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Revision of the European Energy Efficiency Directive (EED): how to prepare your company?

At the end of 2023, the European Union's new Energy Efficiency Directive (EED) came into force. It revises the EU's targets for reducing final energy consumption, with a very ambitious plan compared to the forecast scenarios initially established : by 2030, the European Union will have to consume 40 % less energy than in 2007 (instead of 32.5 % so far). What new obligations will French industrial companies have to meet in order to participate in this effort? What are the solutions to help you prepare    Our decipherment to help you see things more clearly.

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The European Directive and its transposition in France

Concretely, the EED calls for an additional 11.7% reduction in primary and final energy consumption across the EU by 2030. EU countries should thus save an average of 1.5% per year. These energy savings will be gradual, from 1.3% per year until the end of 2025, gradually reaching 1.9% by the end of 2030.

A major challenge that France plans to meet through the stratégie française énergie climat (SFEC) and its 3 energy planning documents: the national low-carbon strategy (SNBC), the multi-year energy program (PPE) and the national climate change adaptation plan (PNACC). 4 main action levers have been identified to achieve carbon neutrality by 2050:

  • Changing material inputs;
  • Improving energy sobriety and efficiency;
  • Substitution of carbon energies;
  • Capture, storage and recovery of residual CO2 emissions;

It is clear that energy management in the industrial sector, whose share of energy consumption amounts to 1/5th of the country's total, is a central issue.

European directive and industry: what changes from 2024

Also, some consequent changes will have an impact on the industrial sector in the coming years, with a revision of associated obligations and processes.

Revision of the regulatory and mandatory energy audit

Preliminary provisions

Since 2012, companies with more than 250 employees or sales in excess of 50ME and a balance sheet total in excess of 43ME have been required to carry out an energy audit and then update it every 4 years.

What's changing

Since January 1, 2024, industrial energy audits must imperatively include:

  • The measurement of a minimum of 3 Significant Energy Uses (SEUs) representing 10% of the site's total consumption;
  • A verification/redefinition of the correct thermal mismatch between needs and production ;
  • An identification of waste heat rejection ;
  • The establishment of a energy-saving action plan + a renewable energy (RE) action plan.

Other developments are planned in the DEE:

  • As of October 11, 2026, all companies whose average annual energy consumption has exceeded 10 TJ (total annual energy consumption between 2.7 and 23.6 MWh) over the last three consecutive years will have to undergo an energy audit every 4 years. They can also choose to have their Energy Management System (ISO 50001) certified, thus substituting it for the audit if the latter covers at least 80% of consumption.
  • By October 11, 2027, an energy management system (EMS) must be implemented by all companies whose average annual energy consumption has exceeded 85 TJ (total annual energy consumption exceeding 23.6 MWh) over the last three years.

Note : this revision does not concern companies implementing an energy performance contract (CPE) and, in certain cases, companies with an ISO 14001-certified EMS.

Carbon allowance reform (SEQE-EU)

Introduced in 2005 as part of the ratification of the Kyoto Protocol, the European Union Emissions Trading Scheme (EU ETS) aims to reduce greenhouse gas emissions from energy-intensive industrial sectors, power generators and airlines, by lowering the cap on greenhouse gas emission allowances set by the EU over time.

A major reform of Directive 2003/87 (the main legal basis for the EU ETS in European law) was adopted in May 2023. Its provisions are as follows:

  • The target for reducing greenhouse gas emissions, compared with 2005, is currently -43%. This will rise to -62% from 2030.
  • Maritime transport is now a sector covered by the SEQE-EU.
  • A border carbon adjustment mechanism (MACF) is introduced.

Practical implications:

  • The cap on allowances is lowered (-4.2%);
  • Shipping companies must surrender 40% of their emissions allowances in 2024, 70% in 2025 and 100% in 2026.
  • Following the installation of a Border Carbon Adjustment Mechanism (BCAM), free allowances for certain industrial sectors will gradually disappear. Those for aviation are scheduled to be phased out between 2024 and 2026.

If your company is subject to a regulatory energy audit:

In this case, implementing all the recommendations listed in the action plan issued by the audit within 3 years of its completion will entitle you to:

  • The allocation of 20% free quotas - subject to the implementation of recommendations (EE) with return on investment rate of less than 3 years ;
  • Compensation for indirect costs if your EPP contains all the recommendations (EE) of the energy audit, including a rate of return on investment of less than 3 years.

Anticipate your ISO 50001 certification to take action

These changes, which involve implementing demanding energy management measures, are obviously shaking up the world of industry. The right course of action? Take the lead so as not to find yourself unprepared, by implementing a certified energy management system today ISO 50001. Any company committed to improving energy management is in fact exempt from the regulatory audit, if this EMS covers at least 80% of the site's energy consumption. Still optional today, ISO 50001 certification is likely to become mandatory by 2026. This is a good reason to take advantage of PRO SMEn 2023-2026. The latter encourages the implementation of a certified EMS, through the payment of a prime equivalent to 20% of your annual energy expenditure, up to a ceiling of 40,000 euros.

Good to know : 90% of beneficiaries received the maximum bonus of 40,000 euros in 2022.

The ISO 50001 standard draws guidelines for structuring your energy management, and enables you to generate savings over the long term. Because it defines requirements in terms of performance and results rather than means, certified manufacturers must continuously progress  from one year to the next if they wish to maintain the benefits of their certification. Adopting ISO 50001 thus represents a significant opportunity to establish effective energy management and measurement practices over time, as well as an updated action plan. As the icing on the cake, it also helps mobilize your employees around a common goal : a real commitment to energy efficiency.

Of course, the ISO 50001 approach presupposes certain prerequisites: producing reliable data and indicators, defining an energy policy, structuring its organization, and committing to continuous monitoring and improvement - the guarantees of a documented, virtuous management system. Thanks to its dedicated platform, Lemon Energy measures your consumption and qualifies your energy performance at different levels: equipment, workshop, site and group. We then produce the technical and costed basis that will facilitate your exchanges with your certifier. Whether you're a latecomer to energy management, or newly concerned by the revision of the DEE, our expertise will support you in meeting the challenges of the energy transition.