
Standard and the Green-e Energy Code of Conduct, and that have an active contract with Center
for Resource Solutions to be sold as Green-e Energy certified. Use of the Green-e Energy logo in
association with participant when not directly associated with the certified products is strictly
prohibited, and the logo must not appear on business cards, website footers, participant
letterhead or the like. Participant’s use must be in accordance with the Green-e Logo Use
Guidelines.
A2.
Required Language for Describing Green-e Energy Certification
For all products, every use of the “Green-e Energy Certified” Logo must be accompanied with
the website address, “green-e.org”. When possible, the Logo or wordmark used in electronic
media must be an active link to the Green-e website (www.green-e.org).
The following language must also be present in certain circumstances (described below):
“[Product Name] is Green-e Energy certified, and meets the environmental and consumerprotection standards set forth by the nonprofit Center for Resource Solutions. Learn more at
www.green-e.org.”
Participants must include this language next to the Green-e Logo on all certified products’
Product Content Labels and Price, Terms, and Conditions.
Participants must include this language on their website where the certified product is
described most prominently. This requirement may be met by fully displaying the Prospective
Product Content Label in a prominent place on the product webpage.
For language that describes Green-e Energy certification in greater detail, see the Code of
Conduct Guidance Document, posted on the Green-e website.
A3.
Requirements on the Words “Certifiable” and “Eligible”
Participants may not use the phrase “Green-e Energy Certifiable,” “Green-e Eligible,” or any
similar language in describing a renewable electricity, green pricing, or REC product, as it is
likely to mislead customers into thinking that the product will definitely be certified by Green-e
Energy or is equivalent to a certified product. Green-e Energy certified products should be
described as “Green-e Energy certified” rather than as “eligible” or “certifiable.” The word
“Green-e” is a registered certification mark of Center for Resource Solutions and can only be
used in reference to certified products. Renewable energy products are either certified (in
which case the seller has a contract with Center for Resource Solutions and Green-e Energy is
reviewing the sales and resources for eligibility), or not certified (in which case Green-e Energy
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
15
does not and cannot stand behind any statement about whether Green-e might certify the
product at a later date).3
B.
Required Mailings
All participants have customer disclosure obligations. Required mailings may be sent in an
email, newsletter, annual report, or other regular communication. Required mailings must be
actively delivered. It is not sufficient to only post the mailings on the website. An email must be
sent out to all customers with a direct link to the required material itself, and another form of
communication must be used for customers without email addresses.
B1.
Required Mailings: Prospective Product Content Label
Green-e Energy requires all participants to proactively deliver customers of the Green-e Energy
certified product two product content labels annually (unless product changes are made, in
which case additional disclosures may be necessary); a Prospective Product Content Label and a
Historical Product Content Label.
The current year’s Prospective Product Content Label must be delivered to the customer within
60 days of purchasing the certified product, in the form of a welcome packet (see Section B3).
If a customer purchases a certified product to be delivered across more than one calendar year,
or that renews automatically (such as signing up for a green pricing program), the participant
must provide that customer with a Prospective Product Content Label annually for each year of
product delivery within 60 days of renewal, in addition to delivery through the sign-up welcome
packet.
B2.
Required Mailings: Historical Product Content Label
Each customer that purchased the certified product, single mix or multiple mix, during the
previous year (either for the whole year, for a period of the year, or in a one-time purchase)
must receive a Historical Product Content Label by August 1 of the year following purchase
containing accurate and correct information about the contents of the product (See Section
III.E.2 on Substantial Differences in Supply for information about variance).
The full Historical Product Content Label must be delivered to the customer electronically or
physically. The Historical Product Content Label must meet all information requirements of
Section IV.C. If delivered physically, the document must contain a complete Historical Product
Content Label. If delivered electronically, the delivered document or email may contain either
the full Historical Product Content Label or a hyperlink that directly links to the Historical
3
The term “Green-e Energy Eligible” used to describe a generation facility registered in a renewable energy tracking system means that the
facility has already signed a particular attestation and has been reviewed by Green-e against certain portions of the Green-e Energy National
Standard, but such review and “Green-e Energy Eligible” status are not a guarantee that the facility’s output may be used in a Green-e Energy
certified sale, as there are rules related to renewable energy eligibility beyond just facility eligibility.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
16
Product Content Label with language explicitly directing the customer to the full Historical
Product Content Label (for example, “Please view the complete listing of the resources included
in this product: [Year] Historical Product Content Label”).
Exception: For one-time sales where the customer is given a Historical Product Content Label at
time of enrollment that contains information about the actual supply procured for the
customer (including the resource types, proportions, and location of generation by state), a
follow-up Historical Product Content Label in the following year is not required. To qualify for
upfront Historical Product Content Label disclosure, no variance may occur from the product
mix advertised and disclosed to the customer at the time of sale and the actual supply procured
for the product. All product types are eligible for upfront Historical Product Content Label
disclosure, and such disclosure must be approved in advance by Green-e in order to be used
with a product sold to residential customers.
B3.
Required Mailings: Welcome Packet
All participants are required to provide each customer with the current Prospective Product
Content Label; Price, Terms, and Conditions; and all subscription mechanism requirements
listed in F1 “Rules That Apply to All Sales Channels/Subscription Mechanisms” within 60 days of
signing up to receive a certified product or signing up to switch a product offering or percent of
participation. This is referred to herein as the “Welcome Packet”.
The amount of kilowatt-hours (kWh) or percent of use that the customer signed up for must be
clear. This may be in the top portion of the Product Content Label or an accompanying letter or
other document in the Welcome Packet. For example, if the participant offers a 50% and a
100% product, the Prospective Product Content Label may reference both options, but an
accompanying letter or bill must clarify the percent that the customer has subscribed to.
Participants selling in kW must include a disclaimer that the capacity does not guarantee a
certain amount of output and individual unit’s output may vary. Include an estimated output in
kWh for the customer’s contracted kW. Include the average kW needed to power a typical
home in the region.4
The Welcome Packet may be sent electronically or physically. If sent electronically, hyperlinks
to the Prospective Product Content Label and the Price, Terms, and Conditions can be included
in an email or electronic letter. The subscription mechanism requirements listed in F1 “Rules
That Apply to All Sales Channels/Subscription Mechanisms” must be in the body of the email, if
sent by email. The links must be clearly labeled, and include the document names of
“Prospective Product Content Label” and “Price, Terms, and Conditions” at a minimum.
4
Welcome packet requirements for developers in the California Enhanced Community Renewables program can be found at:
http://www.green-e.org/docs/energy/ECR%20Developer%20requirements%204-16-15.pdf.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
17
B4.
Bills
Each bill for the certified product, or an accompanying document or email, must show that a
certified product was purchased and contain the product name.
C.
Product Content Labels, Prospective and Historical
Sellers of all products must supply Product Content Labels to customers. The Prospective
Product Content Label lists information about the supply the participant is advertising to the
customer and plans to provide to them during a specific year.
The Historical Product Content Label lists verified information about the actual supply that was
retired on behalf of the customer during a specific year of sale of a certified product (the
Reporting Year). The Historical Product Content Label is cross-checked with verified data to
ensure that customers receive what is advertised to them.
