Additionality & Materiality | Energy Efficiency Directive Article 7 | Energy Efficiency Directive | ENSPOL | Energy Saving Policies and Energy Efficiency Obligation Schemes |

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Additionality and Materiality

The general understanding is that:

  • Materiality means involvement in the action
  • Additionality is actions that are seen as the capability of the system to promote a change. 

Both terms are crucial for the determination of the baseline when calculating savings from energy efficiency measures, however for both, the understanding of them and the concrete implementation is quite different among Member States (MS).

To quantify the impact of policy measures, only energy savings that are a result of real individual actions that result from the implementation of these policy measures are to be taken into account. Savings can be counted from any individual action that saves energy and are undertaken as a result of policy measures in a MS. See the Commission's Guidance Document for further explanation and references to particular Articles here.


“the activities of the obligated, participating or entrusted party must be demonstrably material to the achievement of the claimed savings” (Annex V, part 2, point c)

MS may not count actions that would have happened anyway. The activities of the national public sector parties that are implementing the policy measure must be 'material' to the carrying out of the action. The term 'material' means that the party in question must have contributed to the realisation of the specific individual action in question, and that the subsidy or involvement of the obligated, participating or entrusted party must not have had what is clearly only a minimal effect in the end user’s decision to undertake the energy efficiency investment, and must be able to show that this is so.

In addition in some cases, only savings that go beyond the minimum requirements originating from EU legislation can count. This is relevant for individual actions that are a result of energy efficiency obligation schemes, alternative policy measures and a national energy efficiency fund, are related to other Directives.

There are additional limitations to count savings from certain alternative policy measures, set out in Article 7(9)(d) and (e), where it is stated that only if the nationally established levels are more ambitious than those required at EU level – as far as this is legally possible – that the difference between the mandatory EU levels and the concretely established levels can be counted.


Additionality is defined as the requirement that goes beyond the standard by only promoting best available technologies in order for an energy efficiency measure to be eligible. Additionality is also connected with income levels of households, with low income households exhibiting different behaviours to higher income households.  


  • In the UK, heating saving measures can only be claimed for low income homes, as it is assumed that higher income homes will replace boilers with the latest models in line with the building code, whereas the poorest households cannot afford to replace broken boilers and therefore use electric heaters instead.

Two basic methods to evaluate additionality are to send surveys to companies and send questionnaires to consumers. Deemed savings can then be reduced by the same percentage as the resulting calculated/observed additionality.

It is not possible to achieve 100% additionally through the implementation of an EEO. Trying to do so will generate high economic costs as a result. Increasing additionality thus always comes at a cost.

Ways of increasing additionality include giving advice and giving low subsidies to consumers and promoting incentives at community level. A combination of different measures/incentives (e.g. advice and subsidy) provides the highest level of additionality.

Sources and further reference:


More in this category: Double counting »

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