Green Electricity Certificates in Printing Factory Carbon Reports: 3 Real Boundaries — China GEC, I-REC, and Green Power Trading

In September 2026, an outdoor equipment brand client sent us a questionnaire. One section of the attachment was titled “Energy Sources,” with the following request: “Please provide proof of the proportion of green electricity used by the factory, as well as the type of green certificates used, their issuance numbers, and cancellation status.”

The customer has specified these two items very clearly—issuance number and cancellation status. This shows that their carbon team is not merely checking a screenshot confirming the purchase of green certificates, but is conducting a verification.

Here is our situation: since 2024, we have purchased green electricity through an electricity retailer and have also begun purchasing green certificates. We have completed a full carbon inventory, so our Scope 2 figures are well supported. However, when we received this questionnaire, we were unable to complete the field for the type of green certificates used, because the customer followed up with this question: “Could you please confirm whether your green certificates are GEC (China Green Electricity Certificates) or I-REC?”

This is a highly professional and critical question, because we have Chinese Green Certificates, while the other party will most likely only recognize I-REC.

This article covers three things: what China’s Green Certificate is, what it can and cannot prove, and which three criteria printing companies should first confirm when responding to this type of questionnaire.

The first boundary: China Green Electricity Certificates, GEC, and I-REC are three distinct instruments and cannot substitute for one another

First, let’s clarify the names, since they are often written inconsistently in customer questionnaires.

NameNatureCoverageInternational RecognitionChina Green Electricity Certificate (GEC)An electronic certificate issued by the National Energy Administration, serving as the sole proof of the environmental attributes of renewable electricity generated in ChinaElectricity fed into the grid from wind power, solar power, conventional hydropower, biomass, geothermal energy, ocean energy, and other projects that have been registered and documented nationwideMutual recognition between countries is under way, but it has not yet been fully accepted by the RE100 systemI-RECRenewable electricity certificates issued by the International Non-Governmental Organization, the I-TRACK FoundationRenewable power generation projects worldwideThe primary standard within the RE100 frameworkGreen electricity tradingDirect transactions based on power purchase agreements (PPAs), including physical electricity and environmental attributesDirectly linked to specific power generation projectsGreater recognition than green certificates in scenarios requiring location-based procurement

Several basic facts about China's green certificates that every printing plant must accurately explain when preparing a carbon report:

1 green certificate corresponds to 1,000 kWh of renewable energy. Any monthly electricity volume for which fewer than 1 green certificate can be issued is carried over to the following month.

Green certificates are valid for 2 years, calculated from the month in which the electricity was generated, inclusive. For the existing electricity volume from projects commissioned before 1 January 2024, the validity period of the corresponding green certificates is extended until the end of 2025. Green certificates that have expired or for which green electricity consumption has been declared complete are automatically written off by the National Green Certificate Issuance and Trading System.

Once a green certificate has been sold, it cannot be traded again, and certificates for which completed consumption verification has been declared will be written off. Therefore, the same green certificate cannot be used in duplicate for both “carbon emissions accounting” and “green electricity consumption certification.”

Renewable energy generation projects in China may no longer apply for international green certificates, ensuring the authority and uniqueness of Chinese green certificates. The practical impact on printing companies is that for projects located in China, you can only obtain GEC certificates, not I-REC certificates.

Now comes the key timeline issue. Before the issuance of Document No. 1044 in August 2023, the RE100 framework accepted Chinese Green Certificates. However, under the new rules, renewable electricity in China can in principle only be used to apply for and obtain domestic Green Certificates, and China has almost no newly added generating units eligible for I-REC issuance. As a result, the current situation is that it is extremely difficult for a printing company to obtain I-REC certificates for its factories in China under the existing rules.

This is the true situation we faced when completing the questionnaire: the client wanted the I-REC methodology, while we only had GEC, so we explained the situation honestly and provided an alternative path.

The second boundary: Green certificates prove that “the electricity is green,” but not that “the factory is green.”

