How should an enterprise calculate the EED Article 11 threshold?
Calculate the threshold at enterprise level using average annual for the three completed years before the assessment year: n-3, n-2, and n-1. Article 11 says to take all energy carriers together, so the record cannot cover only electricity, gas, one site, or one business unit when the applicable enterprise boundary is broader.
Commission Recommendation (EU) 2024/2002 suggests using invoiced energy, energy delivered through energy service providers, and self-consumed renewable energy inside the system boundary. Exported renewable energy is subtracted if it has not already been netted out. A Member State may allow self-consumed renewable energy other than bioenergy to be excluded, so that point needs a national check.
If the enterprise is above 85 TJ, Article 11 points to an independently certified energy management system. If it is above 10 TJ and does not implement an energy management system, Article 11 points to an energy audit obligation. The 10 TJ test is not a smaller version of the 85 TJ duty; it is the audit threshold for enterprises that do not have an energy management system.
- Set the enterprise boundary used for the calculation and note the national-law basis for that boundary.
- Gather for years n-3, n-2, and n-1, including every carrier and use inside the system boundary.
- Reconcile invoices, energy-service deliveries, on-site renewable self-consumption, exports, and any nationally permitted renewable-energy exclusion.
- Convert consumption into a common unit, keep the conversion factors, and calculate the three-year average annual total in TJ.
- Classify the result as above 85 TJ, above 10 TJ but not above 85 TJ, or not above 10 TJ for the period reviewed.
- Recheck the calculation when acquisitions, disposals, site openings, major production changes, or national transposition rules change the enterprise boundary or data basis.
Binding EED text for the enterprise thresholds, the previous-three-years averaging period, and the requirement to include all energy carriers together.
Sections 3 and 4 provide non-binding guidance on final energy consumption, years n-3 to n-1, system boundaries, energy bills, service-provider energy, renewable self-consumption, and linked enterprises.