The electricity user whose consumption is backed by the project’s renewable energy attributes can claim its green electricity—not automatically the solar plant owner, investor, or buyer of the physical power. In the U.S. REC market, the user must retain or acquire the relevant RECs and retire them, or have a supplier retire them on its behalf. If the project owner sells those RECs, it cannot also count them toward its own renewable electricity use.[1]
A valid claim depends on the contract, certificate eligibility, consumption volume, and retirement records. The examples below use hypothetical figures; U.S. and Chinese rules are addressed separately.
Who Gets the Claim When Electricity and RECs Are Sold Separately?
Suppose a solar plant generates 1,000 MWh, or 1 million kWh. Company A buys the electricity without the RECs. Company B buys the corresponding 1,000 RECs. Each REC represents the renewable attributes of 1 MWh.[2]
B consumes 2,000 MWh during the reporting year. If the RECs meet the applicable market and generation-period requirements and are retired for B, they cover 50% of its annual electricity use.
| Party | Supported statement | Limit |
|---|---|---|
| Solar plant owner | “The plant generated 1,000 MWh and sold the associated attributes.” | The owner cannot also apply the sold attributes to its own electricity use. |
| Company A | “We purchased 1,000 MWh of electricity.” | The purchase does not include the solar attributes sold to B. |
| Company B | “We matched 50% of our annual electricity use with solar RECs.” | The certificates do not establish direct delivery from the plant or hourly solar supply. |
Does Owning Rooftop Solar Give You the Claim?
Ownership of the roof or panels does not settle ownership of the environmental attributes. For a third-party-owned commercial or industrial rooftop solar system, the factory should check whether its electricity contract includes those attributes and how they will be transferred.
In the U.S., the FTC states that a business selling all the RECs from its renewable generation should not claim to use that renewable energy. Buying replacement wind RECs may support a wind-based consumption claim, but it does not restore the claim to the original rooftop solar attributes.[3]
Actual on-site consumption also matters. If a factory uses 1 million kWh annually and its rooftop system generates 300,000 kWh, of which 100,000 kWh is exported, on-site solar supplies 200,000 kWh, or 20% of factory consumption—not 30%.
The wattage in PV module specifications cannot replace these measurements. A module’s rated power describes output under stated test conditions; consumption claims need metered energy volumes and evidence of attribute ownership.
How China’s Green Certificate Rules Differ
China issues one green electricity certificate for every 1,000 kWh of eligible renewable generation. Solar electricity exported to the grid receives tradable certificates; electricity generated and consumed on site receives non-tradable certificates. Where the generator and on-site consumer are different parties, certificates are transferred to the consumer according to actual use.[4]
| Electricity volume | Corresponding certificates | Treatment |
|---|---|---|
| 700,000 kWh consumed on site | 700 | Non-tradable. If the generator and consumer differ, the first transfer requires an energy management contract or agreement and payment settlement evidence. |
| 300,000 kWh exported | 300 | Tradable certificate category. The owner must still check actual ownership, prior transfers, and applicable pricing-mechanism arrangements. |
“Tradable” does not mean all 300 export certificates remain available to the project owner. Certificates transferred through green electricity transactions cannot be traded again. Certificates linked to electricity covered by the renewable energy sustainable development pricing settlement mechanism involve provincial account arrangements.
Year Matching and Cancellation
- Generation year: From January 1, 2026, certificates cancelled for a green electricity consumption claim must correspond to electricity generated in the consumption year.
- Validity: The generation month is month zero; validity ends on the last day of month 24. An unexpired certificate for 2025 generation therefore does not qualify for a 2026 consumption claim.
- Volume: The amount cancelled should, in principle, not exceed actual electricity use in the stated consumption setting.
- Purpose: Expiry cancellation is not proof of a company’s green electricity consumption. The consumption cancellation statement must identify the holder, quantity, period, location, and use.
These requirements are set out in Articles 20 and 28–32 of China’s certificate management implementation rules.[5]
What Should the Purchase Contract Say?
A PPA for 500 MWh of solar electricity should explicitly state whether it includes certificates covering those 500 MWh. Check:
- What is delivered: Certificate quantity, project, energy source, and generation period.
- Who handles it: Delivery and retirement responsibilities, deadlines, beneficiary, and supporting records.
- What happens if output falls short: Eligible replacements, additional costs, and delivery deadlines.
- Who has exclusive use: Terms preventing resale or conflicting claims over the same attributes.
If only 450 MWh of eligible attributes are delivered and retired, a forecast of 500 MWh does not support a completed 500 MWh claim. Under a virtual PPA, financial settlement also needs to be distinguished from certificate delivery and retirement.
How Many Certificates Do You Need?
A company consumes 2,000 MWh annually and targets 60% renewable electricity. It already has 300 MWh of on-site solar consumption with eligible, retained attributes.
Additional attributes needed = 2,000 × 60% − 300 = 900 MWh.
That means 900 certificates of 1 MWh each, assuming annual matching is allowed and the certificates meet the intended claim’s requirements. Domestic consumption recognition, Scope 2 accounting, and customer procurement standards may differ.
Do not count certificates in addition to the electricity they already cover. A 500 MWh green electricity purchase with 500 matching certificates supports 500 MWh of consumption, not 1,000 MWh. For multiple sites, record each allocation so the same volume is not assigned twice.
What the Claim Does Not Cover
Annual matching does not establish round-the-clock supply. A site consuming 2 MWh during a nighttime hour cannot prove that hour was solar-matched simply because a plant generated an extra 2 MWh at noon. An hourly claim needs time-specific supply evidence.
RECs are not carbon offsets. A purchase of 1,000 RECs represents 1,000 MWh of renewable attributes, not 1,000 tonnes of avoided emissions. It cannot be converted directly into offsets for diesel, aviation, or other emissions.[6]
Under GHG Protocol’s 2015 Scope 2 Guidance, eligible contractual instruments can support market-based accounting. They do not directly change the grid emissions factor used for location-based accounting. Companies subject to dual reporting must report both results; matching all electricity use does not eliminate emissions from fuels, materials, or transport.[7]
A claim that procurement enabled a new solar plant to be built needs separate evidence, such as financing approval conditional on the PPA. A certificate purchase from an operating project does not, by itself, establish that link.
What Records Support the Final Statement?
- Consumption: Metered volume, site, user, and reporting period.
- Certificates: Identifiers, project, technology, generation period, and quantity.
- Ownership: Contract and delivery or allocation records.
- Retirement: Records naming the beneficiary and the consumption covered, including where a supplier acts on the customer’s behalf.
After verification, a factory using 1,000 MWh and retiring eligible solar certificates for 600 MWh could state:
“We matched 600 MWh of our factory’s 1,000 MWh annual electricity consumption with solar certificates retired on our behalf. This represents 60% of consumption on an annual matching basis.”