ISO 50001 and EU Directive 2023/1791 – Energy Management in Manufacturing Facilities

Key facts

• EU Directive 2023/1791 requires manufacturing plants with high energy consumption to implement a certified energy management system, most often in line with the ISO 50001 standard.
• The energy consumption threshold determines the obligation:
  • 85 TJ/year or more: A mandatory certified EMS is required by October 2027.
  • 10–85 TJ/year: A mandatory energy audit is required every 4 years, or a voluntary EMS can be implemented.
• The system must be certified by an independent body; a proprietary IT solution without an audit is not sufficient.
• ISO 50001 ensures continuous improvement in energy efficiency, leading to lower energy costs and regulatory compliance.
• Benefits for companies include: savings, a competitive advantage, an improved image, and ESG compliance.
• Key factors when choosing a system are: compliance with ISO 50001, the possibility of certification, consumption monitoring, and integration with production processes.
• Poland must adapt its national legislation by October 2025, so companies should begin their preparations now.

The European Union has amended the Energy Efficiency Directive (EED) – Directive (EU) 2023/1791 of the European Parliament and of the Council – introducing new, more stringent requirements for companies regarding energy management. At the heart of these changes lies the “Energy Efficiency First” principle, which is intended to accelerate energy savings, reduce greenhouse gas emissions, and improve energy security across the EU. The new directive aims to reduce total energy consumption in the EU by 11.7% by 2030 (compared to 2020 forecasts), which is crucial for achieving the EU’s climate goals (including reducing CO₂ emissions by 55% by 2030 and achieving climate neutrality by 2050). To meet these ambitious goals, large industrial plants and other organizations must implement certified Energy Management Systems (EMS) – most commonly compliant with the ISO 50001 standard – which will ensure continuous improvement of energy efficiency and compliance with the new regulations.

Why is an Energy Management System Required?

The new regulations were introduced because sporadic energy audits proved insufficient to achieve lasting energy savings. A traditional energy audit (previously required every 4 years for large enterprises) provides a one-time diagnosis of energy consumption and identifies opportunities for improvement, but it does not ensure continuous monitoring and optimization of energy use. In contrast, an Energy Management System (EMS) based on ISO 50001 mandates a systematic approach to continuous improvement of energy efficiency. It is based on the Plan-Do-Check-Act (PDCA) cycle, whereby the organization constantly monitors consumption, analyzes data, and implements corrective actions, rather than relying on one-off improvements. In other words, implementing ISO 50001 involves formal energy management, establishing appropriate energy policies and procedures, and launching energy consumption monitoring, which allows for the ongoing identification and elimination of energy waste.

A second key reason is the implementation of the EU’s climate policy. Directive 2023/1791 emphasizes increasing energy savings and strengthening the role of energy management systems in enterprises to accelerate the decarbonization of the economy and increase energy efficiency. Without the introduction of mandatory systems (or equivalent measures), member states would risk failing to achieve the objectives of the European Green Deal. An energy management system helps companies contribute to the reduction of GHG emissions through conscious energy management and investments in energy-saving technologies, which is important from the perspective of climate commitments. Additionally, the EU’s “Efficiency First” principle means that energy efficiency is prioritized when shaping policies and investments – requiring an EMS in large plants is a practical implementation of this principle.

Energy security and costs are also significant. Improving efficiency reduces the consumption of fuels and energy, which limits dependence on unstable supplies of raw materials and lowers the operating costs of enterprises. In a context of rising energy prices, systematic management of energy consumption allows companies to better control expenses and avoid losses. The implementation of an EMS is therefore necessary not only due to legal requirements but also for purely business reasons – companies can gain a competitive advantage through lower energy costs and avoid financial penalties for non-compliance with new regulations. In summary, the requirement to have a certified EMS stems from both the long-term climate goals of the EU and the practical need to ensure lasting energy savings and continuous improvement of efficiency in enterprises.

