FAQ - Electricity labelling and certificate of origin

The purpose of electricity labelling is to provide end users with information about the composition and origin of the electricity they consume. At least once a year, electricity supply companies are required to indicate – either on, or together with an electricity bill – the source from which their electricity has been produced, and whether it was produced in Switzerland or abroad.

It is not possible for consumers to directly identify the source of the electricity they consume. For this reason, an accounting system was introduced: a certificate of origin is created during the production stage, and this is validated when the electricity is consumed. With this method, the production details can be allocated to the end consumption stage independently of the physical and commercial electricity flow. In this way it is possible to ensure that a specific grade of electricity (e.g. 100 kWh solar power from Switzerland) can only be sold as such once.

Article 9 of the Federal Energy Act (SR 730.0) forms the legal basis for the certification of origin of electricity, as well as for electricity accounting and electricity labelling. Following the total revision of the Federal Energy Act, the Federal Energy Ordinance (SR 730.01) was also totally revised and it entered into force together with the Act on 1 January 2018. The Ordinance of the Federal Department of the Environment, Transport, Energy and Communications (DETEC) on the Certification of Origin and Labelling of Electricity has replaced the previous DETEC Ordinance of 24 November 2006 on the Certification of Origin of Electricity.

The electricity labelling guidelines of the Swiss Federal Office of Energy (SFOE) (www.bfe.admin.ch/stromkennzeichnung > Vollzugshilfen für Energieversorgungsunternehmen/Tools for electricity supply companies) contain comprehensive instructions concerning electricity labelling.

A list of all Switzerland’s suppliers and their electricity mixes can be viewed on www.stromkennzeichnung.ch (not available in English). This website also contains background information about the operational implementation of electricity labelling, as well as about electricity production and electricity consumption in Switzerland. It also contains links to the relevant legal bases.

The full declaration requirement is also based on the following audit mandate (Diener-Lenz parliamentary postulate):
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In accordance with Article 9, paragraph 3b, of the Federal Energy Act the electricity labelling requirement applies to all electricity suppliers who deliver to end users in Switzerland. In other words, it is suppliers (and not network operators) who are responsible for electricity labelling.

The labelling requirement also applies to electricity suppliers who deliver less than 500 MWh per annum to end users. However, in accordance with Article 4, paragraph 4 of the Federal Energy Ordinance these suppliers are exempt from the requirement of publication on www.stromkennzeichnung.ch.

The designation of energy sources is legally binding. Only those designations of energy sources specified in Appendix 1, section 1.1 of the DETEC Ordinance on the Certification of Origin and the Labelling of Electricity may be used.

From the delivery year 2025 onwards, a graphical comparison of the ordered product with the supplier mix of the electricity supplier must be made for electricity disclosure. This is to be displayed on the bill, for example as a pie chart. When issuing the bill, the electricity supplier addresses the end consumer individually, which is why it is important here to show the ordered product transparently and in comparison to the supplier mix.

The SFOE recommends rounding percentages up or down to the nearest decimal place. More detailed figures may be indicated in the case of very small percentages. Standard commercial practice should be observed here.

Energy obtained from sewage treatment plants is classified as biomass.

No. The SFOE merely recommends an annual audit. Suitably qualified auditors in the electricity sector include Naturemade, TÜV, PWC.

Following the entry into force of the revised Federal Energy Act of 30 September 2016, only the standard certificates of origin as specified in the DETEC Ordinance on the Certification of Origin and the Labelling of Electricity are accepted. However, it is also possible to use alternative electricity certificates, which can be issued for electricity production in countries in which no certificates of origin are issued for the production of electricity from non-renewable energy sources. These certificates can be used for the trading of electricity certificates in Switzerland.

Second-priority certificates (e.g. based on electricity supply contracts or on agreements with independent producers) may no longer be used for electricity labelling purposes.

As before, suppliers are required to provide their end users with an electricity label by the end of the following year, e.g. either on or together with their electricity bill.

In addition, by not later than the end of June in the following calendar year, companies subject to the electricity labelling requirement also have to publish their supplier mix and the total quantity of electricity supplied to their end users. These details have to be published via the freely accessible website, www.stromkennzeichnung.ch. All electricity suppliers are required to record their supplier mix in the electricity certification system operated by Pronovo.

Electricity labelling for consumers must be carried out at least once per calendar year, e.g. either on or together with the electricity bill. Suppliers are at liberty to choose the form and extent of the enclosure containing the electricity label, as long as the mandatory requirements stipulated in Article 4 of the Federal Energy Ordinance and Article 8 and Appendix 1 of the DETEC Ordinance on the Certification of Origin and the Labelling of Electricity are fully complied with. Electricity labels may also be sent together with an electronic invoice.

It is important that the customer is individually informed about the product she or he has ordered and that the comparison with the supplier mix is made transparent.

