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§ EED Article 11

The EED audit, ready before the deadline.

The recast Energy Efficiency Directive (EU 2023/1791) makes energy audits mandatory for every enterprise above 10 TJ a year — roughly 2.8 GWh, a line most GMP pharma sites clear many times over. The first are due 11 October 2026, and audit capacity has tightened into every EU deadline on record. SEU builds the analytical core of that audit in days, structured to the EN 16247-1 headings an assessor checks.

§ The regulatory clock
11 Oct 2026First mandatory audit> 10 TJ/yr (≈ 2.8 GWh)11 Oct 2027Certified EnMS (ISO 50001)> 85 TJ/yr (≈ 23.6 GWh)FY 2027CSRD ESRS E1 reportingenergy & emissions disclosureEED 2023/1791 · EN 16247-1 · audits repeat every four years; ISO 50001 surveillance is annual

Every prior EU/UK audit cycle ended in a late pile-up and assessor scarcity. Starting in the deadline quarter means paying peak consultancy rates for the same model SEU builds now.

§ Requirement → report section

What EN 16247-1 and EED Annex VI ask of an audit, and where the SEU report carries it.

Requirement
Based on up-to-date, measured, traceable operational data
In the audit
§3 Basis of audit & data provenance

Bill reconciliation — modelled annual energy held against your 12-month utility bills with the residual stated plainly — plus IPMVP Option C calibration against an interval meter export.

Requirement
Detailed review of the energy consumption profile
In the audit
§5 Energy review (ISO 50001 §6.3)

Energy baseline (EnB), normalised EnPIs (kWh/m², kWh/unit), energy by end-use, and an 8,760-hour load profile with load-duration and pattern decomposition.

Requirement
Proportionate, representative coverage of significant energy use
In the audit
§4 M&E balance · §5.2 SEU register

A per-equipment first-law balance across the whole utility network, and a Significant Energy User register with Pareto coverage — the 80/20 of where the energy actually goes.

Requirement
Life-cycle cost analysis, not simple payback periods
In the audit
§8 Discounted cashflow · §11 MACC

Measures ranked on NPV and IRR over the analysis horizon with fuel and electricity escalation — and a marginal abatement cost curve for the carbon view.

Requirement
Recommendations with a basis for follow-up
In the audit
§10 Ranked opportunities · §11 Roadmap & M&V

Every measure carries capex, saving, NPV, payback and GMP change-control triage; the decarbonisation roadmap sequences them and the M&V protocol defines how savings get verified.

Requirement
Storable data for historical analysis and performance follow-up
In the audit
The portable plant file (.seu.json)

The entire model — equipment, topology, assumptions, anchors — saves to a file you own. Re-open it next year, re-reconcile against the new bills, and the audit regenerates.

SEU produces the analytical core; formal certification and sign-off remain with your qualified auditor or certification body. See the methodology for what each engine rests on — and its honest limits.

§ Asked by obligated sites

Does SEU satisfy an EED Article 11 energy audit?

SEU produces the analytical core of one — an energy review structured to the EN 16247-1 headings an auditor checks: a measured-data basis (bill reconciliation plus optional meter calibration), coverage of the significant energy users, life-cycle-cost-ranked recommendations, and a storable model for follow-up. Formal certification and regulatory sign-off remain with your qualified auditor; SEU is the engine under that work, not a rubber stamp.

What do the 10 TJ and 85 TJ thresholds mean?

Under the recast Energy Efficiency Directive (EU 2023/1791), enterprises averaging above 10 TJ of annual energy use (≈2.8 GWh) must complete an energy audit every four years — the first by 11 October 2026. Above 85 TJ (≈23.6 GWh), an audit is no longer enough: a certified energy-management system such as ISO 50001 is required by 11 October 2027. Most GMP pharma sites sit well above both lines.

Will my IT department need to review anything?

There is nothing to install and no integration: SEU runs in the browser, the model is stored on your device, and no plant data reaches our servers. It sits outside the BMS control loop and writes to nothing, so it is decision-support outside the GxP-validated estate — the long procurement gate never opens.

Can our consultancy use SEU for our audit?

Yes — and that is often the fastest path. Your appointed auditor keeps the judgement, the site walk and the sign-off; SEU does the weeks of spreadsheet model-building that sit underneath. The audit stays their deliverable.

What does “calibrated” mean here?

That the model has been held against metered reality and the variance is shown plainly, not hidden. The first anchor is your utility bills (annual electricity and fuel against the modelled totals — the site-closure check in the report); an interval meter export then sharpens that to a load profile. The report states its basis either way: bill-anchored, or benchmark estimate.

In scope for October 2026?

A fixed-fee pilot audit gets the analytical core done now — before the deadline quarter prices it like an emergency.