Benefits of Implementing the ISO 50001 System

Implementing a certified energy management system brings numerous business, financial, and environmental benefits. The most important of these include:

• Reduction of energy consumption and operating costs: Thanks to systematic monitoring and optimization, a company can use energy more efficiently, which translates into real financial savings (lower energy bills). Companies reporting with ISO 50001 often record a decrease in the energy intensity of their processes, and consequently, a drop in production costs.
• Higher operational efficiency and performance: The implementation of an EMS stimulates the search for technological and organizational improvements that increase energy efficiency. For example, identifying energy “bottlenecks” can lead to machinery modernization, waste heat recovery, or control automation – which often increases the overall efficiency of the plant.
• Compliance with regulations and avoidance of penalties: A certified system (e.g., ISO 50001) guarantees compliance with current and future legal requirements related to energy efficiency. This minimizes the risk of financial sanctions for violating the directive or national laws and prepares the company for any future tightening of energy and climate policy.
• Improved image and market advantage: Proactive actions for sustainable development strengthen the organization’s credibility in the eyes of customers, investors, and business partners. An ISO 50001 certificate is proof of the company’s commitment to environmental protection and rational resource management, which builds its positive image as a responsible enterprise. This can facilitate winning contracts (especially in public tenders that include ESG criteria) and attract investors focused on sustainable development.
• Continuous improvement and innovation: Thanks to cyclical energy reviews and analysis of indicators, the EMS provides a mechanism for the continuous improvement of energy performance. The company establishes measurable energy objectives and monitors progress (so-called EnPIs – Energy Performance Indicators), which motivates a constant search for improvements. Early detection of deviations (e.g., a sudden increase in consumption) allows for a quick response. This, in turn, fosters innovation in processes and technology that not only save energy but often improve overall quality and productivity.
• Reduction of emissions and compliance with climate goals: Lower energy consumption (especially from fossil fuels) means a reduction in greenhouse gas emissions and thus a lower carbon footprint of the business. Implementing ISO 50001 helps to realize the company’s internal climate policies and aligns with global efforts to limit global warming. It can also lower costs related to the emissions trading system or emission fees.
  

A well-implemented energy management system is beneficial not only from the point of view of meeting legal requirements but also brings tangible economic and environmental benefits to the plant. Companies that implement ISO 50001 early gain an advantage as efficiency leaders – they achieve immediate savings, build a “green” company brand, and prepare for the tightening requirements of the future.

Does Every EMS Meet the Directive’s Requirements?

Directive 2023/1791 clearly states that the required energy management system must correspond to recognized standards and be certified by an independent body. Therefore, it is not enough to have any internally developed energy monitoring system – the system must comply with relevant European or international standards and have a certificate confirming this compliance. In practice, this means the necessity of implementing a system compliant with the EN ISO 50001 standard (Energy management systems) or an equivalent, and then obtaining independent certification. Only a certificate from an accredited body (e.g., for ISO 50001 or possibly EMAS) will be recognized as fulfilling the obligation imposed by the directive.

The directive also allows for alternative compliance paths in some cases. In some EU countries, the EMAS eco-management system will be accepted as meeting the requirements (EMAS is an EU environmental management system that includes, among other things, energy efficiency). Furthermore, enterprises that already have a certified environmental management system (ISO 14001 or EMAS) may be exempt from a separate audit or a separate EMS, provided that an energy audit meeting the directive’s criteria is carried out within that environmental system. In other words, if a company has, for example, implemented ISO 14001 extended to include energy management (or EMAS), and carries out the required energy audits, this may be considered as meeting the requirements – however, the environmental system itself must also be certified by an independent body.

It is worth emphasizing that ISO 50001/EMAS certification is not absolutely required for all enterprises, but only for those that exceed certain consumption thresholds (more on this below). For companies with an average annual energy consumption of >10 TJ, the directive offers the alternative of regular energy audits instead of implementing a full system (if they do not want or need to obtain a certificate). However, in the highest consumption category (>85 TJ), a certified EMS is mandatory – an audit alone is not enough. To summarize, for an EMS to be considered as meeting the requirements of the directive, it should have an ISO 50001 certificate (or equivalent). The implementation of random or partial solutions (e.g., only energy monitoring without a broader management system) will not be considered compliant with the regulations unless it has been certified according to a recognized standard.