C1.
Required Information for All Product Content Labels
All Product Content Labels must follow all state requirements and include the information
contained in this section. Participants may be approved to use a different format for the label if
required by a state regulation or law, as long as this label contains all the required information.
Unless noted, all requirements apply to both Prospective and Historical Product Content Labels.
Rules that only apply to specific labels and/or product types are referenced and briefly
summarized in this section, but see the respective Prospective Product Content Label and
Historical Product Content Label sections that follow for details. Participants selling to
residential customers are required to use the Product Content Label format applicable to their
product type; templates are provided below. Participants selling to non-residential customers
may use another Product Content Label format, if it meets the requirements of the Product
Content Label and only with approval from Green-e Energy.
The following components are required:
1. The Product Content Label title must include whether it is the Prospective or
Historical Product Content Label and the calendar year of sales to which it applies
2. The resources in the renewable energy product, listed by fuel type percentage and
geographic disclosure of facility location(s)
a. Location: Disclosures of facility location should be, at a minimum degree of
specificity, by state/province:
i. Prospective Product Content Label for Green Pricing and Competitive
Electricity products: Facility location(s) must be provided by
state/province, not simply by NERC region
ii. Prospective Product Content Label for REC products: Should be broken
out by state if possible, however such products may be sourced
nationally and therefore use terms like “National” or “lower 48 U.S.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
18
states” Use of “National” description is only appropriate if sourcing from
the lower 48 states and/or Washington, D.C.
iii. Product Content Label for all products: If the product might source from
Canadian Provinces, Alaska, or U.S. territories, you are required to call
these locations out specifically by state, province, or territory name on
the Prospective Product Content Label, as well as the Historical Product
Content Label
iv. Prospective Product Content Label for all products: Rules on the use of
“or” and “and” in lists of potential locations apply. See Section III.E.1 for
details
b. Resource:
i. Prospective Product Content Label for all products: Must list each
resource type that may be included in the product
c. Percentage: See Section III.E.1 for rules on allowable deviation between
Prospective Product Content Label and Historical Product Content Label.
Products sold to residential customers must specify the percentage of each
resource type. Prospective Product Content labels for products sold to
commercial customers may list estimated proportions or “Up to 100%” beside
each resource type, but must specify all resources that may be used in the
product, however they must also specify the criteria for example, “lowest cost
option” used to determine the resources chosen
3. Text describing the level of enrollment or enrollment options (e.g. 100 kWh per
block, 50 percent of electricity use5), and whether the product is sold in kWh, kW, or
as a percent of electricity use. Each Product Content Label template herein contains
the text that must be used for the product type
a. Participants selling in kW must include a disclaimer that the capacity does not
guarantee a certain amount of output and individual unit’s output may vary,
include an estimated output in kWh for the customer’s contracted kW, and
include the average kW needed to power a home in the region6
b. If multiple enrollment levels are displayed in the PPCL, the letter in the Welcome
Packet must disclose the individual customer’s enrollment level
4. The comparative mix of the customer’s default electricity mix
a. Green Pricing Programs and Competitive Electricity Products: Use the system
resource mix of the default provider or utility. In all cases, using the resource mix
most specific to the target customer is encouraged
b. REC products: This can be at a maximum the national average resource mix. In all
cases, using the resource mix most specific to the target customer is encouraged
5
Products sold by kW can use estimated percent of use, while products sold by kWh must percent of actual use.
Enrollment requirements for developers in the California Enhanced Community Renewables program can be found here http://www.greene.org/docs/energy/ECR%20Developer%20Requirements.pdf.
6
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
19
5. Participant customer service contact information, including a phone number, email
address, and company website
6. The Green-e Energy logo, and the Green-e Energy disclosure language: “[Product
Name] is Green-e Energy certified, and meets the environmental and consumerprotection standards set forth by the nonprofit Center for Resource Solutions. Learn
more at www.green-e.org.”
7. For REC products: The Short REC Disclosure Language (see Template 4)
8. For electricity products: if applicable, a breakout of RPS or other mandated
renewables
a. Electricity products that use mandated renewables as allowed under Section III.D
of the National Standard: Use Template 1a
b. Electricity products containing Green-e Energy certified renewables for less than
100% of customer load: Use Template 1b
c. All other electricity products: Use Template 1
9. The following footnotes, as applicable:
a. All products: The New Date disclosure (see Footnote 2 in the templates)
i. If a repowered facility is used to supply the customer, Footnote 2 must
include the following language: “This product includes generation from a
facility that was approved under a strict set of criteria and qualifies as
repowered.”
ii. If a facility approved by Green-e for Extended Use is used to supply the
customer, Footnote 2 must include the language: “This product includes
generation from a facility that was approved for extended use by Green-e
Energy.”
iii. If both repowered and Extended Use facilities are used, the two
sentences above may be combined to read: “This product includes
generation from facilities that were approved for extended use under a
strict set of criteria by Green-e Energy and/or qualify as repowered.”
b. All residential products: Include the following: For comparison, the current
average mix of resources supplying [region or your electric utility] includes: Coal
(x%), Nuclear (x%), Oil (x %), Natural Gas (x %), Hydroelectric (x %), and Other (x
%). This resource mix was prepared in accordance with [XX state law; a particular
best practice standard; other cited source]. Any resource greater than 1% must
be broken out individually
c. All residential products: Include the following footnote describing the average
residential electricity usage: “The average home in the United States uses 909
kWh per month. [Source: U.S. EIA, 2013]” participants may opt to list the
electricity usage in the average home in the state or service territory where they
certified product is offered, and should use the most recently available Energy
Information Administration (EIA) data at the time of publication. The geographic
reference, data source, and year must be given. Data on national average
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
20
electricity usage can be found on the EIA website:
http://www.eia.gov/tools/faqs/faq.cfm?id=97&t=3
d. Prospective Product Content Label for all product types: A footnote explaining
that actual resource figures may vary (see Footnote 1 in the templates)
e. All products containing hydropower (including Prospective Product Content
Labels for products that state that they may source from hydropower): The
following modifications should be made to the hydropower footnote depending
on the country of generation (see Footnote 3 in the templates):
i. If the product will not or does not source from Canadian hydropower, the
reference to EcoLogo should be omitted
ii. If the product will not or does not source from U.S. hydropower, the
reference to LIHI should be omitted
10. It is recommended, but not required, that the participant provides customers with
more detailed information on the month or quarter of generation of the renewable
energy used in the certified product, since some end-user certifications rely on this
information
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
21
C2.
Product Content Label Templates
Template 1: Electricity Products Sold as Percent of Use or Blocks
[YEAR HISTORIC/YEAR PROSPECTIVE] PRODUCT CONTENT LABEL 1
[PRODUCT NAME] is sold in blocks of [###] kilowatt-hours (kWh) or matches X% of your electricity usage.
In [year], [Product Name] [was/will be] made up of the following new renewable resources averaged
annually.
