Bruk av miljøsertifikater | Norges Bank Investment Management

Av: Carine Smith Ihenacho, Chief Governance and Compliance Officer and Kristin Verpe, Senior Investment Stewardship Manager.

Vårt synspunkt

Miljøsertifikater/Environmental Attribute Certificates (EAC-er) er instrumenter som sertifiserer miljø- og klimarelaterte attributter for varer og aktiviteter.
Vi mener porteføljeselskaper bør prioritere å redusere klimautslipp fra egen drift og verdikjede. Bruk av EAC-er kan være en midlertidig løsning der dette ennå ikke er mulig.
Vi støtter generelt ikke bruk av EAC-er for klimautslipp fra egen drift, men vi støtter at det brukes i noen tilfeller for utslipp fra energiforbruk, og er positive til en mer fleksibel tilnærming for utslipp i verdikjeden.
Alle EAC-er som anskaffes bør ha høy kvalitet og demonstrere addisjonalitet, sporbarhet og verifiserbarhet.
Selskaper bør tydelig skille mellom utslippsreduksjoner fra direkte tiltak og EAC-er i rapporteringen sin

Resten av synspunktet er tilgjengelig på engelsk.

Relevance to Norges Bank Investment Management

As a long-term investor with more than 8,000 portfolio companies, we have a financial interest in an orderly transition to global net zero emissions by 2050. We expect companies to commit to aligning their business activities with this goal.

We recognize that companies may find EACs useful in implementing their transition plans. We need to balance the risk that EACs distract from investments in direct emission reductions against their role in enabling long-term decarbonization. Our approach reflects this balance while maintaining focus on business transformation.

This document is primarily focused on EAC use in the short and medium term, i.e. typically for emission targets up to 2035. In the ultimate net-zero target year, many companies will have to neutralise residual emissions with carbon removals.

Definitions

EACs are instruments that certify the environmental and climate-related attributes of commodities, activities, or projects, conveying exclusive rights to these attributes and enabling credible claims by the holder. Often, there is a geographic mismatch between those who are willing to pay for a low-carbon product or emission reduction, and those with the ability to supply it. The global market for EACs helps link that supply and demand.

EACs are usually grouped into carbon credits (which convey emission reductions, removals or avoidance) and commodity certificates (which convey the emissions profile of activities such as electricity or fuel production).

While the use cases and characteristics vary among EACs, they raise similar questions regarding their use in companies' transition plans.

Application of EACs in company transition plans

In our view, the appropriate use of EACs varies across different emission scopes. We believe a more flexible approach to EAC use is appropriate when companies have less control over their emission sources.

Scope 1 Emissions

Companies have the greatest opportunity to drive direct and durable impact through their operational decisions. Companies should prioritise reducing their own Scope 1 emissions, including through energy efficiency improvements, fuel switching, and process optimization within company operations.

EACs should generally not be counted towards interim science-based targets. Use of EACs for low carbon fuels and feedstocks could be considered if direct procurement is not available.

Scope 2 Emissions

Companies have significant influence over energy procurement decisions, though they typically depend on third-party providers rather than controlling generation directly. However, market conditions and the characteristics of the company's energy usage affect the procurement options.

Where feasible, our preference is for companies to procure clean energy through long-term contracts. We believe this sends clear market signals in support of clean energy generation. For smaller energy customers or in markets where bundled options are not available, unbundled EACs (specifically renewable energy certificates) can serve an important role.

Scope 3 Emissions

We recognize the significant challenges companies face in decarbonizing their value chains. We therefore support a flexible approach to EAC use that can accelerate progress and meaningful action in supply chains.

Companies should pursue Scope 3 emission reductions through multiple pathways. Direct mitigation and procurement should be prioritized, but several methods can be pursued simultaneously:

Supplier engagement with clear targets and timelines for value chain partners.
Commodity EACs for upstream purchased goods. We prefer instruments and procurement arrangements that help enable mitigation in the long term, including long-term purchase agreements.
High-quality voluntary carbon credits as a complement to direct mitigation and supplier engagement. We would for example consider credits meeting the Core Carbon Principles (CCPs) criteria as high quality.

Recommendations for credible use

Clear direction of travel: EACs can serve as a bridge while companies work to address the barriers that are inhibiting direct mitigation. Companies should explain their roadmap toward more direct approaches, including long-term contracts and physical procurement.
Quality and integrity: Additionality, traceability, and verifiability are crucial integrity factors across all types of EACs. The environmental attribute purchase should take place within a recognised certification and governance system.
Transparency: Companies should clearly distinguish between emission reductions from direct mitigation versus EACs in their reporting. Disclosures should generally follow GHG Protocol and ISSB guidance as a minimum, and provide information about the EAC type and volumes procured.

Following market developments

We support ongoing initiatives to improve the integrity and functionality of EAC markets.

This view is published as the Science Based Targets initiative’s (SBTi) Corporate Net Zero Standard is undergoing major revisions, and we support SBTi’s efforts to find actionable solutions for companies making credible efforts.

We are also following developments in biodiversity credits that companies may use as part of no net loss or net positive nature commitments. In line with the mitigation hierarchy, we expect companies to only use biodiversity credits as a last resort for nature impacts that cannot be avoided, minimized or restored. We continue to monitor best practices and developments in how quality considerations are accounted for. This includes the "like-for-like or better" principle, which means credits must conserve the same biodiversity values being impacted, or provide greater ecological value.

Our view on corporate use of EACs may continue to evolve over time as markets, standards and technologies develop. We will closely follow the ongoing work of standard-setting initiatives and market integrity efforts as EAC markets continue to mature and scale.

Important Information: We will not apply any policies discussed herein in circumstances where we believe that implementing or following such policies would be deemed to constitute seeking to change or influence control of a portfolio company with securities registered on an exchange regulated by the United States Securities and Exchange Commission.