Overview of RE100 Guidance for Passive Procurement

This section provides a concise summary of the RE100 initiative's guidance on passive procurement of renewable electricity, as outlined in The Climate Group's RE100 Technical Criteria (version 5.0, updated March 24, 2025, with minor corrections on April 15, 2025). RE100, co-led by The Climate Group and CDP, sets global standards for corporate renewable electricity claims, emphasizing credible, transparent procurement to drive grid decarbonization. Passive procurement aligns closely with Standard Supply Service (SSS) concepts, allowing companies to claim default-delivered renewables without active sourcing, while imposing strict boundaries to prevent over-claiming or resource shuffling.

Our Granular Registry methodology for estimating and allocating SSS resources—using credible third-party data, pro rata load shares, and EAC tracking proxies—fully complies with RE100's passive procurement requirements. By leveraging public sources (e.g., grid mix data from Ember or EPA eGRID) and ensuring exclusive, verifiable claims, the Registry enables users to substantiate passive claims in line with RE100's credibility principles, while supporting transitions to active, granular procurement via our Marketplace.

Key Elements of RE100 Passive Procurement Guidance

RE100 categorizes passive procurement as one of five recognized procurement types (Section Four), distinguishing it from active methods like PPAs or unbundled EACs. It applies only to involuntary, default supplies and requires evidence to ensure claims are unique, exclusive, and impactful. Passive claims must meet RE100's six credibility principles (Appendix A: credible generation data, attribute aggregation, exclusive ownership, no double claiming, geographic/vintage limits) and broader requirements like EAC cancellation in relevant markets (Section Five: 2) and a 15-year commissioning/re-powering limit (Section Five: 4.2, with exemptions).

RE100 recognizes two subtypes of passive procurement:

1. Default Delivered Renewable Electricity from the Grid, Supported by EACs (Section Four: 5.1):

   • Description: This covers the renewable portion of a utility or supplier's standard/default mix delivered passively (e.g., via RPS compliance or publicly owned resources). Companies can claim their pro rata share if the supplier retires equivalent Energy Attribute Certificates (EACs) on behalf of all customers, preventing double-countingdouble counting.

   • Key Boundaries and Limits:

     • Claims are capped at the verifiable renewable share in the default supply (e.g., if a supplier's mix is 20% renewable with EACs retired, a customer can claim 20% of their load as renewable).

     • If part of the load is actively procured (e.g., via a green tariff), passive claims apply only to the unmet portion (e.g., for 100 MWh total load with 60 MWh voluntary, passive claims are limited to the renewable share in the remaining 40 MWh).

     • Compliance mandates (e.g., RPS) alone do not suffice; EACs must be retired, and claims cannot include renewables sold voluntarily (e.g., via premium products like Korea's Green Premium, which RE100 classifies as retail contracts).

     • EAC cancellation is required in markets where EACs are common (Appendix C lists markets like the U.S./Canada, Europe, China, and India), with supplier disclosure of retired EACs (portfolio approaches acceptable).

   • Sustainability and Impact: Excludes coal co-firing (Section Five: 3) and subjects claims to a 15-year asset age limit (exemptions for grandfathered pre-2024 contracts or up to 15% of total consumption). Claims must align with market boundaries (Appendix B: e.g., U.S./Canada as one market; specific European countries as a single market).

   • Compliance with Granular Registry Methodology: Our approach estimates SSS renewable shares using public data (e.g., RPS retirements, grid mix percentages) and allocates pro rata entitlements via load ratios, mirroring RE100's EAC-supported defaults. The Registry's third-party proxies ensure exclusive claims without double-counting, and our hourly extensions (optional in SSS methodology) support RE100's vintage limits for granular tracking.

2. Default Delivered Renewable Electricity from the Grid in Markets with ≥95% Renewable Generation Mix and No Allocation Mechanism (Section Four: 5.2):

   • Description: In highly renewable national grids without EAC systems or specific allocation (e.g., Paraguay, Uruguay, Ethiopia as of 2025), companies can passively claim 100% renewable consumption for grid-sourced electricity. This does not apply to sub-regions, imports, or non-grid sources.

   • Key Boundaries and Limits:

     • Applies only to entire markets meeting the 95% threshold on a generation basis (verified via credible data like national statistics).

     • Excludes markets with EAC mechanisms (e.g., Norway, Iceland) or significant non-renewable imports (e.g., Nepal).

     • List is dynamic; RE100 reviews as markets evolve.

   • Sustainability and Impact: Still requires adherence to credibility principles, excluding unsustainable sources (e.g., non-certified biomass/hydropower per Section Three).

   • Compliance with Granular Registry Methodology: For these markets, our Registry uses grid mix data (e.g., Ember or national reports) to validate ≥95% thresholds and allocate full passive claims without EACs, ensuring no over-claiming. This aligns with RE100's boundary approach, and our data quality hierarchy (e.g., regulatory filings) provides verifiable proxies where supplier data is absent.

Broader RE100 Alignment and Compliance Affirmation

RE100's passive procurement guidance emphasizes preventing "free-riding" on defaults by capping claims at grid/supplier mix shares and requiring EACs for credibility—directly supporting SSS principles like pro rata allocation and anti-shuffling measures from GHG Protocol drafts. The Granular Registry complies by:

• Estimating SSS shares via public sources (e.g., RPS retirements, public ownership data) when suppliers don't allocate, ensuring claims do not exceed verifiable grid mix boundaries.

• Enforcing exclusive ownership through EAC tracking proxies and residual mix adjustments.

• Supporting RE100's 15-year limit and market boundaries (e.g., via commissioning date checks in our data catalog).

• Enabling transparency with Jupyter notebooks for calculations, facilitating third-party verification (Section Six: 3).