Written by Giulia Baldelli
The limited availability of accurate and systematically collected data on energy consumption, particularly for small and medium-sized enterprises (SMEs), poses a significant challenge to the effective implementation of Article 11 of the Energy Efficiency Directive (EED). This lack hinders the identification of companies subject to specific regulatory obligations. Moreover, accurate knowledge of energy consumption patterns is a key prerequisite for identifying energy efficiency improvement opportunities.
Improving energy efficiency in SMEs is a key component of the European Union’s climate strategy. Approximately 24.3 million SMEs operate across the EU, representing 99.8% of all enterprises and employing nearly 85 million people, equivalent to around 64% of the total workforce1, making their contribution to the energy transition particularly significant. However, companies operating close to regulatory thresholds often have limited awareness of their actual energy consumption and of the benefits brought by the implementation of energy efficiency and renewable energy measures.
To address this gap, a set of indicators has been developed to estimate company-level energy consumption. The selection of these indicators is based on existing scientific literature and standardized estimation methodologies, with priority given to metrics that are both practical to apply and representative of real energy use. Among them, energy consumption per employee is adopted as the primary indicator; it provides a simple yet effective proxy for energy intensity. This indicator is intended to support preliminary screening, facilitate benchmarking across companies, and help identify businesses that may require further assessment under the EED.
Methodology
As no official data are available on the number of companies falling within the scope of Article 11 of the Energy Efficiency Directive (EED), nor on the annual energy consumption of individual enterprises, an indirect estimation approach was adopted.
The analysis was based on the most recent datasets available from Eurostat and the Joint Research Centre (JRC). Data refer to 2023. Energy consumption data were collected by country and economic sector. Manufacturing activities were analysed according to the NACE classification, while the service sector included the following activities: accommodation and food service (I), administrative and support service activities (N), arts, entertainment and recreation (R), education (P), human health and social work activities (Q), information and communication (J), real estate activities (L), professional, scientific and technical activities (M), water supply, sewerage and waste management (E), and wholesale and retail trade, including the repair of motor vehicles (G). Mining and quarrying (B) and construction (F) were also included in the analysis.
Eurostat structural business statistics were used to obtain the number of enterprises and employees by country, sector and enterprise size. Five size classes were considered: 0–9, 10–19, 20–49, 50–249 and 250 or more employees.
The estimation of SME energy consumption was based on the assumption that energy use is proportional to the number of employees within each sector. For each country and sector, the average energy consumption per employee was calculated by dividing total sectoral energy consumption by the total number of employees. This indicator was then multiplied by the number of employees in SMEs to derive their total energy consumption. To estimate energy consumption at the enterprise level, the average energy consumption per employee was multiplied by the upper bound of each size class (e.g., 9 employees for the 0–9 class), providing a conservative estimate of the maximum energy consumption within that class. This approach allows to identify the size classes that could potentially exceed the annual threshold of 10 TJ established by Article 11 of the EED. By combining these estimates with the number of enterprises in each size class, country and sector, it was possible to estimate the share of SMEs potentially exceeding the 10 TJ annual energy consumption threshold. The analysis was repeated for all countries and sectors considered, enabling cross-country comparisons and providing a consistent proxy for SME energy consumption where direct measurements are unavailable. Finally, the results were cross-checked against findings from the scientific literature and other available sources to assess the robustness of the estimates.
Main results and implications for research
Across all manufacturing sub-sectors in the EU, SMEs dominate in terms of number of companies, typically accounting for more than 99% of firms. Despite this dominance, there is a wide cross-country and cross-subsectors variability. However, only a limited share of SMEs exceeds the 10 TJ threshold, meaning most of them are not subject to the energy audit obligations. Three sub-sectors show the highest share of SMEs falling under the obligations of Article 11 of the EED:
- Manufacturing of chemical and pharmaceutical products: more than 90% of SMEs exceeds the 10 TJ threshold in six countries (Belgium, Bulgaria, Finland, Hungary, Lithuania and Romania).
- Manufacturing of non-metallic mineral products: more than 90% of SMEs exceed the 10 TJ threshold in ten countries (Austria, Belgium, Croatia, Cyprus, Denmark, France, Ireland, Italy, Latvia and Spain).
- Mining and quarrying sectors: more than 80% of SMEs exceed the 10 TJ threshold in five countries (Austria, Belgium, Denmark, Finland and Spain).
Both the services and the construction sectors are characterized by a limited energy consumption with around 0-2% of SMEs falling under the audit obligations.
This research will be further developed, and new proxy indicators will be added to the analysis.
- Katsinis, A. A. et al., 2024. Annual Report on European SMEs 2023/2024, SME performance review, Luxemburg: Publications Office of the European Union. ↩︎
