It is one of the questions that comes up most often once a company starts looking at its footprint in detail: "We buy electricity with guarantees of origin, so our Scope 2 is zero. Why does the platform still show emissions from transmission and distribution losses?"
The short answer is that the two things live in different boxes of the inventory. A certificate cannot cover energy that never reached your meter. The long answer is worth it, because this is exactly the kind of detail that separates a calculation that passes an audit from one that does not.
Two boxes that do not mix
Scope 2 measures the generation of the electricity you consume. Scope 3, Category 3, gathers everything else tied to that energy that does not fit in Scope 1 or 2. That includes the upstream fuel chain and, what matters here, transmission and distribution (T&D) losses.
A guarantee of origin (GdO in Spain, I-REC across much of Latin America) is a Scope 2 instrument. It certifies the source the electricity was generated from and is used in the market-based method for that scope. It lives inside the Scope 2 boundary and has no defined effect on Category 3.
Why a certificate cannot cover the losses
The underlying point is first-principles. A GdO or an I-REC are busbar-level certificates: they certify 1 MWh generated at the plant. If the grid loss rate is 12% and you buy 1 MWh of certificates, only 0.88 MWh reaches your meter. The other 0.12 MWh was lost along the way. It was never delivered to you, you never consumed it, and it was never the subject of your certificate. That loss is accounted for by the grid operator in its own inventory, not by you.
In other words, you cannot claim as renewable energy that you never received. The certificate stays at the plant gate and the loss happens afterward.
This lines up with how the standard is written. Formula 3.3 of the GHG Protocol for T&D losses uses the electricity life cycle emission factor, which is the grid average equivalent to the location-based factor, not the market-based factor. There is no exception for certificate holders.
What the standards say
This is not our interpretation. It is in the sources.
Look at formula 3.3, the one the Technical Guidance for Calculating Scope 3 Emissions (2013, Chapter 3) itself uses to calculate these losses:
electricity consumed × electricity life cycle emission factor × T&D loss rate
The only factor in it is the grid life cycle factor. There is no variable for your guarantees of origin, and none for the market-based method. A Scope 2 certificate has nowhere to enter this calculation. The GHG Protocol's own public FAQ confirms the same for a company that buys electricity from a T&D system it does not operate. All of this applies directly to Chile and Peru.
In Spain, the MITECO carbon footprint calculator is a Scope 1+2 tool. Its instructions exclude T&D losses from the corporate inventory expressly "to avoid double counting". The factor for electricity with a renewable GdO is 0 kg CO2e/kWh in Scope 2, and the losses simply do not appear in that box.
The CNMC confirms the nature of GdOs. The guarantee certifies energy generated at the busbar, per the definition in Circular 1/2018 (BOE-A-2018-5717) and the labeling methodology in Circular 2/2021 (BOE-A-2021-2570). It is what was generated upstream of the transmission grid, not what reached your outlet.
The practical takeaway
Buying renewable energy is a real lever for cutting your Scope 2. But it does not erase T&D losses, which are a separate, and much smaller, line in your Scope 3.
A platform that zeroes out that line just because you hold certificates is inflating your reductions and leaving you exposed to a verifier, right when you report under CSRD or go through an audit. That is why at Grumbic we treat them separately. The certificate does its job in Scope 2 and the losses stay where the standard says they should. Fewer surprises later, and a number that holds up when someone reviews it seriously.
