Article 11 of the 2023 revised energy efficiency directive - A harmonization check for multinational enterprises (MNEs)

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Volume Title

School of Engineering | Master's thesis

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Date

2025-11-06

Department

Major/Subject

Energy Conversion Processes

Mcode

Degree programme

Master's Programme in Advanced Energy Solutions
Kehittyneiden energiaratkaisujen maisteriohjelma
Magisterprogrammet i avancerade energilösningar

Language

en

Pages

80

Series

Abstract

This study examines the changing landscape of energy legislation within the European Union through a literature review of new Directives and Regulations. The study narrows its focus on the revised Energy Efficiency Directive (EED 2023/1791), specifically on Article 11 of the Directive. By structured email interviews with Ministries and National Authorities, as well as with experts representing NGOs from different Member States, the harmonization of the implementation of Article 11 is evaluated. Article 11 of the revised EED sets requirements on enterprises to implement energy management systems or conduct energy audits based on the energy consumption of the enterprise. This requirement adds to the administrative and financial burden from previous Directives and Regulations already carried by enterprises in multiple sectors. In this work, the implementation for multinational enterprises (MNEs) is investigated through the interviews to provide MNEs with insight about possible options for compliance with the Directive. The research reveals an implementation gap for MNEs, where further guidance is required since energy consumption should be assessed as the sum of each linked enterprise. While the jurisdiction of a Member State is limited by its borders, the operational environment of an MNE is not. Thus, governance of MNEs should be done on a higher level. While the Commission Recommendation 2024/2002 provides some guidance on the practical implementation in the transposition process for Member States, the lack of harmonization in the implementation of article 11, presented in this study, underscores the need for further guidance for MNEs at the European Union level, since interborder decisions cannot be taken individually by Member States.

Description

Supervisor

Vuorinen, Ville

Thesis advisor

Ferrantelli, Andrea

Keywords

energy efficiency directive, energy management system, ISO 50001, European Union, energy efficiency, administrative burden

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Permanent link to this item

https://urn.fi/URN:NBN:fi:aalto-202512159238

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[dipl] Insinööritieteiden korkeakoulu / ENG