Fuel used to meet a mandate — can it make a certificate?

There are two reasons to use low-emission fuel: because you choose to, or because a scheme requires it.

The question is this. May fuel used to meet a mandate be turned into a certificate and sold?

The SBTi evidence synthesis treats this as one of its six themes (p.18).

Both sides

One view: if the reduction was already compelled by regulation, that fuel would have been used with or without a certificate. Reselling it into the voluntary market adds no reduction that was not already going to happen.

The other: a certificate improves revenue certainty for producers and brings low-emission fuel deployment forward. Even for volumes that meet an obligation, a market that shares the premium speeds up the next plant.

It is not settled.

What can be done now

There is no need to wait for the answer. Whichever way it settles, the same thing has to be established.

Which fuel this certificate came from, and whether that fuel was used to meet an obligation under some scheme. A certificate that cannot answer that is in trouble under either conclusion.

Which is why the geography condition from the earlier article applies again here — certificates reported against a regulatory obligation should be traded only within the geographic scope that regulation defines (evidence synthesis, p.39). It is a device for managing exactly this overlap between a scheme and a certificate.

Relatedly, aviation has more still open. On sustainable aviation fuel the evidence synthesis records that "it is unclear whether book and claim chain of custody models are allowed beyond fuel blending in existing policies" (p.47).

This article expands one section of LCS EAC special report 1, Do the Reductions You Buy Become Yours? The full report works from the SBTi Corporate Net-Zero Standard V2.0 and SBTi Evidence Synthesis Report Part 2 as primary sources, with the printed page number given for every quotation.