Requirements for an Energy Management System Compliant with ISO 50001

For an Energy Management System (EMS) to meet the requirements of the directive and the ISO 50001 standard, it must include specific elements and functionalities. The ISO 50001:2018 standard defines in detail the requirements for planning and operational energy management in an organization. The key features of such a system include:

• Energy policy and management commitment: The company’s top management should establish a formal energy policy, committing to improving energy efficiency. Management must support the implementation of the EMS by providing resources and including energy objectives in the company’s strategy.
• Energy review and planning: The organization must conduct an energy review – an analysis of its processes in terms of energy consumption, identification of the main areas of energy use (so-called SEU – Significant Energy Uses), and the factors influencing this consumption. Based on this, an energy baseline is established, as well as Energy Performance Indicators (EnPIs) to monitor progress. The company then sets objectives and targets for energy savings, along with action plans to achieve them.
• Documentation, procedures, and operational control: Implementing ISO 50001 involves developing appropriate procedures and instructions that regulate activities affecting energy consumption. The system includes, among other things, procedures for the operation and maintenance of equipment to ensure they operate in an energy-efficient manner, as well as guidelines for employees (training in energy saving, energy awareness). An important element is the integration of energy management into daily operations – e.g., considering energy efficiency in production planning, scheduling machine work, or controlling heating and lighting.
• Monitoring, measurement, and analysis: Continuous monitoring of energy consumption is the heart of the ISO 50001 system. The standard requires the establishment of practices for measuring and collecting data on energy consumption by key equipment, systems, and processes. This data must be regularly analyzed to assess energy efficiency and identify deviations or losses. The system should enable ongoing data analysis – for example, through a sub-metering infrastructure connected to a supervision system. This allows the company to detect anomalies in real time (e.g., consumption deviating from the norm, a drop in the power factor, etc.) and take corrective action. Monitoring also includes tracking the achievement of the established EnPIs and verifying the implementation of the improvement plan.
• Design and procurement considering energy: ISO 50001 sets requirements for the organization to consider energy efficiency when designing new facilities, processes, or equipment, and when purchasing equipment that affects energy consumption. This means, for example, choosing machines with a higher efficiency class, investing in energy-saving technologies, or designing processes to minimize energy losses (e.g., heat recovery). This element ensures that energy management is integrated with the company’s investment decisions.
• Internal audit and management review: Like any ISO management system, an EMS requires regular internal audits to assess the effectiveness of the system and its compliance with the standard’s requirements. Management should conduct periodic reviews of energy management, during which it evaluates the results (achieved savings, EnPIs), the effectiveness of the actions taken, and decides on any corrections to objectives or policy. Such a mechanism ensures continuous improvement – the organization corrects its course based on experience and changing conditions.

All the above elements constitute the comprehensive approach required by the ISO 50001 standard. The system must cover all significant areas of energy consumption in the enterprise and the factors influencing them, as well as involve personnel who have an impact on energy performance (from technical staff to machine operators). It is important that the standard is designed to be applicable by any organization on its own, but it can be integrated with other management systems (e.g., as part of an integrated ISO system with quality or environment). A necessary condition, however, is that the entire system must be certified by an accredited certification body, which formally confirms compliance with the requirements of ISO 50001 and thus with the requirements of the directive.

Who is Obliged to Implement an EMS?

