Energy audit obligation – BAFA Bulletin

Energy audit obligation for large companies: BAFA (Federal Office of Economics and Export Control) bulletin allows only few exceptions:

On 22nd April 2015, the amended German Energy Services Law (EDL-G) on the implementation of the EU Energy Efficiency Directive entered into force. The law stipulates that all companies that no longer apply as a small or medium-sized business must perform an energy audit according to DIN 16247-1 by no later than 5th December 2015. This obligation had already been made known for a long time; however, it was unclear whether there would be exemptions for certain companies or individual locations or divisions.

These uncertainties were now also clarified by the BAFA bulletin published on 13th May 2015: All large companies that carry out an economic activity, and no statutory or public authority tasks, are obliged to run an energy audit. There are exceptions for companies or groups of companies with multiple locations or subsidiaries: Here, a “matrix solution” is possible under certain conditions. In this case, the energy audit must only be carried out at a number of locations corresponding to the square root of the total number of locations. A further exception is the 90% rule – the energy audit must cover 90% of the energy consumption of the company.

However, the energy audit should not only be seen as a tiresome chore. Regardless of the legal requirements, energy audits are ideal in analysing the status quo of a company with regard to its energy consumption, and improving its energy efficiency by concrete measures.

As an alternative to the energy audit, an energy management system as per ISO 50001 or an environmental management system according to EMAS can be introduced. A transitional period has been allowed for these alternatives. In such cases, introduction must be demonstrated by 5th December 2015. Certification of the management system is then only required by 31st December 2016.




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