Green-e Energy Certified New2 Renewables in [PRODUCT NAME] [YEAR]
-Biomass
%
-Geothermal
%
-Low impact hydroelectric3
%
-Solar
%
-Wind
%
Total Green-e Energy Certified New Renewables
%
Generation Location
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures may vary according to
resource availability. We will annually report to you before August 1 of next year in the form of a Historic Product Content Label
the actual resource mix of the electricity you purchased. [or, for HPCL: These figures reflect the power delivered to [Product
name]’s customers in [year].]
2. New Renewables come from generation facilities that first began commercial operation within the past 15 years. [include the
following language if applicable: “This product includes generation from a facility that is approved under a strict set of criteria as
repowered” or “This product includes generation from a facility that is approved for extended use by Green-e Energy.”]
3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (www.green-e.org/getcert_re_stan.shtml)
and include facilities certified by the Low Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org) or EcoLogo
(www.ecologo.org); and facilities comprised of a turbine in a pipeline or a turbine in an irrigation canal.
For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil
(x %), Natural Gas (x %), Hydroelectric ( x %), and Other (x %). This resource mix was prepared in accordance with [a specific state
law; a particular best practice standard; other cited source].
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone], [website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the
nonprofit Center for Resource Solutions. Learn more at www.green-e.org.
Template 1a: Electricity Products with Renewable Portfolio Standard Renewable Energy Allowed
under Section III.D of the Green-e Energy National Standard
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
22
[YEAR HISTORIC/PROSPECTIVE] PRODUCT CONTENT LABEL1
[PRODUCT NAME] covers 100% of your electricity usage.
A percentage of this product’s renewable content, listed below, is satisfied by renewable portfolio standard (RPS) statemandated renewables that also meet Green-e Energy eligibility rules, up to the [%] renewables that [Seller] must
provide you under State’s RPS rules. 100% of the product’s renewable electricity content is Green-e Energy certified.
In [YEAR], [PRODUCT NAME] [was/will be] made up of the following new renewable resources averaged annually.
Green-e Energy Eligible New2 Renewables in [PRODUCT NAME]
Resource Type
Voluntary Renewables
Voluntary Generation Location
Mandated
Renewables
Mandated
Resource
Location
Biomass
20%
MD
2%
PA
Geothermal
%
%
Hydroelectric3
%
%
Solar
2%
WV
%
Wind
73%
PA, MD
3%
Total Green-e Energy Certified New Renewables
VA
100%
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures may vary according to resource availability. We will annually report to
you before August 1 of next year in the form of a Historic Product Content Label the actual resource mix of the electricity you purchased. [or, for HPCL: These figures reflect
the power delivered to [Product name]’s customers in [year].]
2. New Renewables come from generation facilities that first began commercial operation within the past 15 years. [include the following language if applicable: “This
product includes generation from a facility that is approved under a strict set of criteria as repowered” or “This product includes generation from a facility that is approved
for extended use by Green-e Energy.”]
3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (www.green-e.org/getcert_re_stan.shtml) and include facilities certified by the Low
Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org) or EcoLogo (www.ecologo.org); and facilities comprised of a turbine in a pipeline or a turbine in an
irrigation canal.
For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil ( x %), Natural Gas ( x %), Hydroelectric
( x %), and Other ( x %). This resource mix was prepared in accordance with [XX state law; a particular best practice standard; other cited source]
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone], [website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the nonprofit Center for Resource Solutions.
Learn more at www.green-e.org.
Alternative format:
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
23
[YEAR HISTORIC/PROSPECTIVE] PRODUCT CONTENT LABEL1
[PRODUCT NAME] matches X% of your electricity usage.
A percentage of this product’s renewable content, listed below, is satisfied by renewable portfolio standard (RPS) state-mandated renewables
that also meet Green-e Energy eligibility rules, up to the X% renewables that [XXXX Company] must provide you under State’s RPS rules. 100%
of the product’s renewable electricity content is Green-e Energy certified.
In [YEAR], [PRODUCT NAME] [was/will be] made up of the following new renewable resources averaged annually.
Green-e Energy Eligible Mandated Renewables in [PRODUCT NAME]
Generation Location
-Biomass
%
-Geothermal
%
-Hydroelectric3
%
-Solar
%
-Wind
5%
Total Eligible Mandated New Renewables
5%
Green-e Energy Certified Voluntary New2 Renewables in [PRODUCT NAME]
-Biomass
%
-Geothermal
80%
-Hydroelectric3
%
-Solar
%
-Wind
15%
Total Green-e Energy Certified Voluntary New Renewables
95%
Total Certified New Renewables
100%
Idaho
Generation Location
Washington
Idaho
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures may vary according to resource availability. We will annually report to you before August 1
of next year in the form of a Historic Product Content Label the actual resource mix of the electricity you purchased. [or, for HPCL: These figures reflect the power delivered to [Product name]’s
customers in [year].]
2. New Renewables come from generation facilities that first began commercial operation within the past 15 years. [include the following language if applicable: “This product includes
generation from a facility that is approved under a strict set of criteria as repowered” or “This product includes generation from a facility that is approved for extended use by Green-e
Energy.”]
3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (www.green-e.org/getcert_re_stan.shtml) and include facilities certified by the Low Impact Hydropower
Institute (LIHI) (www.lowimpacthydro.org) or EcoLogo (www.ecologo.org); and facilities comprised of a turbine in a pipeline or a turbine in an irrigation canal.
For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil ( x %), Natural Gas ( x %), Hydroelectric ( x %), and Other ( x
%). This resource mix was prepared in accordance with [XX state law; a particular best practice standard; other cited source]
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone], [website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the nonprofit Center for Resource Solutions. Learn more at
www.green-e.org.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
24
Template 1b: Percent-of-Use Electricity Products With Less Than 100% Green-e Energy Certified
Renewable Energy
[YEAR HISTORIC/PROSPECTIVE] PRODUCT CONTENT LABEL 1
[PRODUCT NAME] provides [% less than 100] of your electricity usage with new Green-e Energy certified renewable energy.
In [YEAR], [PRODUCT NAME] [was/will be] made up of the following renewable resources averaged annually.
Green-e Energy Certified New2 Renewables in [PRODUCT NAME]
-Biomass
%
-Geothermal
%
-Low impact hydroelectric3
%
-Solar
%
-Wind
%
Total Green-e Energy Certified New Renewables
[number < 100]%
Generation Location
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures may vary according to resource availability. We will annually report to you before
August 1 of next year in the form of a Historic Product Content Label the actual resource mix of the electricity you purchased. [or, for HPCL: These figures reflect the power delivered to
[Product name]’s customers in [year].]
2. New Renewables come from generation facilities that first began commercial operation within the past 15 years. [include the following language if applicable: “This product includes
generation from a facility that is approved under a strict set of criteria as repowered” or “This product includes generation from a facility that is approved for extended use by Green-e
Energy.”]
3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (www.green-e.org/getcert_re_stan.shtml) and include facilities certified by the Low Impact
Hydropower Institute (LIHI) (www.lowimpacthydro.org) or EcoLogo (www.ecologo.org); and facilities comprised of a turbine in a pipeline or a turbine in an irrigation canal.
For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil (x %), Natural Gas (x %), Hydroelectric (x %), and Other (x
%). This resource mix was prepared in accordance with [XX state law; a particular best practice standard; other cited source]
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone], [website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the nonprofit Center for Resource Solutions. Learn more at
www.green-e.org.
