Feedback to Consultation on the CBAM Carbon Methodology
Properly recognising corporate power purchasing agreements in carbon accounting rules.
Download the position paper
SolarPower Europe and its Battery Storage Europe Platform have responded to the European Commission’s consultation on carbon accounting methodology.
Within the current CBAM framework, SolarPower Europe acknowledges and supports the existing provision allowing importers to apply an actual electricity emission factor for the calculation of indirect emissions where there is a corporate renewable power purchasing agreement, or a direct technical link to the generation source.
To be workable, the Power Purchasing Agreement (PPA) definition should clearly include arrangements with intermediaries – such as utility-sleeved, portfolio or aggregator PPAs – where a third party procures renewable energy from producers and supplies it to industrial consumers. Similarly, virtual (financial) PPAs should also be recognised under CBAM.
The verification and reporting rules should also be tweaked to minimise compliance costs and keep administrative burden proportionate for manufacturers and importers, i.e. verification frequency should be aligned with with importers’ quarterly reporting obligations, and clear guidance should be provided for verifiers.
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