France
Standard Supply Service (SSS) in France: Claiming and Challenges
Overview
Standard Supply Service (SSS) refers to the default electricity supply provided to consumers in France, typically through regulated tariffs such as EDF's Tarif Bleu, which serves approximately 70% of residential and small business customers as of November 2025. Under the Greenhouse Gas (GHG) Protocol's Scope 2 Guidance (updated via public consultation in 2025), SSS allows companies to make market-based claims for low-carbon attributes in their default supply, provided they adhere to strict criteria for fair allocation and avoidance of double-counting. This page provides a comprehensive resource for French customers using the Granular Registry platform to navigate SSS claims, addressing common misunderstandings in a market dominated by nuclear power (65-70% of the mix) and evolving renewable integration. Key nuances include the decoupling of Guarantees of Origin (GOs) through state auctions and the transition from legacy mechanisms like ARENH to new nuclear allocation contracts.
What is SSS in the Context of GHG Protocol?
SSS, as formalized in the 2025 GHG Protocol revisions (Section 5.1.3), enables reporting entities to claim a pro-rata share of low- or zero-emission resources in their default electricity supply where there is a traceable, mandatory financial relationship (e.g., via regulated tariffs or non-bypassable charges). This includes publicly owned or regulated facilities under cost recovery obligations, such as France's nuclear fleet and subsidized renewables. Claims are limited to the entity's proportional load share to prevent over-allocation. Critically, SSS attributes cannot be resold or concentrated beyond pro-rata shares, ensuring no harm to non-claiming customers. If attributes are voluntarily transferred (e.g., via separate GO sales), they become ineligible for SSS, forcing reliance on residual mix factors (higher-emission defaults excluding claimed resources).
In France, SSS aligns with the EU's Renewable Energy Directive (RED III, transposed into national law by May 2025), which mandates transparency in energy mixes and prevents double benefits from subsidies. Misunderstandings often arise from assuming default supply inherently conveys all attributes, ignoring GO decoupling.
Regulatory Framework in France
France's electricity market operates under a hybrid model: partially liberalized since 2007, with regulated tariffs coexisting alongside competitive offers. Key regulations include:
RED III (Directive (EU) 2023/2413): Fully transposed by May 2025, it requires granular GOs (15-minute intervals where feasible) for renewables and extends to non-renewables like nuclear. To avoid double benefits, GOs from subsidized projects are withheld from producers and auctioned by the state, with proceeds offsetting consumer levies like the Contribution au Service Public de l'Électricité (CSPE).
National Laws: The Energy Code (Code de l'Énergie) governs GOs via the Commission de Régulation de l'Énergie (CRE). The Accès Régulé à l'Énergie Nucléaire Historique (ARENH) ended December 31, 2025, replaced by Contrats d'Allocation de Production Nucléaire (CAPN) for nuclear allocation. The Programmation Pluriannuelle de l'Énergie (PPE) targets 40% renewable electricity by 2030, up from 22% in 2023.
GHG Protocol Alignment: French residuals, published by ADEME and the Association of Issuing Bodies (AIB), exclude voluntary claims and SSS-allocated resources, typically yielding 50-100 gCO2e/kWh (dominated by nuclear but adjusted for unclaimed portions).
Default Electricity Supply in France
Most consumers (residential and small businesses) are on EDF's Tarif Bleu, a regulated tariff set by the CRE biannually. As of November 2025:
Energy Mix: Approximately 65-70% nuclear (365-385 TWh estimated for 2025, per EDF updates), 10-15% renewables (hydro dominant, with growing wind/solar), and the remainder from gas/imports. Exact mixes vary; EDF reports annually, but attributes are not automatically bundled.
Financial Link: Customers pay non-bypassable charges (e.g., CSPE at ~€32/MWh) funding nuclear maintenance and renewables, establishing SSS eligibility.
Suppliers: While EDF holds ~70% market share, alternatives like Engie or TotalEnergies offer default-like services. Competitive markets cover larger industrials, but SSS applies to regulated segments.
Misunderstanding: Many assume Tarif Bleu conveys full nuclear/renewable attributes, but RED III decoupling requires explicit verification.