The remaining [%] of electricity is not Green-e Energy certified.
Resources—
Generation Location
-Wind ( RPS Mandated Renewables)
%
-Hydroelectric ( RPS Mandated Renewables)
%
-etc.
%
Total RPS Mandated Renewables
[RPS percent]%
Natural Gas
%
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
25
Template 2: Optional Combined HPCL and PPCL for Electricity Products Sold in Blocks
PRODUCT CONTENT LABEL1
[PRODUCT NAME] is sold in blocks of [###] kilowatt-hours (kWh). This table provides the
renewable resource mix in [PRODUCT NAME] in [YEAR], as well as the projected resource
mix in [YEAR+1].
Green-e Energy Eligible New2 Renewables in [PRODUCT NAME]
[YEAR] - Historic
[YEAR +1] - Prospective
%
%
Generation Location
Biomass
%
%
Geothermal
%
%
Hydroelectric3
%
%
Solar
%
%
Wind
%
%
Generation Location
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures may vary according to resource
availability. We will annually report to you before August 1 of next year in the form of a Historic Product Content Label the actual
resource mix of the electricity you purchased. [or, for HPCL: These figures reflect the power delivered to [Product name]’s customers in
[year].]
2. New Renewables come from generation facilities that first began commercial operation within the past 15 years. [include the
following language if applicable: “This product includes generation from a facility that is approved under a strict set of criteria as
repowered” or “This product includes generation from a facility that is approved for extended use by Green-e Energy.”]
3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (www.green-e.org/getcert_re_stan.shtml) and
include facilities certified by the Low Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org) or EcoLogo (www.ecologo.org); and
facilities comprised of a turbine in a pipeline or a turbine in an irrigation canal.
For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil ( x
%), Natural Gas ( x %), Hydroelectric ( x %), and Other ( x %). This resource mix was prepared in accordance with [XX state law; a
particular best practice standard; other cited source]
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone], [website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the nonprofit
Center for Resource Solutions. Learn more at www.green-e.org.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
26
Template 3: Electricity Product Marketed in kW or Shares
[YEAR HISTORIC/PROSPECTIVE] PRODUCT CONTENT LABEL1
[Product Name] is a renewable electricity product. This product is sold in kW].
A purchase of __kW has an estimated output of ___ annually. The average home in your area requires
__kW to power it for one year. Purchase of a certain capacity (kW) does not guarantee a certain amount
of output (renewable energy kWh) will be produced. Individual units’ output may vary based on
weather, efficiency and other factors.
[PRODUCT NAME] is sold in blocks of [###] kilowatts
In [YEAR], [PRODUCT NAME] [was/will be] made up of the following renewable resources.
Green-e Energy Certified New2 Renewable Energy in [PRODUCT
NAME]
Generation Location
Solar
100%
City, State
TOTAL
100%
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures
may vary according to resource availability. We will annually report to you before August 1 of next year
in the form of a Historic Product Content Label the actual resource mix of the electricity you purchased.
[or, for HPCL: These figures reflect the power delivered to [Product name]’s customers in [year].]
2. New Renewables come from generation facilities that first began commercial operation within the
past 15 years. [include the following language if applicable: “This product includes generation from a
facility that is approved under a strict set of criteria as repowered” or “This product includes generation
from a facility that is approved for extended use by Green-e Energy.”]
For comparison, the current average mix of resources supplying [region or your electric utility] includes:
Coal (x%), Nuclear (x%), Oil (x %), Natural Gas (x %), Hydroelectric ( x %), and Other ( x %). This resource
mix was prepared in accordance with [XX state law; a particular best practice standard; other cited
source]
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone],
[website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection
standards set forth by the nonprofit Center for Resource Solutions. Learn more at www.green-e.org.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
27
Template 4: All REC Products
[YEAR HISTORIC/PROSPECTIVE] PRODUCT CONTENT LABEL1
[Product Name] is a Renewable Energy Certificate (REC) product and does not contain electricity, which
may be billed separately or by a separate company. A REC represents the environmental benefits of 1
megawatt hour (MWh) of renewable energy that can be paired with electricity. For more information,
see [hyperlink to Participant webpage containing long REC disclosure language].
[PRODUCT NAME] is sold in blocks of [###] kilowatt-hours (kWh) or matches X% of your electricity
usage. In [YEAR], [PRODUCT NAME] [was/will be] made up of the following renewable resources.
Green-e Energy Certified New2 Renewables in [PRODUCT
NAME]
Generation Location
-Biomass
%
-Geothermal
%
-Hydroelectric3
%
-Solar
50%
National
-Wind
50%
National
TOTAL
%
1. [For PPCL] These figures reflect the renewables that we have contracted to provide. Actual figures may vary according to
resource availability. We will annually report to you before August 1 of next year in the form of a Historic Product Content Label
the actual resource mix of the electricity you purchased. [or, for HPCL: These figures reflect the power delivered to [Product
name]’s customers in [year].]
2. New Renewables come from generation facilities that first began commercial operation within the past 15 years. [include the
following language if applicable: “This product includes generation from a facility that is approved under a strict set of criteria as
repowered” or “This product includes generation from a facility that is approved for extended use by Green-e Energy.”]
3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (www.green-e.org/getcert_re_stan.shtml)
and include facilities certified by the Low Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org) or EcoLogo
(www.ecologo.org); and facilities comprised of a turbine in a pipeline or a turbine in an irrigation canal.
For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%),
Oil ( x %), Natural Gas ( x %), Hydroelectric ( x %), and Other ( x %). This resource mix was prepared in accordance with [XX state
law; a particular best practice standard; other cited source]
The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]
For specific information about this electricity product, please contact [Company Name], [phone], [website].
[Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the
nonprofit Center for Resource Solutions. Learn more at www.green-e.org.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
28
C3.
Annual Update of the Prospective Product Content Label
Each year, the Prospective Product Content Label must be updated by March 1 to reflect the
mix of resources planned to be offered in the new calendar year (See Section III.A “Estimated
Timeline for Processes”).
Customers in automatic renewing subscriptions must receive the updated Prospective Product
Content Label annually by March 1 (See Section IV.B2).
All Single Mix products: The Prospective Product Content Label must be available to potential
customers on the participant’s website by March 1.
Multiple Mix products: Multiple Mix products are not required to have a Prospective Product
Content Label posted online.
C4.
Annual Update and Delivery of Historical Product Content Label
The Historical Product Content Label (the certified product mix delivered to customers the
previous year) must be sent to all existing customers by August 1 of the following year,
regardless of whether or not the mix has changed from the year prior. Customers who received
the certified product but are no longer purchasing the product from the participant must also
receive the Historical Product Content Label applicable to their period of purchase if the
participant still has the ability to contact the customer. Green Pricing Programs can request an
extension to October 1 at the latest if they demonstrate need. For one-time sales of certified
products where the Historical Product Content Label is provided at the time of purchase, see
Section IV.B2.
In cases where a “Green-e Energy Certified Product Mix Change worksheet” has been received
and approved by Green-e as per Section III.E1 of this document, the approved change in the
resource mix and the reason for the change must be included on that Reporting Year’s
Historical Product Content Label. Green-e must approve the language used by the participant in
describing the reason for the approved resource mix change prior to the issuance of the
Historical Product Content Label to a participant’s customers.
