The calculation of the energy consumption over 1000h, as well as the calculation for the EEI, shall be based on the Pmeasured value obtained after the deduction of the 10% allowance, where applicable. This is now explicitly mentioned in an amendment to Regulation (EU) 2019/2020.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.