Energy audit: Application of the 90%-Rule for Affiliated Companies with a Management System according to EMAS or 50001
According to the 90%-rule, at least 90% of the total energy consumption must be taken into consideration for the energy audit. Sites or divisions, which together make up less than 10% of the total energy consumption, can be excluded from this consideration in the context of the energy audits. While this rule still had to be applied separately per company during the initial audit, a simplification for repeat audits now applies.
The Federal Office of Economics and Export Control (BAFA) has opened up the possibility for companies to perform the energy audit for the whole group (see BAFA-leaflet 3.2.7). This means that even at the first step all sites and companies may collectively apply the 90%-rule.
This raises the question as to how the 90%-rule is to be applied to a mixed constellation of several associated companies that only to some extent operate an energy management system according to ISO 50001 or an environmental management system according to EMAS.
It should be noted here that the so-called group network is only to consist of companies that are obliged to undergo the energy audit. Companies that have already been certified according to ISO 50001/EMAS have already fulfilled their obligations under the Federal Energy Services Law (EDL-G), and are therefore not subject to the energy audit and thus, are not included in the group network and in the overall energy balance.
Your contact at Arqum: Lena Strauss