Marketing Compliance Review – Frequently Asked - Green-e

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.