Energy Efficiency Directive (EED) – what does it mean for Polish production plants and why it is worth implementing an EMS system

What is the new EED (Directive (EU) 2023/1791)?

The revised Energy Efficiency Directive (EED) – Directive (EU) 2023/1791 – sets out the framework and obligations designed to help the European Union achieve ambitious energy-saving targets.
Among other things, the EED aims to reduce final energy consumption in the EU by 11.7% by 2030 compared to reference projections.
It replaces the previous Directive 2012/27/EU and entered into force on 10 October 2023.
Member States are required to transpose its key provisions into national law – the deadline for transposition was 11 October 2025.

Key obligations for enterprises (especially manufacturing)

1) The Directive requires either an Energy Management System (EMS) or an energy audit – depending on energy consumption

Article 11 of the EED defines the energy-consumption thresholds that determine the obligations:

Companies consuming >85 TJ/year (approx. 23.6 GWh average over 3 years) – must implement an Energy Management System certified in accordance with ISO 50001.
The system must be implemented no later than 11 October 2027.
Companies consuming >10 TJ/year (approx. 2.78 GWh average over 3 years) – must perform an energy audit every 4 years, unless they have an EMS in place (in which case an external audit is not required).
The company must bear the cost of the audit.

2) National audit requirement every 4 years

Regardless of the EED, large enterprises in Poland are required to carry out an energy audit every four years.
Failure to do so may result in financial penalties.
A certified EMS compliant with ISO 50001 or EMAS exempts the company from the recurring audit, provided that an internal audit is performed within the system.

Why implement an EMS (ISO 50001)?

Implementing an EMS not only eliminates the need for recurring audits but also enables optimization of energy and utility costs.
EMS systems provide the essential data that drive efficiency in modern industry.

Regulatory compliance and peace of mind
For entities consuming >10 TJ/year, an ISO 50001-certified EMS replaces the recurring audit requirement.
Avoided audit costs
Typical audit costs for multi-site manufacturing companies can reach PLN 30,000–40,000 per audit.
Tangible energy savings
An EMS enables real-time monitoring of energy consumption, historical data analysis, KPIs (e.g., kWh/unit), alerts, and reviews – leading to measurable, lasting savings.
An example of an ISO 50001-compliant EMS is OmniEnergy.
Better investment decisions
EMS data support ROI calculations for upgrades (compressors, drives, heat recovery, lighting, furnace control, etc.)
They also allow precise estimation of the Technical Cost of Production (TKW).

Example cost comparison

When considering an EMS implementation, it is important to understand the long-term costs of recurring audits.

Market assumptions (example):
An energy audit costs PLN 40,000 every 4 years.
Assume a one-time EMS implementation cost of PLN 10,000 and an annual system subscription of PLN 7,000.

4-year horizon (first audit cycle)

Item	Year 1	Year 2	Year 3	Year 4	Total (4 years)
EMS – one-time setup	10,000	0	0	0	10,000
EMS – annual subscription (7,000/year)	7,000	7,000	7,000	7,000	28,000
Total EMS (without energy savings)	17,000	7,000	7,000	7,000	38,000
Energy audit (every 4 years)	0	0	0	40,000	40,000

Additionally, EMS implementations often bring 7–15% annual energy savings.
For a company spending PLN 1,000,000 per year on energy, a 7% reduction equals PLN 70,000 in yearly savings.

How to design an EMS that “pays for itself”

Define KPIs and business goals – before investing, determine your objectives and how to measure them.
Example KPIs: kWh/unit, kWh/ton, kWh/working hour.
Online monitoring – select key utilities (electricity, gas, steam, compressed air) and set up real-time deviation alerts.
Historical data analysis – data is the fuel of industrial optimization.
The OmniEnergy system includes an energy-data analytics module enhanced with AI models.
Rapid response procedures – define alarm thresholds to enable immediate action in case of abnormal consumption or equipment failure.
Prepare for ISO 50001 certification – ensures formal exemption from audits and organizes compliance evidence.
Certification also strengthens your company’s image as a sustainability-oriented organization.

If you’re unsure where to start, contact us for full support – from identifying high-consumption processes to implementing a tailored EMS.

Summary

The new EED shifts responsibility for improving energy efficiency directly onto companies.
With rising energy costs, implementing an EMS is not only a path to efficiency but also a regulatory obligation.
For manufacturing plants, EMS/ISO 50001 is the safest and most profitable route:
legal compliance, freedom from recurring audits, lower energy bills, and a stronger sustainability reputation.