Renewable energy certificates (RECs) are long-established and widely used instruments in U.S. electricity markets that enable electricity to be bought or sold as renewable. RECs are issued and tracked through regional tracking systems that collect electricity production data. RECs are recognized by the federal government and by states for use in renewable portfolio standard (RPS) and power source disclosure programs, and are also used by the private sector in voluntary-market transactions. For nearly 30 years, parties have bought and sold RECs. The voluntary market for RECs alone serves around 10 million customers, and represents about 8% of all U.S. retail electricity sales (O’Shaughnessy, Jena, & Salyer, 2025). Despite decades of experience with these instruments, their role and function can still be misunderstood, as highlighted in a September 24, 2025 letter from 16 state attorneys general to four leading technology companies. The information below explains what RECs are and why they are critical to free and functioning retail energy markets, emissions accounting, effective state regulatory programs, and consumer choice and protection.
RECs enable renewable electricity use claims on our shared grid
RECs are legally recognized contractual instruments and property rights that are the basis for renewable electricity use claims on the grid (Center for Resource Solutions, 2023a; Harvard Law Review, 2024). Because electricity on a shared transmission system carries no information about its origin or how it was generated, proving physical delivery of renewable power to specific customers is impossible. RECs are needed to substantiate claims to renewable generation (National Association of Attorneys General, 1999). RECs alone ensure transparency and prevent double counting of renewable generation and use claims. They are required in all (currently, 29) state compliance programs, as well as in voluntary markets and all renewable power purchase agreements (PPAs, Center for Resource Solutions, 2023a).
RECs enable credible emissions claims about electricity use
RECs carry the emissions characteristics of renewable generation, making them essential for credible claims about the greenhouse gas emissions associated with electricity that is delivered, sold, or consumed (Greenhouse Gas Protocol, 2015). They convey both the direct emissions of renewable generation and the avoided emissions on the grid, ensuring these benefits are accurately assigned to consumers and electricity suppliers. Without RECs, renewable generation and its emissions benefits could be assigned to different customers, undermining both compliance and voluntary programs that account for electricity use. Credible and verifiable claims about reducing the emissions associated with renewable electricity used or delivered—whether by companies, consumers, or utilities—require RECs.
Bundled and unbundled RECs provide equivalent renewable electricity and emissions claims
Electricity on the transmission grid cannot be physically tracked by generation source, so its renewable characteristics are always separate from the electricity itself (U.S. Department of Energy, 2023). RECs representing those characteristics are issued at the time renewable power is generated and delivered to the grid. Because all electricity on the grid is inherently “unbundled” from its generation source, selling RECs with or without electricity is simply a contractual choice that does not affect the validity or credibility of the claim. The claim to renewable electricity use is itself contractual, reflecting ownership of the REC. Unbundling allows consumers to express renewable electricity preferences even though the physical power they receive comes from the grid mix. The REC’s nature and value remain the same, and sourcing electricity and RECs separately within the same market is functionally equivalent to sourcing both from a single renewable facility.
Unbundled RECs expand markets, lower costs, and enable broad participation and innovation
The ability to buy and sell RECs separately from electricity lowers barriers and expands access, making renewable energy markets more affordable and inclusive for customers of all sizes (O’Shaughnessy, 2024a). RECs increase liquidity, facilitate cross-regional trading, and allow renewables to be developed where it is most cost-effective (O’Shaughnessy, 2025b). By enabling the characteristics of renewable generation, including its emissions, to be transacted separately from electricity, unbundled RECs allow participation even when direct procurement—such as long-term PPAs or onsite projects—is not feasible (e.g., due to cost, scale, location). They have also enabled innovations like virtual power purchase agreements, expanding renewable adoption nationwide.
REC demand drives renewable deployment
Demand for RECs, motivated by consumer choice and preference, sends market signals that drive new renewable development (O’Shaughnessy, 2025b). Not only do REC purchases directly support renewable deployment by influencing investment and project financing, collective consumer demand for RECs and the transparent communication of leading buyers has driven the expansion of supply over time (O’Shaughnessy, 2025a). RECs, therefore, are a central driver of the clean energy transition.
All RECs provide critical revenues that support new project development
Revenues from REC sales flow into renewable project economics, often providing the margin needed for new projects to move forward (O’Shaughnessy, 2025b). Revenues from contracted RECs directly support project financing. Short-term REC purchases from existing projects create revenue that can be reinvested into new capacity, often contributing to the equity needed for future projects. This revenue stream improves project viability, attracts new entrants, and builds long-term market confidence. RECs are therefore not just trading instruments but a vital source of support for renewable deployment.
