According to the Amber criteria (measures), any new renewable energy installation at the facility can be classified as Amber (provided that this is implemented before 2035 and the Borrower/ Issuer has a transition plan aligned with 1.5 °C). However, if an aluminium producer takes a loan for the installation of rooftop solar panels (in order to generate solar energy for its own facility), wouldn’t this already be considered as “Green” under TSC 1.1 Electricity generation using solar PV and CSP (including electricity, heat, and cool)?

Additional questions:

• What is the difference between the “decarbonisation measures enabling the facility to increase share of renewable energy” under TSC 4.5  Manufacture of aluminum, and the renewable energy criteria in TSC 1.1-1.6?
• If these are essentially the same, does it mean that it is up to each borrower/ issuer/ FI to determine which label to use (i.e. Green or Transition) in the example above?

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If the intent is to enable decarbonisation efforts through the generation of renewable energy onsite, the loan can be considered “green” under TSC 1.1 Electricity generation using solar PV and CHP (“combined heat and power”) (including electricity, heat, and cooling).

[Updated in Dec 2025]