2025 is the year that the RE100 change how they recognise green claims

I’ve been following Flexidao for a while, and they recently published an interesting post about updates from the RE100, and the new way the recognise claims around Green Energy. I figured it’s worth sharing here as I think it has implications on how people talk about green energy in datacentres – a long running, and now professional interest of mine.

What do the RE100 rules say?

The key thing about the RE100’s rules, and their technical guidance has been our for a at least two years, is that they now care more about additionality, and more about deliverability.

Understanding additionality

Additionality in this context is largely about relying on power from new green energy brought on stream, rather than claiming energy from old, existing green generation.

This matters because of you’re claiming energy from existing green energy supplies, there’s a risk that you’re not really helping speed a transition from fossil fuels – you’re just reallocating who gets credits for the existing generation.

Their new rules now require green energy claims to come from new-ish generation sources, with a minimum age of 15 years.

Understanding deliverability

The other thing the new rules cover is deliverability. This matters because if you’re in Germany running a datacentre, and then you’re claiming green energy based on certificates from Iceland, then there’s no physical connection between the two – it’s not physically possible to power that datacentre with the geothermal energy generated up on the island of Iceland.

So, the new rules broadly lay out that if you want to claim green energy, the certificates you use to claim green energy need to come from a energy plant where there’s some kind of physical connection, with sufficient capacity to deliver the green energy.

This matter most for Ireland, which is well.. and island, in both geographic AND grid terms. There are a lot of datacentres in Ireland run by big tech companies, many make claims about running on green energy based on these certificates.

Under these new rules, the claims by about running on green energy would not be accepted by the RE100.

Does this matter?

Honestly, I’m not sure yet.

In Ireland, we have seen cases where energy companies claiming to use green energy have been banned from making such claims by their Advertising Standards Agency, on the basis that it’s deceiving consumers.

If you follow the GHG reporting rules, and the European’s Unions own guidance on selling green energy, which more or less say every unit of power needs to be backed by a certificate issued in the European Market to be sold as green power, then they can probably get away with it for now, because there’s no requirement for deliverability to be respected.

At the same in Europe, the more recent rules on receiving subsidies for Green Hydrogen are dependent on are based on a ‘three pillars’ basis (timely, additional, deliverable), precisely to avoid the consequences of polluting activity being passed off as green.

From the point of view of the grid, a datacentre and a electrolyzer are not that different – they both use loads of energy, and represent a very dense, heavy load on the grid.

So, from that point of view, it’s reasonable to apply the the same kind of restrictions on green energy claims to both datacentres and electrolyzers alike.

I’m not aware of any pending court cases deciding this yet. I’ve love to know if so, as I see it as an unanswered question right now, and while I have my own point of view, I’m not a judge, or lawmaker.


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