Conclusion
RECs are the legal foundation of credible renewable electricity and emissions claims, ensuring that renewable generation and its benefits are accurately assigned to electricity use. Long utilized in both compliance and voluntary markets, RECs create the demand signals that drive renewable deployment and grid decarbonization. RECs create access, enable market efficiencies, and provide critical revenues that support new projects, making participation possible for a wide range of consumers and suppliers. They are an indispensable tool for scaling renewable energy and achieving the demand-side changes needed for the clean energy transition.
Resources
RECs and Renewable Energy Claims
- Center for Resource Solutions. (2023a, April). The legal basis for renewable energy certificates: Version 2.0. https://resource-solutions.org/wp-content/uploads/2015/07/The-Legal-Basis-for-RECs.pdf – legal substantiation for RECs, from states, federal agencies, and the courts
- Federal Trade Commission. (2012, October 11). Guides for the use of environmental marketing claims (Green Guides) (16 C.F.R. Part 260). https://www.ftc.gov/sites/default/files/documents/federal_register_notices/guides-use-environmental-marketing-claims-green-guides/greenguidesfrn.pdf – § 260.15 parts (a) and (c)): RECs are required to avoid deceptive renewable energy use claims; recognizes unqualified renewable energy usage claims on the basis of RECs
- Kohm, J. A. (2015, February 5). Letter from James A. Kohm, Associate Director, Division of Enforcement, regarding Green Mountain Power’s renewable energy statements (FTC). https://www.ftc.gov/system/files/documents/public_statements/624571/150205gmpletter.pdf – further explanation and an example of how enforcement and prevention based on FTC guidance about RECs has reduced deception about renewable energy claims
- Center for Resource Solutions. (2023b, April 24). Comments of Center for Resource Solutions in response to the FTC’s review of the Green Guides, Matter No. P954501 (CRS Comment). https://resource-solutions.org/wp-content/uploads/2023/05/CRS-FTC-Comment-4-24-2023.pdf – “REC ownership requirements for both voluntary and compliance renewable energy transactions have been reinforced since 2012, by states, the federal government, and voluntary standards.”
- National Association of Attorneys General. (1999, December 4). Environmental marketing guidelines for electricity. U.S. Environmental Protection Agency. https://19january2021snapshot.epa.gov/sites/static/files/2018-05/documents/naag_0100.pdf
- Harvard Law Review. (2024, January). Renewable energy credits as property. 137 Harv. L. Rev. 936. https://harvardlawreview.org/print/vol-137/renewable-energy-credits-as-property/ – RECs as property
- Weinstein, J. D. (2021). What are renewable energy certificates? Futures and Derivatives Law Report, 41(1), 1–12. https://www.researchgate.net/publication/349536396_WHAT_ARE_RENEWABLE_ENERGY_CERTIFICATES
- U.S. Department of Energy. (2023, December). Assessing lifecycle greenhouse gas emissions associated with electricity use for the Section 45V clean hydrogen production tax credit. https://www.energy.gov/sites/default/files/2023-12/Assessing_Lifecycle_Greenhouse_Gas_Emissions_Associated_with_Electricity_Use_for_the_Section_45V_Clean_Hydrogen_Production_Tax_Credit.pdf – “EACs are a sound contractual mechanism”
- State of New Jersey, Board of Public Utilities. (2021, April 8). In the matter of Cavallo petition for enforcement of Environmental Information Disclosure (EID) rules and for amendments to EID rules: Order (Docket No. QO20100664). https://www.nj.gov/bpu/pdf/boardorders/2021/20210407/8D%20ORDER%20Cavallo%20revised.pdf – addresses the legitimate use of unbundled RECs for NJ RPS, denies petition claiming RECs are “a misleading marketing tool”
- U.S. Environmental Protection Agency. (2018, September). Guide to purchasing green power. https://www.epa.gov/sites/default/files/2016-01/documents/purchasing_guide_for_web.pdf
- O’Shaughnessy, E., Jena, S., & Salyer, D. (2025). Status and Trends in the U.S. Voluntary Renewable Power Market: 2023 Data (NREL/TP-6A20-92289). Golden, CO: National Renewable Energy Laboratory. https://www.nrel.gov/docs/fy25osti/92289.pdf – most recent data on the full U.S. voluntary renewable energy market
- National Renewable Energy Laboratory. (2015, August 5). Renewable Electricity: How do you know you are using it? https://docs.nrel.gov/docs/fy15osti/64558.pdf
RECs and Emissions Claims
