Both new and ongoing investments may be eligible as VCA expenditures if they meet the other criteria.
In general, funding for ongoing projects may be eligible if the project was initiated within the five years before the certification year. “Initiated” means that the spending decision was approved and implemented. This includes both operating costs and capital and/or depreciation expenses. For example, a decision to switch a product component to low carbon aluminum would reduce emissions and earn VCA credit as an ongoing project for up to five years after the switch.
For certain ongoing projects where the decision to use lower carbon inputs is made every 1-2 years, funding beyond the five-year window may also be eligible. This provision recognizes that the decision to use certain low carbon inputs is more easily reversible than others. For example, low carbon packaging materials that carry a price premium may be easy to remove from the supply chain. To qualify, such projects must meet the other VCA criteria, including documentation of a price premium.