EU Energy Efficiency Directive

Mar 12, 2019 | Energy and Carbon, Environment, News | 0 comments

The EU Energy Efficiency Directive came into force throughout the EU in 2012.  This requires all large companies to have a high quality energy audit every four years.  The second round of audits are now due for completion by the end of this year (2019).

Directive Impact

Whist reducing the impact of climate change is essential, this directive can be seen as a bit of a sledgehammer to crack a nut.  The directive only applies to companies with more than 250 staff, yet there would be many companies with less than 250 staff but would use more energy than larger companies.  For example, a pharmaceutical manufacturing plant with 200 employees would consume significantly more energy than a corporate headquarters with 500 staff.

The aim of the directive is to identify energy saving opportunities.  This can be easily done and an audit should identify many such opportunities.  However, for the large corporate headquarters mentioned above, if they are operating out of rented or leased offices, then the practicality of implementing significant energy savings is limited.  

One aspect of directives is that it is up to each member state to decide how to implement.  For the EU Energy Efficiency Directive this can result in significant differences and difficulties when carrying out audits for EU multinationals.  One example of these difference is whether to include the grey fleet (these are vehicles owned and driven by employees on company business but where the costs are paid by the company).  In the UK, the grey fleet is included, in Ireland it is excluded. This would make intercompany energy performance difficult to compare across the EU.

Sample Size

A second example concerns the sample size of the audit.  For example, a company may have a chain of stores. Many of the stores would tend to be similar in building type and thus to audit every store would be wasteful in effort leading to excessive costs.  An energy auditor would therefore, if permitted, choose a representative sample of sites to audit. For the UK ESOS implementation of the directive, the auditor is free to determine the sample size and some audits have had sample sizes of 1% of the company’s premises.  However, in the Czech Republic, sampling is not allowed and thus every site would have to be audited. Such rigid rules increase costs without any corresponding benefit.

Despite the above misgivings about the directive, it is possible to identify real and practical energy savings by undertaking such audits.   Examples from the second round of audits from our work include

  • Chain of stores with manufacturing plant.  Compressed air and process cooling savings with paybacks of less than 9 months
  • Chilled food distributor.  Heating and chilling savings with paybacks of less than 4 months
  • Pharmaceutical manufacture. AHU and lighting savings with paybacks of less than one year.
  • Electricity generator with heating and lighting savings with paybacks of less than 6 months.

Environmental Efficiency

Bob Sutcliffe is a Chartered Engineer and a Certified Energy Manager.  Bob is listed on the UK and Irish registers of approved energy consultants for EU Energy Efficiency Audits.  He may be contacted at

If you are looking for environmental consultants, visit Environmental Efficiency