- Greenhouse Gas Protocol. (2015). Scope 2 Guidance: Guidance for corporate greenhouse gas accounting and reporting of purchased electricity, steam, heat, and cooling (Final version). https://ghgprotocol.org/sites/default/files/ghgp/standards/Scope%202%20Guidance_Final_0.pdf – RECs for corporate emissions reporting
- Center for Resource Solutions. (2022, November). Guide to electricity sector greenhouse gas emissions totals. https://resource-solutions.org/wp-content/uploads/2022/11/Guide-to-Electricity-Sector-Greenhouse-Gas-Emissions-Totals.pdf – explains the role of RECs in emissions accounting
- California Office of the Attorney General. (2024, July 23). Opinion No. 24-201 (Rob Bonta, Attorney General). https://oag.ca.gov/system/files/opinions/pdfs/24-201.pdf – explains the difference between RECs and Offsets
- California Public Utilities Commission. (2008, August 21). Decision 08-08-028: Decision on definition and attributes of renewable energy credits for compliance with the California Renewables Portfolio Standard (Rulemaking R.06-02-012). https://docs.cpuc.ca.gov/word_pdf/FINAL_DECISION/86954.pdf – avoided grid emissions are included in RECs, separate from direct emissions (e.g., zero emissions) claim, and not equivalent to offsets
Impact and Benefits of RECs
- O’Shaughnessy, E. (2024a, September 23). A more comprehensive view of the impacts of voluntary demand for renewable energy (Working paper). SSRN. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4953515
- O’Shaughnessy, E. (2024b, October 9). Categorical claims about voluntary renewable energy actions are not supported by categorical evidence. Progress in Energy, 6(4), Article 043005. https://doi.org/10.1088/2516-1083/ad81ab
- O’Shaughnessy, E. (2025a, January). Impacts of voluntary renewable energy demand on deployment: A market-based approach (Report). U.S. Environmental Protection Agency. https://www.epa.gov/system/files/documents/2025-01/impacts_voluntary_renewable_energy_demand.pdf
- O’Shaughnessy, E. (2025b, June 23). On the economics of renewable energy certificates (Working paper). SSRN. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5316219
- Zeyen, E., Riepin, I., & Brown, T. (2025). Response to “Does the purchase of voluntary renewable energy certificates lead to emission reductions? A review of studies quantifying the impact.” Journal of Cleaner Production, 524, 146253. https://doi.org/10.1016/j.jclepro.2025.146253
- O’Shaughnessy, E., & Sumner, J. (2023). The need for better insights into voluntary renewable energy markets. Frontiers in Sustainable Energy Policy, 2, Article 1174427. https://doi.org/10.3389/fsuep.2023.1174427
- CPUC Decision 10-03-021 – articulates the impact and significance of unbundled RECs in California RPS
- Perez, A.P. et al. (2016). “The Economic Effects of Interregional Trading of Renewable Energy Certificates in the WECC,” The Energy Journal, 37(4), 2016, 267-296. Executive Summary: https://www.iaee.org/ej/ejexec/ExecSum14-177.pdf – the economic benefits of unbundling; unbundling saves states and ratepayers money
- E3 (Energy & Environmental Economics, Inc.). (2024, July). Consequential impacts of voluntary clean energy procurement. https://www.ethree.com/wp-content/uploads/2024/07/E3_VoluntaryCorporateProcurement_HourlyEmissions_June-2024.pdf
- Horwitz, Y., Fratzscher, S., & Grin, A. (2024, May). “Good intentions, bad policy, and the threat to the clean energy transition: Why additionality should not be a requirement for corporate clean energy goals.” Sol Systems. https://42797541.fs1.hubspotusercontent-na1.net/hubfs/42797541/GHG%20Scope%202%20-%20Good%20Intentions%20Bad%20Policy%20Whitepaper%20-%20Final.pdf
- World Resources Institute & U.S. Environmental Protection Agency. (2018, June). Describing purchaser impact in U.S. voluntary renewable energy markets. https://www.epa.gov/sites/default/files/2018-06/documents/gpp_describing_purchaser_impact.pdf
- American Council on Renewable Energy. (2023, December). ACORE statement on the value of renewable energy certificates. https://acore.org/wp-content/uploads/2023/12/ACORE-SBTi-Statement-on-Renewable-Energy-Certificates.pdf
- He, H. et al. (April 2023). Paths to Carbon Neutrality A Comparison of Strategies for Tackling Corporate Scope II Carbon Emissions. Tabors Caramanis Rudkevich. https://tcr-us.com/uploads/3/5/9/1/35917440/paths_to_carbon_neutrality_white_paper_april23.pdf
- Holt, E., Sumner, J., & Bird, L. (2011). The role of renewable energy certificates in developing new renewable energy projects (NREL/TP-6A20-51904). National Renewable Energy Laboratory. https://docs.nrel.gov/docs/fy11osti/51904.pdf
For more information about this release, contact Jeff Swenerton, Communications Director, at +1-415-561-2119 or jeff.swenerton@resource-solutions.org.