For Single Mix products: The updated Historical Product Content Label for the previous year
must be present on the participant’s website each year by August 1. The website posting must
meet the display requirements listed in Section IV.E8.
For Multiple Mix products: Participants are not required to post the Historical Product Content
Label on the participant website for multiple mix products.
D.
Price, Terms, and Conditions (PTC)
Each Participant must provide all customers with a Price, Terms, and Conditions (PTC)
disclosure document that clearly describe the customer’s responsibilities in purchasing the
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
29
Green-e Energy certified product. The PTC must be in a simple and easily understandable
format; there is no required format, but a sample template is provided in the Code of Conduct
Guidance Document.
D1.
Delivery Requirements for the Price, Terms, and Conditions
The PTC must be sent to new customers within 60 days of purchasing the certified product as a
part of their Welcome Packet (see Section IV.B.3). The PTC must be sent to all existing
customers (including customers engaged in automatic renewing contracts, and those
purchasing single mix and multiple mix products) any time the mix changes significantly.
Required notification of such significant change must allow customers at least 30 days to cancel
without penalty or fee for such cancellation.
All required information must be found within the same document which serves as the PTC. For
multiple mix products, the contract may serve as the PTC if all of the required information is
included.
D2.
Required Information for Price, Terms, and Conditions
The Price, Terms, and Conditions must include:
a) The Green-e Energy Logo (as used in Sections IV.A.1 and IV.A.2 of this document)
b) The following language for describing Green-e Energy: “[Product Name] is Green-e
Energy certified, and meets the environmental and consumer-protection standards set
forth by the nonprofit Center for Resource Solutions. Learn more at
www.green-e.org.”
c) Company name: Name of the Participant company and any joint venture partners
from whom the customer is purchasing or with whom the customer is contracting (if a
subsidiary or joint venture, both names). Such information must be prominently
displayed to customers and must match the name provided to Green-e
d) Company contact information: Primary customer service contact information,
including customer service number, address, email and website
e) Contract length: Duration of the contract (in months)
f) The cost of the certified product: This includes the price of the certified product, taxes,
and any other charges. REC products sold by an electricity provider must list the
premium of the REC product separately from electricity sold to the customer. Current
prices must be listed on the PTC for each mailing, must always be available upon
request or on company website, and must include the rate structure (either fixed or
variable) of the product. If the rate structure will change in the future (for example,
from an introductory fixed rate to a variable rate), a schedule must be disclosed to the
customer. If variable rate applies, disclose what this means and that the prices will
change and the frequency at which they will change (e.g. monthly)
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
30
g) Product Content Label: If electronic format, the PCL must be hyperlinked within
electronic versions of the PTC
h) Any other potential charges: including, but not limited to, the obligations/charges
associated with terminating the contract or changing from the current certified
product resource mix
i) Bill logistics: Information on how customer will be billed and who will bill the customer
a. REC products: Include the following billing disclosure language: “The price of
RECs is in addition to charges for your electricity. You will be charged
separately for your electricity charges from [Participant name, or “your utility”]
j) For REC products, REC disclosure language: “[Product Name] is a Renewable Energy
Certificate (REC) product and does not contain electricity, which may be billed
separately or by a separate company. A REC represents the environmental benefits of
1 megawatt hour (MWh) of renewable energy that can be paired with electricity. For
more information, see [hyperlink to Participant webpage containing long REC
disclosure language]”
k) Any other conditions: If there are state guidelines for format and content of PTC, a
Participant must adhere to the state guidelines, provided that the Green-e Energy
requirements described above are met. If the state required format is excessively long
or unclear, then it is suggested that Participants also supply their customers with a
summary sheet of key information
E.
Additional Required and Restricted Language
E1.
General Guidance on Acceptable Marketing Language
Only use environmental marketing claims in advertising that are clear, factually based, and:
a) Do not overstate environmental attributes or benefits, expressly or by implication
b) Present comparative claims in a clear manner to avoid customer confusion
c) Do not represent or imply that purchasing the certified product will reduce emissions
that are capped under state or federal law, such as sulfur dioxide or nitrogen oxides
(unless from generator is in an attainment region for NOx), unless company has secured
those emissions allowances and is conveying them to the end-use customer (see the
Green-e Energy National Standard for more information, as well as Section IV.E.3.
“Emissions Avoidance Value of Renewable Energy Products, Including Biomass”);
d) Only compare a product’s generation sources to other generation sources in a clear,
factual and non-deceptive way
e) Do not make statements such as, “This product is made from 100% renewable resources
such as wind, solar, geothermal, low-impact hydro and biomass,” unless the product
contains specific purchases of all of those resources. Participants may describe their
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
31
f)
g)
h)
i)
j)
k)
l)
product mix and may define renewable resources, but must always be clear and
differentiate the type of power that is actually contained in their specific products
Do not state or imply something untrue, such as purchasing this product results in
electrons going directly from the generation unit to a purchaser’s house. However, it is
acceptable to say that you are delivering electricity from a particular facility if the RECs
come from that facility and electricity is also being delivered as part of the product
Language used to describe renewable resources in a general way must also provide
clarity about which specific resource types are contained in the Green-e Energy certified
product offered
Do not show pictures of renewable resources that are not contained in your product
mix. For example, do not show a picture of a wind turbine if your product contains 100%
landfill gas
Do not make claims about renewable power that is found in the default system mix as
being Green-e Energy certified, except in the specific instances allowed in Section III.D
the Green-e Energy National Standard. Renewables in system power that are listed in a
PCL or marketing statements must be categorized under the “non-certified” portion of
an electricity product and specifically labeled as “non-certified” or “not certified”
When describing, advertising, offering, or selling both certified and non-certified
products on the same marketing piece or website, clearly differentiate between which
products are Green-e Energy certified and which products are not Green-e Energy
certified. In this case, the Green-e Energy logo can only appear in association with the
certified products and nowhere else on the marketing piece or website
Each separate certified product must have a distinct and consistently-used name to
avoid confusion about what consumers are purchasing and whether it is certified, and
such product names must not contain the word “Green-e” or “certified”
Do not refer to RECs as offsets. Further, because of the confusion that such marketing
can cause, it is recommended that marketing materials for certified renewable energy
products not use the word “offset” as a verb in order to avoid customer confusion.
Please note that this policy does not preclude Green-e Energy participants from making
environmental equivalency claims; see Section III.E.3 below
E2.
Renewable Energy Certificate (REC) Disclosure Language
Approved Renewable Energy Certificate (REC) disclosure language is required on certain
materials.
Green-e Energy allows REC sellers to refer to their product as “renewable energy,” “green
power,” or similar as they are required to display the Short REC Disclosure Language on all
materials with a subscription mechanism.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
32
a. Short REC Disclosure Language
This language must be fully visible on the Prospective Product Content Label, Historic Product
Content Label, Price, Terms, and Conditions, and all marketing materials with a subscription
mechanism (including prior to sign up through websites):
[Product Name] is a Renewable Energy Certificate (REC) product and does not
contain electricity, which may be billed separately or by a separate company. A
REC represents the environmental benefits of 1 megawatt hour (MWh) of
renewable energy that can be paired with electricity. For more information, see
[hyperlink to Participant webpage containing long REC disclosure language].