No. Although they do not have to be published on the electricity supplier's website, they do have to be posted on the common website for all Swiss electricity suppliers. If the information provided to end users includes the product mix according to Article 4, paragraph 2 of the Federal Energy Ordinance, in the publication on the common website (www.stromkennzeichnung.ch) reference must also be made to the location of the supplier mix.

Publication on the Internet alone is not sufficient.

Free-market end users who make use of their right to access the network in accordance with Article 11, paragraph 2 of the Federal Electricity Supply Ordinance can procure their electricity on the open market.

Point 2.2.6.4 in the Electricity Market Model Handbook of the Swiss Association of Electricity Producers (VSE) states that a supplier procures energy and, where applicable, certificates of origin, from one or more traders and/or producers for supplying its end users. Each supplier is allocated the data points of its end users and production units.

This means that, in each case and regardless of the type of contract, the supplier is subject to a labelling requirement for the allocated data points for the entire quantity of procured electricity.

In addition to suppliers subject to a labelling requirement, suppliers who are not subject to this requirement can also effect cancellations in the certification of origin system. This applies, for example, if an end user wishes to show a high proportion of renewable energy, perhaps in line with the principle of corporate social responsibility, for a company’s sustainability report or for covering the proportion of the required electricity for the production of a label.

If an end user procures certificates of origin from another supplier than the one for which it is subject to a labelling requirement, these certificates can be cancelled as follows:

a) Transfer of the certificates of origin to the supplier subject to a labelling requirement. The latter then cancels them under the heading “Electricity labelling for Switzerland” and includes them in the electricity label.

b) The supplier subject to a labelling requirement procures certificates of origin and takes them into account in its electricity label. The supplier who is not subject to a labelling requirement cancels the additionally acquired certificates of origin under the heading “Voluntary market”; the involved quantity of electricity is labelled twice with certificates of origin.

Further information is available in section 3.2.1 of the SFOE’s electricity labelling guidelines.

Yes. The only requirement is that end users must receive at least one definitive declaration per year.

All end users have to receive an electricity declaration once a year. In theory, this also applies to customers with temporary connections, but in practice there are cases in which this is not possible.

No, the electricity declaration does not necessarily have to be available on the supplier’s own website. It does however have to be published on the common website of all electricity suppliers.

Yes. The electricity label must be delivered to end users either on or together with their electricity bill. Additional information, e.g. an offer for a hydropower product or a newsletter, may be included in the same delivery.

No. The Energy Ordinance merely stipulates that electricity accounting must be carried out. This may be in electronic form or on paper. What is important here is that the accounts are clearly structured and complete, and that, if they are subjected to an audit, they are found to contain plausible data. However, the method used by the SFOE has proved to be a good basis for many electricity companies.

Yes. Electricity accounting is a legal requirement. Article 9, paragraph 3 of the Federal Energy Act of 30 September 2016 stipulates that companies subject to a labelling requirement must also carry out electricity accounting. Accounts may be kept in any suitable form. The SFOE has posted accounting examples on its electricity labelling website: www.bfe.admin.ch/stromkennzeichnung.

As long as you are not a contractual partner in this chain, you do not have to take account of such transactions. These sales do not affect your electricity accounting and declaration.

The electricity accounting examples produced by the SFOE are available as Excel files on the following web site (under "Tools for electricity supply companies"): www.bfe.admin.ch/stromkennzeichnung.

Figures may be reported in kilowatt hours (kWh), megawatt hours (MWh) or gigawatt hours (GWh).

A non end user is an entity such as an electricity producer or trader.

End users are clients who buy electricity for their own consumption. Exceptions: purchase of electricity by power plants for their own requirements, and by pump storage power plants for the operation of their own pumps.

Storage systems with end use (stationary storage systems in buildings or bidirectional charging stations for electric vehicles) are also end users.

Yes. Any form is acceptable, as long as the accounts are clearly structured and correct. The SFOE has posted sample accounting methods as Excel files for downloading (www.bfe.admin.ch/stromkennzeichnung).

Electricity declaration is based on figures for each calendar year. If no precise data are available for individual suppliers or clients, estimates have to be made, which then form an integral part of the electricity accounting and must be presented when an audit is carried out.

Transmission losses must be reflected in the accounts.

Example
Sale of 100 percent energy with certified quality, purchase of 103 percent energy with certified quality, 3 percent transmission losses in own network. Upon purchase, the 3 percent was booked in the accounts. This results in a surplus of 3 percent, which may be used at the company’s own discretion.

As pump energy is a form of storage and not production, no guarantees of origin (GOs) are issued for pump energy (for further details, see "Leitfaden zum Einsatz von Pumpen"). It is therefore not possible to convert GOs of electricity from other sources (such as coal or wind) into hydropower GOs through pump storage. If the electricity for pumping is to come from renewable sources, there need to be corresponding GOs in the portfolio. The GOs for energy that is lost during the pump storage process have to be cancelled.

