BEIS designing a Framework for Transparency of Carbon Content in Energy Products - Which? response

Summary

Which? welcomes the opportunity to respond to this consultation. Consumers are keen to play their part in reaching net zero and must be able to trust that when they choose a product or service claiming to be green that it gives the benefits and value they expect. Customers can only support those companies making additional investments into clean power if it’s clear which they are, and action is needed from the Government to empower consumers and ensure they are provided with the clear and reliable information they need.

• Which? research has found that there is often a mismatch between consumers’ expectations of ‘renewable’ and ‘green’ tariffs, and the approach taken by energy companies. We also found evidence of confusing messaging by companies, for example suggesting that customers can get 100% renewable electricity supplied to their homes, which isn’t technically possible if they have a standard grid connection.
• The current system of retrospective annualised matching (using REGO certificates) does not provide a sufficient level of consumer transparency. We found that some firms imply that buying REGOs is the same as putting renewable power into the grid, but often there is not such a direct connection.
• The lack of official definitions for ‘green’ and ‘renewable’ energy tariffs makes it difficult for consumers to identify which companies are doing the most to invest in low carbon electricity generation. The definition of these terms should be clarified in regulations so that their usage is standardised, and consumers can have greater clarity over what they are buying.
• The Government should also consider mandating energy companies to provide more information to consumers on where the renewable electricity and gas they supply comes from, including what approach they take to buying renewable power and to what extent.
• Any future green or low carbon tariff framework should leave space for supplier innovation, and to reward different approaches that genuinely provide additional investment in renewable generation. In particular, a future tariff framework must accommodate the needs of electric vehicle drivers, and allow for developing concepts such as vehicle-to-grid charging.
• The tariff regulatory framework should also take into account ‘green gas’ tariffs in order to future-proof the approach. This should include clarifying the terminology, requiring companies to provide adequate information to consumers, and clarifying whether carbon offsetting should be permitted in the definition of ‘green gas’.