The Short REC Disclosure Language must contain a link to the Long REC Disclosure Language
hosted on the Participant’s website.
b. Long REC Disclosure Language
The Long REC Disclosure Language must be included in customer Welcome Packets, and on the
Participant website (on the certified product page or in a general Frequently Asked Questions)
if the certified product is referenced. See other website requirements in Section IV.E.8 and
Section IV.F.1.
The Long REC Disclosure Language may be either fully displayed or a link. If a link, a sentence
such as the following must be included: “For more information about Renewable Energy
Certificates (RECs), see: [hyperlink to Participant webpage containing long REC disclosure
language]”.
“Your purchase of Renewable Energy Certificates (RECs) supports renewable electricity
production in the region of generation. For every unit of renewable electricity generated, an
equivalent amount of RECs is produced, and by purchasing and pairing RECs with your
electricity service you are using and receiving the benefits of that renewable electricity. You will
continue to receive a separate electricity bill from your utility for electricity service [if
applicable]. Your REC purchase also helps build a market for renewable electricity. Increased
demand for and generation of renewable electricity helps reduce conventional electricity
generation in the region where the renewable electricity generator is located. It also has other
local and global environmental benefits which may include emitting little or no regional air
pollution or carbon dioxide.
The RECs in [Product Name] are verified and certified by Green-e Energy, and [Company Name]
is required to disclose the quantity, type and geographic source of each certificate. Please see
the Product Content Label for this information. Green-e Energy also verifies that the renewable
certificates are not sold more than once or claimed by more than one party. For information on
Green-e Energy please visit its website, www.green-e.org.”
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
33
E3.
Emissions Avoidance Value of Renewable Energy Products, Including Biomass
Green-e Energy certified products must be denominated in common electricity terms (e.g.
megawatt-hours (MWh), kilowatt-hours (kWh), kilowatts (kW), percentage of a user’s kWh of
electricity consumption).
Participants can market their certified products as instruments to address the environmental
impacts traditionally associated with the consumption of electricity. One such impact is the
emission of carbon dioxide resulting from the generation of electricity using fossil fuels.
Consuming electricity with zero-emission generation attributes therefore reduces or (if it
represents 100% of consumption) eliminates altogether the indirect carbon dioxide emissions
associated with the user’s consumption of purchased electricity, classified as “Scope 2”
emissions by the World Resources Institute’s Greenhouse Gas Protocol.
In addition, as zero-emission generation displaces emitting generation on the electricity grid,
the corresponding avoided grid emissions can also be claimed as a benefit of the zero-emission
electricity consumed (provided that emissions from the electricity sector are not capped under
a cap-and-trade system without a renewable energy set aside or similar mechanism).7
The implicit or explicit marketing of Green-e Energy certified renewable electricity and REC
products as a means to address or reduce emissions from anything other than the consumption
of electricity purchased from the grid shall not be permitted. Likewise, statements about the
certified product causing global reductions in emissions are not permitted. Reducing emissions
from sources other than electricity must be done directly or with carbon offsets held to a
different set of quality criteria, including additionality criteria. This can be accomplished with
products certified by Green-e Climate. For further information about Green-e Climate, including
how to begin offering a Green-e Climate certified product, please visit www.greene.org/climate or contact Green-e Climate at climate@green-e.org or 415-561-2100.
Related to this, Green-e Energy recommends that marketing materials for certified renewable
energy products not use the word “offset” as a verb in order to avoid customer confusion.
Please note that this policy does not preclude Green-e Energy participants from making
environmental equivalency claims associated with the renewable electricity and REC products
that they sell, including carbon-related equivalency claims associated with the avoided grid
emissions benefit.
a. Statements Related to Renewable Resources other than Biomass
Below are examples of carbon-equivalency statements that a Participant may use in marketing
materials when selling renewable energy products that are comprised of renewable resources
other than biomass. These first four statements are related to the emissions that would have
7
It is important to note that these avoided emissions do not necessarily represent a reduction beyond a global business-as-usual scenario and
therefore cannot be traded as emissions reductions or used to address emissions outside of the electricity sector.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
34
occurred if the renewable electricity was not generated (avoided grid emissions), and not any
emissions changes that result from the purchase of the certified product:




The generation of the renewable energy you choose instead of your regular electric
service has a greenhouse gas benefit equivalent to… (e.g. taking X # of cars off the road
for one year or recycling X # of aluminum cans)
The 100% renewable electricity that you choose over your regular electric service has a
greenhouse gas benefit equivalent to…
Compared to your regular electric service, choosing 100% renewable energy means
choosing electricity that has a greenhouse gas benefit equivalent to…
Participant’s 100% renewable energy product has a greenhouse gas benefit equivalent
to… if you purchase X MWh annually.
Carbon equivalency numbers provided by the EPA Greenhouse Gas Equivalencies Calculator8
are also permitted as long as that calculator is cited.
Participants shall not use any of these claims to suggest that the purchase of a Green-e Energy
certified product can be used to directly address emissions associated with activities other than
electricity consumption, but rather to frame the environmental benefit of renewable energy in
a manner that the average consumer will better understand.
The first step in making such claims is often a conversion to metric tons of CO2 emissions
avoided. The maximum conversion factor that Green-e Energy permits for use in such carbonrelated equivalency claims is based on the non-baseload output emission rate of electricity
generation9 of the NERC region in which the renewable MWh is generated10. In cases where a
Participant does not explicitly provide upfront geographic disclosure of a certified REC product’s
supply to consumers, the maximum rate that may be used is the non-baseload output emission
rate of electricity generation in the NERC region with the lowest of such a rate at the time the
equivalency language is first published, which is available from the EPA’s eGRID database.
Participants are responsible for emissions equivalency statements made on marketing
materials.
Green-e Energy recognizes that Participants may want to use another methodology to make
these conversions for equivalency claims in certain cases. Participants can only use rates higher
than non-baseload output emission rate for the relevant NERC region of generation with the
8
Available at: http://www.epa.gov/cleanenergy/energy-resources/calculator.html
This rate is effectively the emissions from marginal grid generation, and is appropriate where renewable electricity generation’s direct
emissions are zero. This is consistent with the EPA’s electricity carbon calculator, which uses non-baseload output emissions rates. However,
use of emissions from marginal grid generation may not be appropriate for renewable generation with positive direct emissions, for example
generation from biomass fuels. All carbon equivalency statements must be supported by generally acceptable scientific methodologies. Green-e
does not endorse such statements when positive direct emissions exist.
10 Programs that specifically work with end-use consumers in communicating or recognizing their renewable energy purchases may require
consumers to use a separate methodology for deriving the carbon value of renewable energy purchases, including using different conversion
factors or calculating rates by different regions of generation. End-use consumers will need to work directly with these separate programs to
determine what environmental claims are permitted under their respective guidelines.
