Marketing Compliance Review – Frequently Asked Questions What is Green-e Energy Marketing Compliance Review (MCR)? In the spring and autumn of each year, Green-e staff conduct a thorough review of marketing and disclosure materials to ensure that program participants are upholding the requirements of the Green-e Energy Code of Conduct. MCR is only performed on Green-e Energy certified products and does not apply to non-certified products. MCR is a contractual obligation for Green-e Energy certified products and is crucial to ensuring transparency and consumer protection in the marketing and sale of certified products. When is the submission deadline, and who is required to submit? The deadlines for MCR submissions are always the final business day in August and the final business day in February. Green-e Energy participants on semi-annual review must submit the required materials in both August and February (February: residential-only materials, August: all materials, including commercial/wholesale, if applicable). Participants on annual review who sell certified products to residential customers – exclusively or in addition to commercial or wholesale customers – must submit only in August and must submit all materials for all certified products. Participants selling certified products exclusively to commercial or wholesale customers are only required to submit during February. What types of materials are required to be submitted for MCR? Green-e Energy participants are required to submit all materials relating to the marketing and sale of certified products. This includes Historical and Prospective Product Content Labels, Terms & Conditions documents, marketing pieces with and without enrollment/subscription mechanisms, sample invoices/bills, links to any relevant webpages, and any materials that discuss certification or refer to the product without mentioning certification. MCR is a retrospective process to review materials used in the last year (or six months, depending on product type). See the chart below for details. MCR Cycle Submit Materials… Spring Annual Review used January 1 through December 31 of the previous year, plus PPCL from current year Autumn Annual Review used June 30 of the previous year through July 1 of the current year Spring Semi-Annual Review used July 1 through December 31 of the previous year, plus PPCL from current year Autumn Semi-Annual Review used January 1 through June 30 of the current year How do submissions for residential and commercial products differ? For both residential and commercial products, Green-e Energy requires the submission of all materials relating to the marketing and sale of certified products. Participants selling exclusively to commercial and/or wholesale customers may have different types of marketing materials, e.g. certificates of purchase given to customers for CSR purposes, pitch decks, responses to RFPs, PPA templates, etc. How does the submission process work? Materials will be submitted via email to [email protected]. All required documents must be attached to the submission email(s). If necessary, .ZIP files or Dropbox links may be included in the email. Please do not embed attachments in the submission form itself or merge all materials into one document. Participants may be solicited to pilot a new online MCR submission process that will be implemented in future cycles. How do participants request an extension to the submission deadline? In order for materials to be reviewed in a timely manner, please submit by the MCR deadline. Green-e grants extensions in limited cases where the participant demonstrates sufficient justification, and extensions are only granted in advance of the submission deadline. Email [email protected] to request an extension. Participants that do not request an extension and do not submit materials by the deadline will be posted on www.greene.org. How long does it take to process MCR submissions, and how is feedback provided? Feedback will be provided via email from Green-e staff. Due to the depth of the review process and the volume of submissions received, it may be a few months before Green-e can provide a list of required revisions to correct any issues identified in the review process. Participants are given 30 days to come into compliance with the Code of Conduct requirements. What happens if a participant fails to submit for MCR or neglects to make the required changes? As part of the Green-e Energy Certification and Logo Use Agreement, ongoing compliance with Code of Conduct is a contractual obligation for all participants. MCR is the primary process used to confirm compliance with the Code of Conduct or identify issues that must be addressed to achieve compliance. Participants that fail to meet the submission deadline, the 30-day follow up deadline, or a pre-approved extension deadline will be immediately posted on the Green-e website. The certified product name(s) will be removed from the Green-e website upon remedy of the infraction. If the participant does not submit materials or fails to cooperate with Green-e Program staff on required revisions within a reasonable timeline, enforcement and censure activities will be triggered, and the certified product(s) may be decertified. See Section V of the Green-e Energy Code of Conduct.
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