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):
https://www.admin.ch/gov/de/start/dokumentation/medienmitteilungen.msg-id-60276.html

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.

The size of the declaration table is clearly stipulated: it has to be at least 7 centimetres high and 10 centimetres wide. The designations of the various energy sources are also stipulated. However, no requirements apply with respect to size and style of font and other design elements.

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.

Yes. The minimum requirement is a table that is at least 7 centimetres high and 10 centimetres wide. Diagrams, pie charts, etc., are permitted as long as they do not interfere with the clarity of the declaration.

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.

In principle, no. An electricity label based on certificates of origin must be produced for each kilowatt hour of electricity supplied to end users (cf. Federal Energy Ordinance, Article 4, paragraph 1). This means that, since supply year 2018, no more electricity from an unknown source may be declared for an electricity label (principle of full declaration). The only exception applies to supply contracts that were concluded prior to 1 November 2017: here, the electricity may still be declared as originating from an unknown source (cf. Federal Energy Ordinance, Article 79) until supply year 2020. The term “supply contracts” refers to agreements with end users on the free market, not with end customers with basic supply.

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 sections 2.4.2 and 2.4.3 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.

If end users are to be informed about the origin of their specific electricity, the supplier has to opt for the product mix. With the product mix, each group of customers receives a declaration specific to their order. With the supply mix, on the other hand, all customers receive the same declaration. For further information, please refer to the "Leitfaden Stromkennzeichnung".

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.

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.

If players on the solar power exchange pass on the ecological added value of the produced electricity to their supply company, the certificates are transferred to the latter. They are booked in the accounts under certificate of origin. For the declaration of the supply mix, the allocation of certificates from the solar power exchange is made proportionally to all end users. If the client group with a (partial) solar energy product is to be provided with a specific declaration (your electricity mix: XX percent solar energy), the electricity supplier has to opt for the declaration of the product mix.

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.

No, so far, declaration of radioactive waste in the electricity declaration is voluntary in Switzerland.

Since 1 January 2009, a surcharge is collected on the transmission costs of the high-voltage network to finance the promotion of renewable energy (feed-in remuneration at cost). This surcharge may be passed on to lower network levels and ultimately to end customers. End customers who pay the associated fee are also entitled to receive the corresponding electricity category. Each year the Swiss Federal Office of Energy (SFOE) publishes the fixed percentage of subsidised electricity that has to be declared (www.bfe.admin.ch/stromkennzeichnung > Tools for electricity supply companies).

The supplier mix indicates the composition of the overall supply to all an electricity supplier's end customers. Thus all customers receive the same uniform electricity mix, regardless of the product they have purchased. By contrast, the term "product mix" refers to the specific electricity mix that is allocated to the individual customer groups.

In terms of processing, the product mix is simpler, but does not permit any differentiation by customer group. Depicting the individual product mix is more complex because the corresponding accounting system has to be prepared. On the other hand, with a product mix it is possible to inform each customer about their individual electricity composition.

An electricity supplier has to decide whether it declares the supplier mix to all its end customers or the product mix to all its end customers. A free combination of product and supplier mix is not possible. If a supplier has decided in favour of the product mix, it may also inform its end customers about the supplier mix. Suppliers are required to publish their supplier mix on the electricity labelling website (www.stromkennzeichnung.ch), regardless of the option they have chosen.

If both methods were to be combined, this would result in duplicate marketing of certain electricity categories. This can be illustrated using the following simplified example: Customer A purchases solar electricity only, and customer B purchases nuclear electricity only. Customer A receives information about the product mix, and customer B receives information about the supplier mix. In this case, customer A only "sees" his solar electricity, while customer B "sees" an electricity mix in which customer A’s solar mix is included. In this example, the solar electricity is declared twice (and a portion of the nuclear electricity is not declared to anyone).

One solution is to differentiate between customers who buy a special product and the remaining customers. Customers who choose to buy a specific product receive a corresponding declaration, while the other customers receive a declaration concerning the remaining mix from the other electricity sources. The supplier mix then comprises this remaining mix as well as the electricity explicitly sold as products.

Another option is to offer products, but declare the supplier mix to the customers. Purchased products may not be explicitly declared in the electricity labelling table, but the purchased product may be indicated in the form of text or a graph with wording such as: "With your purchase of product XY you are supporting the development of renewable energy" or "By choosing product XY you are helping ensure that the corresponding quantity of (e.g.) solar electricity has been produced and fed into the grid".

The legal basis for electricity labelling is Article 9 of the Federal Energy Act (730.0), while the legal provisions governing the product and supplier mix are specified in Article 4, paragraph 2 of the Federal Energy Ordinance (730.01), and in Figures 1 and 2 in Appendix 1 to the DETEC Ordinance on the Certification of Origin and the Labelling of Electricity.

No. Only one mix (either the producer or the supplier mix) has to be included in the information that is sent to end users. However, the supplier mix always has to be published on the electricity labelling website (www.stromkennzeichnung.ch).

If an electricity supplier chooses the product mix, in the information delivered to end users attention must be drawn to the publication of the supplier mix on the electricity labelling website (www.stromkennzeichnung.ch) (cf. Appendix, DETEC Ordinance on the Certification of Origin and the Labelling of Electricity, section 2.5).

If these end users are to be given specific information, the electricity supplier has to cite the product mix. Here, each customer group receives a label based on its electricity purchase, whereas with the supplier mix all customers receive the same label. For further information please refer to the SFOE’s electricity labelling guidelines (Leitfaden zur Stromkennzeichnung).

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.

The SFOE’s guide to electricity labelling (www.bfe.admin.ch/stromkennzeichnung > Tools for electricity supply companies > "Leitfaden Stromkennzeichnung") contains detailed information about electricity disclosure in Switzerland.

The explanatory report dated 10 February 2011 (not available in English) on the revision of the Federal Energy Ordinance that entered into force on 1 October 2011 contains background information regarding the introduction of the product mix.

On the www.stromkennzeichnung.ch website (not available in English) you will find a summary of all supplier mixes in Switzerland, as well as background information on electricity labelling, certificates of origin and the various energy sources.