Here, free market forces come into play. Certificates, which are often not tied to physical deliveries, can be bought and sold at any time as long as the regulations are duly observed. In Switzerland, certificates are offered or purchased by numerous major producers, traders, distributors and organisations.

Certificates are generated for all forms of electricity production, including from block heat and power plants. The decisive factor here is that the produced energy fed is certified by means of a meter. In the case of oil-fired block and heat power plants, certificates are generated in the "oil" category, and with gas-fired plants they are allocated to the "gas" category.

In accordance with the Swiss Code of Obligations, accounts, vouchers and business correspondence must be archived for a period of ten years. In the case of ISO-certified companies, this period may be longer.

Yes, sale to third parties is possible. The network operator then only receives the physical delivery of energy, without a quality certificate. The operator of a photovoltaic facility, for example, can feed the produced electricity into the local network and in return receive remuneration for the supplied energy (obligation of network operators to accept energy). The operator can sell the certificate of origin either to the local network operator (here an obligation to accept does not apply) or to any other customer. The applicable tariffs for most network operators are published on the following website: www.pvtarif.ch. Here, the photovoltaic facility must be registered in the certification of origin system operated by Pronovo and the production data have to be transmitted to it.

These transactions are normally carried out on the exchange without certificates of origin. In other words, they concern electricity without certified quality. The introduction of full declaration means that the entire quantity of electricity supplied to end users must be verified with certificates of origin. Thus for the quantity of electricity purchased without certified quality the certificates of origin have to be acquired separately.

If in a European country no European certificates of origin are issued for electricity production from non-renewable sources, the relevant authority can register alternative electricity certificates. For this purpose, the producer has to provide the authority concerned with confirmation of the fact that the origin of the involved quantity of electricity will not be allocated to anyone else. Alternative certificates are only permissible for trading and cancellation within Switzerland.

In electricity accounting, own consumption (i.e. electricity consumed by the supply company itself) may be deducted from the total electricity sales to end users. If 100 percent hydropower is used for own consumption, the corresponding quantity has to be booked as own consumption. If own consumption is met using the same electricity mix as supplied to end users, it is booked as part of the total electricity sales to end users.

Certificates of origin may be sold. Prices for different quality levels may be specified freely.

The applicable EU Regulation (2018/2001) governing renewable energy stipulates that declaration of electricity towards end users is mandatory in all EU member states.

These costs have to be allocated to sales.

The CO2 emissions and radioactive waste quantities are shown on each GO and can therefore be added up over a certain amount of electricity supplied.

The cancellation report PDFs and the Excel reports from the GO system offer the option of calculating, for example, the total of CO2 emissions per discloure year, per electricity product or even an average value for one kilowatt hour.

Since January 1, 2009, a surcharge has been levied on the transmission costs of the high-voltage grid to promote renewable energies (grid surcharge). This surcharge can be passed on to the lower grid levels and ultimately to the end customers. If an end customer pays the grid surcharge, they are also entitled to the corresponding quality of the subsidized electricity. This is why this share is shown as “subsidized electricity” in the electricity disclosure. Every year, SFEO publishes the fixed percentage of promoted electricity that must be shown to end customers (Certificates of origin and electricity labelling > Tools for electricity supply companies.

Quarterly disclosure provides a better reflection of the seasonality of electricity production and consumption, thus increasing the transparency of electricity disclosure. End consumers can be sure that the declared origin of the electricity matches their consumption seasonally.

Until now, it has been possible to use guarantees of origin from the summer to account for electricity consumption in the winter, even though electricity has to be imported in some cases during the winter. This distorts the actual situation, which is mitigated by the quarterly disclosure.

When ordering and purchasing GOs, in particular when ordering future production, a clear distinction must now be made between production quarters. It is no longer sufficient to order GOs for a specific year; instead, orders must be placed for specific quarters.

Yes, with the quarterly electricity disclosure, electricity sales must be recorded quarterly and the same amount of GOs from the corresponding production quarter must be canceled. The requirement of 66 percent domestic, renewable energy from the 2028 supply year in the standard product onward must also be met for each quarter. However, the electricity disclosure is sent out once a year, as before.

If no smart meters have been installed, standard load profiles must be used to estimate quarterly consumption. The industry can make recommendations in this regard.

Standardized feed-in profiles can be used for small photovoltaic systems. Production is significantly higher in the two summer quarters than in the winter quarters.

The subsidized portion of electricity generation will also be reported quarterly. To this end, Pronovo publishes quarterly estimates (in German).

However, since the electricity disclosure does not have to be done until the following year, it is also possible to wait for the final values. What is important is that at the time of the quarterly cancellations, there are enough GOs available corresponding to the amount of electricity delivered in a given quarter (including the share of subsidized electricity).