Can market-based certificates (Guarantee of Origin, Renewable Energy Certificates, etc.) be used to justify the use of actual emission factors?
During the transitional period, the general rule for the emission factor for electricity is to use default values which will be provided by the Commission. However, actual emission factors for electricity can be used if the relevant conditions are met (i.e., existence of a direct technical link or a power purchase agreement, as explained above).
Market-based specific emission factors, determined for example by Guarantees of Origin or Green Certificates cannot be used to justify the use of actual emission factors.
Further information can be found in Section D.2 of Annex III to the CBAM Implementing Regulation and in the guidance document for non-EU installations, Section 6.7.3.2.
Source: EC’s Questions and Answers on CBAM
CBAM Regulation and Guidance document for non-EU installations
CBAM Regulation 2023_1773
Guidance document for installation operators outside the EU