This is the area where printing companies are most likely to overestimate their own performance. When client questionnaires ask for “carbon data,” many of our peers simply assume that purchasing green certificates means operating a zero-carbon factory, then report a Scope 2 emissions figure of zero. This claim cannot withstand verification.

The coverage boundary of the green certificate is very clear: it applies only to indirect emissions from electricity, namely the electricity component of Scope 2. All other emissions from the printing plant fall outside its scope:

Scope 1 direct emissions: Natural gas used to heat printing presses, diesel used by forklifts, and fuel used by vehicles on the factory grounds—none of these are covered by green certificates.

Scope 3 value chain emissions: Purchased corrugated cardboard, white cardboard, ink, and glue—this is the largest category in the printing plant's Scope 3 emissions. The carbon footprint of the packaging materials themselves falls entirely outside the scope of green certificates.

Non-electricity components of Scope 2: Energy used within the plant from sources other than electricity is likewise not covered.

Therefore, the purpose of green certificates is to reduce the figure for “electricity” under Scope 2, rather than reduce the carbon footprint reported across the board. If a printing plant responds to a customer questionnaire only by saying, “We have purchased green electricity,” and the customer then asks, “What about your paper and ink?”, the exchange becomes quite awkward.

There is another harder technical point that must be understood, as this is a new rule introduced after 2024: the draft calculation rules for the carbon footprint of electric vehicle batteries under the EU Battery and Waste Batteries Regulation explicitly state that green certificates may not be used to reduce emissions when calculating a battery’s carbon footprint. The logic behind this rule is clear: green certificates do not carry the attributes of the renewable electricity they represent, so using the purchase of green certificates to offset emissions from actual electricity consumption is considered unreliable under a strict accounting system. The EU Emissions Trading System also does not currently recognize green certificates of any kind; what it recognizes are allowances.

The customer's original words were approximately: "Our company is a RE100 member, and the report only recognizes I-REC. Could you switch to another supplier to purchase I-REC?"

Our current response is as follows: “Under the current regulations, renewable energy projects commissioned within China can only be issued China Green Certificates, and I-RECs are not available. This is not an issue with the supplier but a matter of the regulatory framework. We can do three things: first, provide the complete set of Green Certificate numbers, certified electricity generation, production dates, and cancellation statuses in the fields you require; second, provide a breakdown of total electricity consumption so that your verification team can see the actual renewable electricity coverage rate; and third, support your assessment of whether to accept GECs as evidence for Scope 2.”

A third boundary: three overlooked practical issues—expiration, deregistration, and single use

This is the layer where mistakes are most likely to occur in practice, because the "deregistration status" in the customer questionnaire refers to exactly this.

First, the validity period is 2 years, which constitutes a strict time window. The green certificate’s validity period begins in the calendar month when the electricity is generated and lasts for 2 years. This means that a green certificate purchased by a printing plant in 2026 will expire in 2028. If the client’s brand reporting cycle is once every 3 years, the certificate will have expired by the second reporting period, and the green certificate purchased in 2026 cannot be used to substantiate the electricity consumption in 2029.

This directly leads to a procurement rule: Do not stockpile green certificates. If a printing plant buys three years' worth of green certificates all at once and stores them, the certificates used in the first two years will expire in the third year, resulting in unnecessary waste. The correct approach is to purchase an annual amount based on the electricity consumption for that year. Stockpiling green certificates offers no benefit because their validity period starts from the month of production, not the date of purchase.

Second, cancellation is a one-time process. Article 24 of the Issuance and Trading Rules for Renewable Energy Green Electricity Certificates stipulates that green certificates that have expired or for which completed green electricity consumption has been declared shall be promptly cancelled by the National Energy Administration Certification and Exchange Center. Green certificates for voluntary emission reduction projects that have completed review and registration are also linked to the CCER registration platform for freezing, preventing duplicate benefits from the carbon market.

