Which? published its response to the Department for Business, Energy and Industrial Strategy (BEIS) consultation on a framework for transparency of carbon content in energy products on 20 March 2023. The consumer body said it welcomed the opportunity to respond and called for clearer rules on how green and renewable tariffs are defined and described1.
Which? said its research had found a mismatch between what households expect from tariffs labelled renewable or green and what suppliers actually do. It cited confusing messaging, including suggestions that customers can receive 100 per cent renewable electricity at a standard grid connection, which it said is not technically possible1. It also said the current system of retrospective annualised matching using Renewable Energy Guarantees of Origin (REGO) certificates does not give consumers enough transparency, and that some firms imply buying REGOs is the same as putting renewable power into the grid when often there is no such direct connection1.
The response argued that the absence of official definitions for green and renewable energy tariffs makes it hard for households to tell which companies are investing most in low carbon generation, and that the terms should be clarified in regulations so their use is standardised1. Which? said the government should consider mandating suppliers to give more information on where the renewable electricity and gas they supply comes from, including their approach to buying renewable power and the extent of it1.
"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."
On future tariff design, Which? said any framework should leave room for supplier innovation and reward approaches that genuinely add investment in renewable generation. It said the framework must accommodate electric vehicle drivers and allow for developing concepts such as vehicle-to-grid charging, and should take account of green gas tariffs to future-proof the approach. That includes clarifying terminology, requiring adequate consumer information, and clarifying whether carbon offsetting should be permitted within the definition of green gas1.
Why it matters for households
The consultation concerns what a household is actually buying when it chooses a tariff described as green or renewable. Under the current arrangements described by Which?, renewable output is matched to consumption retrospectively over a year using REGO certificates, which the consumer body says does not show a direct link between a home's supply and renewable generation1. For a household weighing up a green energy tariff, the practical question is whether the label reflects additional investment in generation or the purchase of certificates. Which? says the lack of official definitions makes that distinction difficult to establish1.
The response also points to green gas, where terminology, consumer information and the treatment of carbon offsetting are all unresolved1. Households on gas heating, or considering a green gas tariff, have no standard definition to compare offers against. The Green Gas Levy is a separate mechanism and is not addressed in the response.
For homes with an electric vehicle, the framework Which? describes would need to cover charging and vehicle-to-grid arrangements, which affect how a household's demand and any export are treated1. Which tariffs a home can take up also depend on its meter, as set out in which tariffs your meter allows.
What happens next
No next steps or timetable are given in the response. BEIS has not set out in this document when or whether it will act on the points raised, and no government decision following the consultation has been reported1. The consultation itself sits within the wider process covered in energy consultations and how policy is made.