Directive 2023/1791 precisely defines the categories of enterprises that must take action regarding systematic energy management or audits. Unlike previous regulations, the new directive does not define obligations based on the size of the company (number of employees or turnover), but on the level of energy consumption by the enterprise. Thanks to this, the obligations now also cover some medium-sized enterprises with high energy intensity, which were previously exempt from such requirements. Below is a summary of the criteria:

• Large energy consumers – over 85 TJ annually: All enterprises (including manufacturing plants) with an average annual energy consumption over the last 3 years exceeding 85 TJ (approx. 23.6 GWh) must implement a certified energy management system according to ISO 50001 (or possibly EMAS, if the given country allows it). The deadline for achieving compliance is 4 years from the entry into force of the directive, i.e., by October 11, 2027, the enterprise should have an EMS certificate. In practice, this applies to the largest industrial plants, e.g., steel mills, refineries, chemical plants, large heavy industry, but also very energy-intensive plants from other sectors (e.g., large cement plants, paper mills, etc.).
• Medium energy consumers – from 10 TJ to 85 TJ annually: Enterprises consuming more than 10 TJ, but not more than 85 TJ of energy annually (average over 3 years) are also covered by the new requirements. These companies must conduct a periodic energy audit every 4 years, unless they decide to voluntarily implement a certified ISO 50001 system, which in their case can be an alternative path to compliance. The first audit should be carried out by October 11, 2026, and subsequent ones at least every four years. After each audit, the company must develop a concrete action plan implementing the audit recommendations and publish information on the implementation of these recommendations in its annual report. The audit obligation in this category now also applies to some SMEs – e.g., smaller industrial plants or large service companies – as long as they exceed the 10 TJ consumption threshold. This is a significant change, as previously the SME sector was exempt from mandatory audits.
• Others (below 10 TJ annually): Enterprises with lower energy consumption (<10 TJ annually) generally have no absolute obligation to implement an EMS or audits under the directive. This includes most small businesses. However, the directive encourages member states to create support programs and incentives so that even SMEs with lower consumption voluntarily conduct audits or implement efficiency improvement systems. Some countries may introduce their own requirements for sensitive sectors or offer co-financing for such activities to raise the overall level of energy efficiency in the economy.

In the context of industries, the directive does not assign different consumption thresholds for individual industrial sectors – the criterion is the amount of energy consumed, regardless of the type of activity. However, there are special requirements for selected facilities and sectors beyond the ISO 50001 system itself: for example, data centers with an IT power demand of ≥ 500 kW have new obligations regarding monitoring and reporting on energy efficiency (e.g., PUE-type indicators) and actions for the sustainable development of these facilities. In addition, the public sector has been given separate targets – administrative institutions must implement efficiency measures to achieve at least a 1.9% annual reduction in energy consumption in public buildings and infrastructure.

Generally, however, for manufacturing plants, the key factor determining the obligation is their level of energy consumption. For example, large factories and industrial plants in Poland often exceed the 10 TJ threshold, and the largest ones – 85 TJ annually, so they will have to implement ISO 50001 or at least perform energy audits. Companies that fall within the scope of the directive should take preparatory actions as soon as possible, because the time for adaptation (transposition of the directive into national law by 2025 and the first requirements from 2026/2027) is relatively short.

What to Consider When Choosing an Energy Management System?

Choosing and implementing an energy management system compliant with ISO 50001 is a strategic decision for an enterprise. Several factors should be taken into account to ensure the system effectively fulfills its tasks and is tailored to the company’s specifics:

1. Compliance with standards and certification possibility: The basic criterion is that the chosen system (whether built internally or with the help of external tools) must enable compliance with the ISO 50001 standard and the obtaining of a certificate. In practice, many companies use the services of consultants or software supporting EMS implementation, but ultimately the system must pass a certification audit. It is worth making sure that solution providers have experience with ISO 50001 and that the proposed tools (e.g., energy monitoring platforms) are compliant with the standard’s requirements (e.g., they allow for defining objectives, measuring EnPIs, reporting results).
   