9
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
35
express pre-approval from the Center for Resource Solutions. In cases where such exceptions
are granted, it will be required that in all marketing materials displaying such carbon
equivalency claims that the source of the calculation methodology used is appropriately cited.
Participants may, however, use rates below the maximum levels in the prior paragraph without
the need to seek pre-approval from the Center for Resource Solutions. Regardless of the
methodology and/or emission rates used, all Participants must be able to provide their carbon
calculation methodology to substantiate stated environmental claims upon request.
The following three statements may be used to describe the retail electricity user’s emissions
from using renewables (their Scope 2 emissions), and are related to the emissions that the user
would have been responsible for if they used system power instead of purchasing renewables:



Generation of [the Green-e Energy certified product] did not cause direct greenhouse
gas emissions
By purchasing [the certified product] you are able to report zero Scope 2 emissions
By purchasing [the certified product] you are reducing your greenhouse gas footprint
compared to your regular electricity service / to your electricity use before your
renewable energy purchase
In the case of Scope 2 emissions, any communication of the actual amount that the user’s
footprint is reduced must be based on the residual mix emissions rate for the NERC region of
the electricity user, in order to be consistent with the WRI GHG Protocol. Green-e Energy
publishes residual mix figures annually, available online at: Green-e Energy National Standard
and Governing Documents.
b. Statements Related to Biomass Resources
Biomass resources used to generate electricity must not be referred to as a “zero emissions
resource” and neither do they have zero direct carbon emissions when used to generate
electricity. Green-e Energy does not provide a methodology for accounting for carbon
emissions associated with biomass energy products.
If emissions from using biomass resources to generate electricity are quantified and used in
marketing materials (including calculations of net emissions, offsite carbon sequestration,
and/or avoided fossil emissions), the following language must be included on the marketing
piece referring to emissions from this resource: “Green-e Energy does not certify or verify
carbon emissions claims or methodologies for calculating emissions related to biomass.”
E4.
Statements Implying Carbon Neutrality
Green-e does not support or endorse claims of carbon neutrality as they are highly likely to be
misleading and extremely difficult to prove. Carbon-neutral claims may not be made about or in
relation to Green-e Energy certified products, and therefore cannot be present on Product
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
36
Content Labels or Price, Terms, and Conditions, or other marketing materials for the certified
product.
If a claim of carbon neutrality is made about a non-certified product, and this statement is in
proximity to discussion of the Green-e Energy certified product, the following clarifying
language must be located immediately beside the claim, “Green-e Energy does not verify this
claim.”
E5.
Describing Products with Special Features
Green-e Energy certifies products that meet its criteria. Participants may wish to market
aspects of a certified product that fall outside of these criteria. In such cases, it is necessary for
the Participant to clearly state that Green-e Energy does not certify certain aspects of the
product.
For example, if the Participant is claiming that part or all of the revenue associated with sales of
the certified product is allocated toward avian protection, it must be clearly stated in the area
where this aspect of the product is discussed that Green-e Energy does not certify the avian
protection aspect, only the certified product itself.
Likewise, if the Participant is claiming that a specific portion of revenue associated with sales of
the certified product is set aside for development of new renewable energy projects, the
Participant must clearly state in the area where this aspect of the product is discussed that this
activity is not verified by Green-e Energy, and that only the product itself is certified.
E6.
Statements Implying Local or Regional Benefits
Local or regional claims require disclosure of the state of generation (matching the Product
Content Label), in support of any claims made, on the same marketing item or page.
E7.
Advertising Through TV, Radio, and Electronic Media
Regardless of the medium, all advertising must follow the same requirements. For example, all
subscription mechanisms advertising REC products require Short REC Disclosure Language.
If customers can subscribe or buy the certified product through a form of electronic media,
such as a mobile interface, subscription mechanism requirements apply (see Section IV.F).
E8.
All Websites
Any and all information related to the certified product provided on the Participant’s website
must be clear and not deceptive. Websites that do not market the certified product in any way
do not need to include specific information about Green-e Energy or provide Product Content
Labels or Price, Terms and Conditions.
Websites that make reference to a certified product must include the following on the most
prominent product webpage:
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
37
a) The Green-e Energy description language, which must be fully visible with the “Green-e
Energy certified” logo:
“[Product Name] is Green-e Energy certified, and meets the environmental and
consumer-protection standards set forth by the nonprofit Center for Resource
Solutions. Learn more at www.green-e.org.”
Note: By fully displaying the PPCL and the PTC the participant meets this requirement.
b) For single mix and Utility Green Pricing products only: The most-recent PPCL, HPCL, and
PTC. For single mix products: The PTC must be visible and prominently displayed on the
certified product’s website, available to all customers prior to purchase. Multiple mix
products are not required to post the PTC on the website, but must meet all other PTC
requirements for distribution.
The documents may be either fully and prominently displayed on the product page or
accessible through hyperlinks displayed to the customer prior to purchase, which must be
clearly labeled to reflect the contents and include the document names of “Prospective Product
Content Label,” “Historic Product Content Label,” and “Price, Terms, and Conditions,” as
applicable, at a minimum. The links must be accompanied with a descriptive sentence, such as,
as applicable: “For a complete list of the resources included in [Product Name] view the
Prospective Product Content Label.” “To see what customers received last year, view the
Historic Product Content Label.” “To view highlights of the conditions of your subscription, see
the Price, Terms, and Conditions.”
For information about when the PPCL, HPCL and PTC are required to be updated, see Section
IV.
For REC products only: The Participant website must include the Long REC Disclosure Language,
which may be fully displayed or accessible through a link. See Section IV.E.2 for the specific
Long REC Disclose Language. If using a link, a sentence such as the following must be included:
“Information about Renewable Energy Certificates (RECs):” Participants that do not reference
the certified product on their website are not required to display the Long REC Disclosure
Language on their website, but the language must be sent to the customer as part of the
Welcome Packet. Multiple-mix products may satisfy this requirement by providing a link to the
Long REC Disclosure Language on the Green-e website within the welcome packet.
For information on websites that also function as a sales channel see section on Subscription
Mechanisms (below).
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
38
F.
Sales Channels/Subscription Mechanisms
F1.
Rules that Apply to All Sales Channels/Subscription Mechanisms
The following rules apply to all mechanisms through which a customer can enroll in or purchase
a certified product. Additional requirements and exceptions are noted in the applicable sales
channel subsection below.
All materials with subscriptions mechanisms made available to residential and commercial
customers prior to subscription, enrollment, or purchase (whichever applies) must contain the
following information:
a) Resource mix: The renewable energy sources used to supply the product and the
resource mix (%) found on the Prospective Product Content Label
a. Multiple Mix Products: (See Section IV.C.3 for instructions on how multiple-mix
products can list “Any of the following resource types” and then list resources
using “or.”) Multiple Mix Products may specify “lowest cost source” here
b) Geographic location: Prospective geographic location of renewable energy sources as
listed on the current Prospective Product Content Label. REC products may list “Lower
48 states,” (sourcing from Canadian Provinces, Alaska, or U.S. territories requires
disclosure, and all “National” products must source only from the lower 48 states)
electricity products must specify the state or states of generation, for example “may be
generated in GA, AL, or FL.” See Section III.E for instructions on using “or” and “and” in
location lists
c) Price: Product’s rate structure and enrollment level options (either kWh block or
percentage of electricity use). If the price is variable, then the average price over the
course of the most recent year should be disclosed if possible. If such data is not
available because the program is new, then an estimation should be provided. Variable
pricing requires disclosure of the factors that determine pricing. Variable pricing should
include information about the frequency of the variations and the average variability if
possible
d) Contract length: Required contract length (if any) and fee for early termination (if
applicable)
e) The “Green-e Energy certified” Logo: with www.green-e.org or the Green-e Energy
description language from Section IV.A.2
f) For REC products only: the Short REC Disclosure Language in IV.E.2 must also be fully
visible
This requirement could also be met by displaying the Long REC Disclosure Language (Section
IV.E.2.b) prior to purchase.
