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Making Environmental Claims


Buying Green Power

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One reason organizations buy green power is so they can make environmental claims (express or implied). Several basic factors should be addressed when making environmental claims:

  1. Ensure your contractual right to make claims. You should ensure that your green power purchase contractually conveys the full rights to the environmental benefits of the generation source. Your organization must retain these rights in order to make an environmental claim.
  2. Ensure your purchase does not count towards a mandate. Buyers of unbundled renewable energy certificates (RECs) or bundled green power products should ensure that their supplier is not also applying the underlying attributes and environmental benefits to a mandate (e.g., a state renewable energy portfolio standard [RPS]). Such a situation would constitute a double claim between you and your supplier.
  3. Make claims that match the scope of your purchase. If you are buying green power for a subset of your organization, you should communicate the scope of your purchase when making your claims.
  4. Retain ownership of RECs for on-site green power. If you own an on-site renewable electricity generation source, you should avoid selling the associated RECs of the on-site source if you wish to make an environmental claim. Selling the RECs transfers your claim on the renewable attributes of the system to the buyer of the RECs.
  5. Retire the RECs associated with your green power purchase. Your organization should retire the RECs associated with its green power purchase. Organizations should not transfer or sell RECs after a claim has been made. Making a claim constitutes a retirement of the REC; any sale or claim by a different owner would constitute a double claim. In taking these steps, you help avoid two different parties claiming the same green power benefits.
  6. Support your claims by buying certified or verified green power products. If your organization is buying green power, especially RECs, you should consider specifying products that are independently certified and verified by a third-party. Certification can provide credibility and confirmation of the product’s environmental value. Verification is based on an audit—independent of the provider—that confirms that you get what was promised, both in quality and in quantity. Audits ensure that no one else is making a claim on the same environmental benefits.
  7. Limit claims to indirect emissions. Your organization should be careful when making claims of emissions reductions. If you are buying renewable electricity or RECs, you are reducing your indirect emissions. Indirect emissions are those resulting from electricity generation that an organization buys from an electricity service provider. An organization buying green power can claim to be reducing its carbon footprint, but cannot claim to be reducing its total emissions to the atmosphere.
  8. Avoid claiming emissions reductions not included in your purchase. In emissions markets regulated by cap and trade programs, such as with nitrogen oxides (NOx) and sulfur oxides (SOx), your organization can claim an emission reduction only if it buys and retires emission allowances. These allowances may be as part of, or separate from, buying RECs.
  9. Use the terms “REC” and “offset” correctly in your claims. The term “offsets” has various definitions among greenhouse gas registries and programs. Often, RECs are not the same as offsets. In voluntary markets, offsets are emissions reductions that are achieved through projects that cause verifiable emissions reductions outside the scope of an organization’s direct or indirect emissions. In regulated cap and trade programs, offsets can have a specific legal meaning as a noun. Describe your purchase as avoiding carbon emissions, such as “This purchase of RECs avoids __ tons of carbon dioxide (CO2).”
  10. Use Emissions & Generation Resources Integrated Database (eGRID) utility subregion emissions rates when calculating carbon equivalencies. eGRID is a comprehensive inventory of environmental attributes of electric power systems. The preeminent source of air emission data for the electric power sector, eGRID is based on available plant-specific data for all U.S. electricity generating plants that provide power to the electric grid and report data to the U.S. government. eGRID contains air emission data for NOx, sulfur dioxide, CO2, and mercury. For assistance using this data, please contact your EPA account manager.
  11. Follow Federal Trade Commission and National Association of Attorneys General green marketing guidance (PDF) (21 pp, 206K, About PDF). These guides apply to environmental claims included in labeling, advertising, promotional materials, and all other forms of marketing, whether asserted directly or implied through words, symbols, emblems, logos, depictions, product brand names, or through any other means, including marketing through digital or electronic means, such as the Internet or electronic mail. The guides apply to any claim about the environmental attributes of a product, package, or service in connection with the sale, offering for sale, or marketing of such product, package, or service for personal, family, or household use, or for commercial, institutional, or industrial use.

Partner organizations are encouraged to contact their EPA account manager for assistance when making claims.

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