2. Integration with existing systems and processes: If the enterprise already has other management systems (e.g., ISO 9001 for quality, ISO 14001 for environment), it is worth considering integrating the energy system with the current management structures. This will help avoid duplicating procedures and documentation – e.g., internal audits or management reviews for several systems can be combined. Sometimes companies decide to extend an existing environmental system with an energy module or implement EMAS, which covers a broader scope of management (including energy). It is also crucial to build the EMS into current operations – so that energy management does not function in isolation but is part of the organizational culture and daily tasks (e.g., through machine operation procedures, regulations for operators, etc.).
   
3. Monitoring functionality and measurement infrastructure: Effective energy management is based on data, so when choosing a solution, the existing (or planned) measurement infrastructure should be considered. It is necessary to check whether energy meters and sub-meters are installed in the plant in individual departments, technological lines, or on devices – if not, the implementation of an EMS may require investment in measurement equipment. It is important that the chosen energy management software is compatible with various measurement devices and systems (the so-called hardware neutrality principle). Thanks to this, the system will be able to automatically collect data from meters (e.g., through integration with the BMS/SCADA system in the factory) and present it in a form useful for analysis. When choosing a system, it is worth paying attention to whether it allows for real-time data analysis, generation of alarms (e.g., power overruns, consumption deviations), and whether it provides tools for forecasting and modeling consumption. These functions are extremely useful for reacting to inefficiencies on an ongoing basis and achieving continuous improvements.
   
4. Scalability and adaptation to the plant’s needs: The energy management system should be adapted to the size and nature of the enterprise’s activity. The EMS in a single factory will look different from that in a capital group with many branches. It is necessary to ensure that the scope of the system covers all areas of activity that consume a significant amount of energy – the directive requires that the system covers the entire enterprise (all legal units) if the calculated total consumption exceeds the thresholds. This means that in a structure with several subsidiaries, the energy consumption is summed up – so the system must cover the entire group, not just selected facilities. It is also necessary to consider whether it is more cost-effective to implement one consistent system for the entire organization or separate ones in individual plants (which, however, can complicate certification). The system should be flexible enough to be expanded as the company grows or to deepen its functionality (e.g., by adding other media: management of heat, compressed air, fuels, etc.).
   
5. Expert support and personnel training: Technology alone is not enough – the success of the system is determined by people. It is worth ensuring that appropriate expert knowledge is used during implementation (e.g., energy consultants or experienced engineering staff) and that training for personnel at all levels is planned. Appointing an Energy Manager or an energy team, trained, for example, according to a European program (qualifications of an auditor/energy manager), is good practice. When choosing a system (and possibly a software provider), let’s pay attention to whether training modules, documentation, support in data analysis are offered, and whether the tool interface is user-friendly. The involvement of employees from operational departments, maintenance, and even production is crucial – the system must provide them with useful information and be acceptable in daily use, otherwise it will remain only “on paper”.
   
6. Implementation and maintenance costs: The budget available to the company for the implementation and subsequent maintenance of the EMS should be assessed. The costs include, among others, the purchase or development of software, the installation of additional meters and sensors, fees for external certification, personnel training, and possible consulting. It is important to treat these expenses as an investment with a quick return – many enterprises recover the costs of implementing ISO 50001 in the form of saved energy within a few years or even faster. Nevertheless, before choosing a specific solution, it is worth preparing a cost-benefit analysis. For example, a cloud SaaS solution may have different costs (subscription) than an in-house system on the company’s infrastructure, but also different capabilities. It is also good to plan for certification in advance – due to the high demand for ISO 50001 auditors before the 2027 deadline, it is worth booking audit dates in advance to avoid delays or penalties for not meeting deadlines.

Finally, it should be emphasized that choosing an energy management system is not a one-time action, but the beginning of a process of continuous improvement. The key is to build an organizational culture in which energy efficiency is a priority on par with other business goals. With a well-chosen and implemented ISO 50001 system, an enterprise will not only fulfill its obligations under the directive but will use them as an opportunity to permanently reduce costs and increase its competitiveness on the market. As a result, the implementation of an EMS will become an element of the company’s sustainable development strategy, bringing tangible economic and environmental benefits for years to come.