As a reminder, additional disclosures will be provided to customers in the form of the Welcome
Packet, sent to the customer within 60 days of sign up, per Section IV.B.3. All other
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
39
requirements of the Green-e Energy Code of Conduct (such as Historic Product Content Label
disclosure) apply.
Note that by displaying the PPCL and PTC prominently on the subscription mechanism itself,
many of the above requirements are achieved.
F2.
All Sales Channels: Participant Must Directly Control All Marketing Materials
Participants must maintain control over all advertising and sales channels of their certified
product.
Third parties without contracts with Center for Resource Solutions (CRS) may endorse or refer
customers to Participants selling Green-e Energy certified products, but they cannot sell
certified products themselves, advertise that they do so, or use the Green-e Energy logo. It
must always be clear to prospective customers who the seller of a Green-e Energy certified
product is and which party has the contract with CRS.
For all Participants, including multi-level marketers, all sales must be done through the
company (the “contracted company”) that has a contract with CRS. This allows affiliated sales
associates to direct potential customers to the contracted company’s website or phone service,
but does not allow such sales associates to sell directly through their own website. Sales
associates are not allowed to use marketing materials that have not been provided by the
contracted company. All websites and marketing materials must be provided by the contracted
company to sales associates. This includes any reference to the product online. In addition,
Green-e may require all marketing materials also be pre-approved by Green-e. Multi-level
marketers must collect all marketing information, including screenshots / images of affiliated
websites for the Marketing Compliance Review submission. Multi-level marketers are not
eligible to move to annual Marketing Compliance Review.
Multi-level marketers must include language in each instance where the Green-e Logo is used,
as well as in the PCL and PTC, stating that Green-e Energy certifies the product and not the
company or the company’s business structure.
F3.
Sales Channel: Websites
In addition to the requirements for websites listed in Section IV.E.8, websites with subscription
mechanisms must display the disclosure requirements for materials with a subscription
mechanism listed in Section IV.F.1 above (the product’s resource mix, geographic location,
price/rate structure, contract length, and REC language where applicable). All requirements
must be fully visible to the customer prior to completing sign up.
Websites offering REC products: the REC Disclosure Language in Sections IV.E.2.a and IV.E.2.b
are required.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
40
F4.
Sales Channel: Bill Inserts/Paper Sign-up Forms
All subscription mechanism disclosure requirements in the first part of Section IV.F.1 apply.
Physical enrollment forms (such as physical mailers, bill inserts, postcard enrollment forms,
etc.) must include the certified product’s resource mix, geographic location, price/rate
structure, contract length, and Short REC disclosure Language (if a REC product). See Section
IV.F.1 for details on these requirements.
F5.
Sales Channel: Door-to-Door Cold Marketing
All subscription mechanism requirements apply. All enrollment forms used must include the
certified product’s resource mix, geographic location, price/rate structure, contract length, and
REC disclosure (if a REC product). See Section IV.F.1 for details on these requirements.
F6.
Sales Channel: Relationship and Warm Marketing
All subscription mechanism requirements apply. All enrollment forms used must include the
certified product’s resource mix, geographic location, price/rate structure, contract length, and
REC disclosure (if a REC product). See Section IV.F.1 for details on these requirements.
All marketing materials must be controlled and approved by the Participant. All sales must be
conducted through the company with a contract with Green-e, e.g. through the parent
company website where the customer has the opportunity to view required disclosures on the
parent company website.
F7.
Sales Channel: Electronic Media
All subscription mechanism requirements apply. Electronic subscriptions mechanisms (such as
social media, mobile apps, electronic interfaces at kiosks, etc.) must include the certified
product’s resource mix, geographic location, price/rate structure, contract length, and REC
disclosure (if a REC product), even in cases with minimal space for disclosure. See Section IV.F.1
for details on these requirements.
F8.
Sales Channel: Customer Service Center
All Participants selling a single mix product must communicate the following to customers who
call with questions about the certified product in these terms or similar as approved by Green-e
Energy. This section also applies to third-party verification (TPV) enrollment software. We do
not require 24-hour availability, but representatives should respond within 48 hours.
For certified competitive electricity and green pricing electricity products:
“We [or, Company Name] offer [Product Name]. It is made up of electricity generated from [list
all resource type(s) found on Prospective Product Content Label] [power / energy] located in
[insert names of states or region listed on Prospective Product Content Label]. Would you like
to know more about [Product Name]?”
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
41
For certified REC products:
“We [or, Company Name] offer [Product Name]. It is made up of [list all resource type(s) found
on Prospective Content Label] renewable energy certificates generated [“in the lower 48 US
States,” or as specific as the names of the states listed on the Prospective Product Content
Label]. [Product Name] does not contain electricity, which may be billed separately or by a
separate company. Renewable electricity generation and use are tracked through RECs, and so
by matching RECs with your electricity service you are using renewable electricity. Would you
like to know more about [Product Name]?”
See the Code of Conduct Guidance Document for an optional short guide for call center
representatives, and additional guidance for call center scripts.
G.
Special Requirements on Brokers
Brokers must ensure that the purchaser of a product certified by virtue of broker’s contract
with CRS receives all of the required information from either the broker or the seller. The
purchaser must receive a Prospective Product Content Label; a Historic Product Content Label;
and a Price, Terms, and Conditions. Prospective Product Content Label disclosure may not apply
if the exact product mix is known at the time of sale (see Section IV.B.1).
H.
Special Requirements for Certified Wholesale Sales
There are no special requirements that apply only to certified wholesale sales; for example, all
PCL, PTC and marketing rules apply to wholesale sales.
In cases where the wholesale seller is a Participant selling a certified wholesale product and the
purchaser is a Participant buying supply for its certified product, the purchasing Participant may
need to specifically request a wholesale product comprised of resources that are compatible
with the resource mix the purchasing Participant is offering in its own certified product in order
to meet the requirements of this Code of Conduct.
Sellers are not allowed to misrepresent the products certification status in a way that implies
certification survives resale by the purchaser.
I.
Utility and Developer Requirements for California Enhanced
Community Renewables Program (SB43)
California Investor-Owner Utilities are required to ensure all required disclosures are conveyed
to the customer. See Green-e Energy Enhanced Community Renewables Developer
Requirements at Green-e Energy National Standard and Governing Documents.
© 2015 Center for Resource Solutions. All rights reserved.
Green-e Energy Code of Conduct
42