• 08/11/2025
  • Article

Tapping waste heat potentials: Mandatory reporting, increasing efficiency and investment planning

More energy efficiency thanks to waste heat utilisation: a complex topic that represents an important area of investment with great potential for many companies. For more and more companies, however, the topic is also associated with far-reaching and sometimes onerous obligations. This is because legislation has already obliged companies to systematically record and report waste heat potential since mid-2024. And these obligations will become even more extensive in 2025.
AI-generated image of a metal smelter, with liquid metal flowing from a smelting furnace in the center
Hot energy source: Steel production generates enormous amounts of waste heat – modern technologies make it possible to use this efficiently and thus significantly reduce energy consumption.

With the German Energy Efficiency Act (EnEfG), which came into force in 2023, the legislator has created a waste heat platform for the first time.

What will change from 2025?

The legislator has obliged companies with an annual energy consumption of more than 2.5 gigawatt hours to report so-called "significant" and "managed" waste heat potentials by 1 January 2025. The reporting obligation then includes detailed waste heat reporting, which means that companies must now report so-called waste heat potential above the threshold values. In addition to basic company data and waste heat potentials, this also includes data such as specific heat quantities or performance profiles and regulation options. This increases complexity and effort for companies.

Companies should therefore first clarify whether and to what extent they are obliged to report - and if so, what data they have to report.

Companies have a duty of disclosure for this data:

  • Companies and locations
  • Waste heat potential
  • Annual amount of heat
  • Maximum thermal output
  • Performance profile
  • Available options for controlling of temperature, pressure and feed-in
  • Average temperature level

This overview is based on the information sheet for the waste heat platform from the Federal Office of Economics and Export Control (Bafa).

Overview chart with the requirements for the reporting obligation of a system

When do companies have to act?

In principle, companies are required to report if they have consumed an average of more than 2.5 gigawatt hours of energy per year in the last three completed calendar years.

Regulations on which companies do not have to report or for which individual sites and installations they do not have to provide information are defined by so-called de minimis thresholds. These include a location threshold, according to which locations with waste heat potential totalling less than 800 MWh per year are exempt from the reporting obligation. In addition, there are so-called installation thresholds that exempt individual installations from the reporting obligation. For example, installations that generate less than 200 MWh of waste heat per year are exempt from the reporting obligation. The same applies to installations with less than 1,500 operating hours per year or an annual average waste heat temperature of less than 25°C.

What are the penalties for non-compliance?

If a company subject to the reporting obligation fails to fulfil its statutory reporting obligation, it is committing an administrative offence. The Bafa can penalise this with a fine of up to 50,000 euros, depending on the extent of the information missing.

Overview chart with the requirements for the obligation to register a site

Companies are confronted with numerous questions

What exactly is a waste heat source and what does waste heat potential mean? What is meant by significant, diffuse and conducted waste heat?

Which de minimis thresholds apply to my company, my sites or individual plants? Which special regulations still apply to my company?

How do I record specific waste heat potentials, basic data or make plausible estimates for my company? And how do I transfer my data to the waste heat platform correctly and on time?

VEA Head of Efficiency Dipl. Ing. (FH) Jens Fischer emphasises the opportunity for companies in cooperation with the VEA - Bundesverband der Energie-Abnehmer e. V.: "The requirements for reporting obligations are increasing for the topic of waste heat - both in terms of scope and complexity. With our customised measurement concepts, we can turn these onerous obligations into an opportunity for companies: Together with them, we create transparency about their consumption and thus not only fulfil the legal obligations for them but also create approaches to increase their energy efficiency and make sensible use of the waste heat they generate."

You can meet VEA at POWTECH TECHNOPHARM: Attend the presentation on Wednesday, 24 September 2025 at 9:30 a.m. in the TECHNOPHARM FORUM in Hall 10.

Are you interested in this topic? Then come to POWTECH TECHNOPHARM and experience this and many other topics live at the trade fair. Get your ticket here with the following code: PTTP25Insights