RE100 Criteria Changed Again: Three Things Korean Suppliers Should Check Now

Contents (6)▾

RE100 is a programme that large global buyers join, but the burden of meeting it travels down the supply chain to their suppliers. Because the RE100 accounting criteria changed twice over in 2024 and 2025, the approach of "just buy some certificates" no longer works. Here are the three changes a semiconductor supplier should check now.

Why suppliers need to follow these changes too

RE100 is joined by the buyer at the top of the chain, but the burden of meeting it travels down the supply chain to suppliers. Once a buyer starts treating "renewable conversion of supplier electricity" as a Scope 3 management item, the renewable energy evidence a supplier submits also has to satisfy the RE100 criteria to count. In other words, the stricter the criteria get, the less the "any certificate will do" approach works for suppliers.

Change 1: the "15-year age" rule for renewable assets

RE100 counts a renewable energy certificate as 100% renewable only when it comes from a generating asset within 15 years of commissioning or repowering. Power and certificates from older plants are sharply limited in how much they count. The measure is intended to steer investment towards new renewable capacity.

When it applies — assessment began with 2024 consumption (the 2025 reporting cycle). One exception has been clarified, however: the original off-taker of a long-term project can still receive partial credit even after the plant passes 15 years.

What it means for suppliers — when you review a PPA or certificate contract, make sure to check the plant's commissioning year. If you secure certificates from ageing assets on price alone, they may not be recognised when it comes to your buyer's reporting.

Change 2: a tighter definition of the European "single market"

RE100 recognises a renewable energy claim only when it rests on generation that took place in the same market as the consumption. For Europe, the definition has been narrowed so that a country counts as part of the single market only if it is an EU single market member state and is a member of the AIB (Association of Issuing Bodies) issuing EECS-compliant Guarantees of Origin.

What it means for suppliers — when dealing with exports to Europe or European buyers, you need to check that the certificate's market boundary lines up. The direct impact on a supplier whose sites are all in Korea is small, but it is worth knowing as background to the logic behind a global buyer's requirements.

Change 3: mandatory evidence of certificate cancellation (retirement)

From the 2025 criteria (v5.0), every renewable energy claim, including those made under a PPA, is recognised only where there is evidence that the certificates were actually cancelled in the registry of the country of consumption. Simply holding a PPA does not satisfy this automatically, and contractual claims without cancellation evidence will not be recognised from the 2027 CDP reporting cycle.

What it means for suppliers — your renewable energy response has to be designed as "a procedure that runs all the way through to registry cancellation", not as "one piece of paper". In Korea, it is safer to map out in advance the cancellation and settlement evidence paths for KEPCO's green premium, RECs, and third-party PPAs separately.

At a glance: the three changes and when they apply

Corporate Energy Transition Center — our view

The direction of these changes is clear. They ask you to prove it "with a newer plant, in the same market, using certificates that were actually cancelled". From a supplier's point of view it looks like a burden, but put the other way round, it creates a line that lets a supplier who has prepared properly earn a buyer's trust. If you systematise your evidence procedures starting now, you will be able to meet future RE100 and EcoVadis requests from buyers without being knocked off balance.

• [Source: RE100 Technical Criteria and Technical Guidance (The Climate Group · CDP)]
• [Source: RE100 2025 Reporting Guidance (June 2025 update) · RE100 press release (criteria revision), checked 2026.6.27]

Note: This summary is provided as an aid to understanding. For reporting and certification, the final judgement must always follow the official RE100 source criteria.