Therefore, “the same green certificate cannot be used both for carbon accounting and for green electricity consumption certification.” If both are required, you need to buy two. This is an implicit double-counting issue that many printing plants discover during internal verification.

Third, the print plant’s own green electricity procurement threshold is actually not high, but its approach is backwards. After the green certificate issuance and trading system became fully operational, the national issuance volume reached 4.734 billion in 2024, an increase of 28.36 times year over year, including 3.158 billion tradable green certificates. By the end of 2024, cumulative issuance had reached 4.955 billion, with 3.379 billion tradable certificates. In terms of prices, an imbalance between supply and demand in the green certificate market has caused prices to continue falling.

This means that, for printing plants, the cost of purchasing green certificates is no longer the main barrier. The main challenge is how to have them recognized by clients after purchase. Printing plants should therefore focus on their ability to respond to verification requests by establishing a ledger that clearly records the certificate number, issuance project, production time, corresponding electricity volume, purchase date, and cancellation status of every batch, rather than deliberating over whether to buy them.

One additional point about the data caliber deserves attention: there is a limit on the deduction of green certificates traded across provincial boundaries in the assessment of energy consumption and carbon emissions control—in principle, the amount of renewable energy consumption in the receiving province that may be offset through green certificate transactions across provincial boundaries must not exceed 50% of the energy savings required to achieve the region’s energy consumption intensity reduction target during the 14th Five-Year Plan. This limit does not directly constrain printing plants, but it explains why green certificate prices have been pushed down so sharply.

Three Scope Questions to Confirm Before Responding to This Kind of Survey

Our current standard procedure is: Upon receiving the questionnaire, first answer three questions, then provide the data.

First: Do you need a GEC (China Green Electricity Certificate), an I-REC, or a green electricity transaction certificate?The answer determines what we provide and whether the data will pass your verification. These three types of certificates belong to different systems and cannot replace one another. Submitting a China Green Electricity Certificate on a form that requires an I-REC would only create problems for you.

Second: What is this data used to calculate—Scope 2 electricity, product-level carbon footprint, or company-level ESG disclosure?Each use has different requirements for supporting documentation. Corporate-level carbon inventories and green electricity consumption certification in China can use green electricity certificates; however, the EU Product Carbon Footprint and Battery Regulation explicitly prohibit using green electricity certificates for offsetting. Let us first clarify the intended use so that we can provide the appropriate documentation.

Third: Through which reporting period do you need green electricity certificates to cover? Because their validity period is 2 years, reports spanning multiple years must be submitted separately for each year; the figures from the most recent year alone cannot cover three years.

The customer is pressing us urgently, saying, “We need to deliver by next Monday.” Our current reply is: “We can provide the data today, but I cannot choose the voucher type for you. If you select the wrong one, it will be the first thing the form reviewer checks. I’ll organize the ledger today and send it to you. Please verify it against the applicable basis; it should only take five minutes.”

One final practical recommendation: establishing a green certificate ledger is the highest-return action in this investment.Many printing plants purchase green certificates with a three-year validity period, then leave the certificates buried in email attachments. When a client requests them, it can take a long time to find them, or the plant may resort to buying one at short notice—and the certificates purchased at that moment often carry a premium. A ledger needs only four columns: certificate number, issued project and production time, corresponding electricity volume, and cancellation status.

Further Reading

Carbon Accounting for Packaging Printing Plants: Three Types of Boundaries and Four Practical Approaches for Printers When Clients Require Scope 3 Data—Green certificates only address electricity within Scope 2, while the remaining challenges are addressed here.

Operating temperature ledger for the five types of zeolite rotor and RTO systems used for exhaust gas treatment at packaging printing plants—the actual figures for Scope 1.

Observation of Packaging Raw Material Price Trends in 2026—The largest component of Scope 3: paper.

The real impact of the three categories of the new European PPWR regulations in 2026 on printing plants—packaging data requirements and documentation logic on the EU side.