Renewable Attributes and GO Auctions
France issues GOs for renewables via the EEX-managed National Registry, but for subsidized projects (e.g., under feed-in premiums or contracts for difference), GOs are retained by the state to prevent double benefits. As of 2025:
Auction Mechanism: Appointed by the Ministry for Energy Transition, EEX auctions GOs from supported facilities (e.g., wind, solar, biogas). Proceeds exceeded €400 million in 2023-2024, reducing CSPE burdens. The 2025-2026 calendars include monthly auctions, with GOs sold to voluntary buyers (e.g., corporates for Scope 2 claims).
Impact on SSS: Default customers (e.g., Tarif Bleu) financially support renewables via CSPE but cannot claim auctioned attributes. Pro-rata shares are limited to unsubsidized renewables (~5-10% of mix), verified via supplier attestations. Auctioned GOs risk double-counting if resold, forcing residuals.
Challenge: Temporal mismatches—annual SSS vs. RED III's push for hourly granularity (effective 2027)—complicate claims.
Nuclear Attributes and CAPN Contracts
Nuclear, France's baseload (operated by EDF), qualifies for SSS due to regulated cost recovery. However:
Nuclear GOs: Issued since 2023 via EEX, certifying low-carbon attributes (0 gCO2e/kWh, excluding lifecycle). Initial volumes were small (0.15 TWh in 2024), traded at €0.50-€2/MWh.
CAPN Mechanism: Post-ARENH (ended 2025), CAPN allocates nuclear production with bundled attributes for 10-15 years. Examples: Data4 (40 MW, 12 years, September 2025); Lafarge France (long-term, September 2025). EDF markets CAPNs to industrials and hyperscalers, potentially outside France.
SSS Implications: Default customers can claim pro-rata nuclear (~65%) if attributes are retired for SSS, but voluntary CAPN sales decouple them, rendering ineligible. Residuals adjust accordingly, inflating emissions.
Misunderstanding: Assuming nuclear is "free" for SSS ignores potential resale.
Challenges in Claiming SSS in France
France's low-carbon grid (average 50 gCO2e/kWh) masks SSS complexities:
Double-Counting Risks: Auctioned renewable GOs or CAPN-sold nuclear attributes allow third-party claims (e.g., data centers), leaving default customers with residuals. Violates GHG Protocol Criterion 6 if unverified.
Verification and Data Gaps: Supplier attestations (e.g., EDF) lack hourly granularity; residuals from ADEME/AIB require cross-checks. CSRD (effective 2025) mandates disclosures, but SMEs face €50,000-€100,000 costs per audit.
Regulatory Transitions: Post-ARENH volatility; RED III's May 2025 transposition introduced grandfathering for RED II-compliant fuels, but delays in full hourly GOs (2027) hinder precision.
Market Misunderstandings: Public debates (e.g., on X) highlight misinformation—e.g., over-subsidized renewables (€5.8 billion in 2023, offset by €9 billion reversements in 2022)—leading to inflated expectations of SSS benefits.
Comparability Issues: Non-uniform SSS across regions (e.g., Corsica's higher fossils) affects multinational reporting.
Uncertainties: If SSS is excluded from residuals, administrative burdens rise; fossil-default rules (GHG Protocol proposal) could penalize unclaimed nuclear.
How to Claim SSS in France Using Granular Registry
Verify Eligibility: Confirm default supply (e.g., Tarif Bleu) and pro-rata share (load-based, e.g., 65% nuclear claim cap).
Gather Data: Obtain supplier attestation (EDF provides annual mixes); cross-verify with EEX registry for un-auctioned attributes.
Apply GHG Protocol: Use market-based method; allocate only non-resold portions. Default to residuals if attributes sold.
Platform Tools: Upload invoices to Granular Registry for automated pro-rata calculation; hourly matching (post-2027) via integrated AIB data.
Report: Disclose in Scope 2 inventory; audit for CSRD compliance.
Recommendations for French Customers
Prioritize voluntary PPAs with bundled GOs for robust claims beyond SSS.
Monitor CRE/EEX auctions; advocate for SSS-inclusive residuals.
Engage third-party verifiers to mitigate double-counting.
For hyperscalers/data centers: Balance CAPNs with SSS limits to avoid greenwashing under EU Green Claims Directive (2028).
Stay updated: GHG Protocol finals (2027) may refine SSS; contact Granular Registry for modeling.
This page is updated as of November 5, 2025; consult official sources for changes.
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