Latest Energy Labels: Are you a retailer of white goods, electronic displays or light sources?

Latest Energy Labels: Are you buying an appliance, a television or lights?

Subsidiary Legislation 427.96, Energy Labelling (Implementing Measures) Regulations, enacts Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU.

Scope

The Regulation lays down a framework that applies to energy-related products placed on the market or put into service. It provides for the labelling of those products and the provision of standard product information regarding energy efficiency, the consumption of energy and of other resources by products during use, and supplementary information concerning products. Consequently, enabling customers to choose more efficient products in order to reduce their energy consumption while encouraging companies to design more efficient products.

Applicability

The Regulation applies to the below energy-related products, where their requirements are set through Commission Delegated Regulations or Regulation and all the corresponding amending acts: 

Air conditioners (Commission Delegated Regulation (EU) No 626/2011)

Domestic ovens and range hoods (Commission Delegated Regulation (EU) No 65/2014) 

Electronic displays including televisions (Commission Delegated Regulation (EU) 2019/2013)

Household dishwashers (Commission Delegated Regulation (EU) 2019/2017)

Household refrigerating appliances (Commission Delegated Regulation (EU) 2019/2016)

Household tumble dryers (Commission Delegated Regulations (EU) No 392/2012 & 2023/2534)

Household washing machines and household washer-dryers (Commission Delegated Regulation (EU) 2019/2014)

Light sources (Commission Delegated Regulation (EU) 2019/2015)

Local space heaters (Commission Delegated Regulation (EU) 2015/1186)

Professional refrigerated storage cabinets (Commission Delegated Regulation (EU) 2015/1094)

Refrigerating appliances with a direct sales function (Commission Delegated Regulation (EU) 2019/2018) 

Residential ventilation units (Commission Delegated Regulation (EU) No 1254/2014)

Smartphones and slate tablets (Commission Delegated Regulation (EU) 2023/1669)

Solid fuel boilers and packages of a solid fuel boiler, supplementary heaters, temperature controls and solar devices (Commission Delegated Regulation (EU) 2015/1187)

Space heaters, combination heaters, packages of space heater, temperature control and solar device and packages of combination heater, temperature control and solar device (Commission Delegated Regulation (EU) No 811/2013)

Water heaters, hot water storage tanks and packages of water heater and solar device (Commission Delegated Regulation (EU) No 812/2013)

Tyres (Regulation (EU) 2020/740) (MCCAA relevant page)

The energy labelling legislations do not cover second-hand products, unless they are imported from outside the EU, or means of transport for persons or goods.

Energy Labelling Product database – EPREL database

The European Commission had established and is maintaining a product database, EPREL (European Product Database for Energy Labelling), consisting of a public part and a compliance part. Commission Implementing Regulation (EU) 2024/994 lays down the operational details of the EPREL database.

Consumers are able to access the public part of the database and to consult product labels and information sheets, making it easier for them to compare the energy efficiency and other parameters of various products. They can access this information either by accessing the EPREL public website at https://eprel.ec.europa.eu/screen/home or by scanning the QR-code on the energy labels of the latest updated products.

Suppliers (EU-based manufacturers, or importers or authorised representatives of non-EU manufacturers) have to upload information about their products, related to the energy label, technical documentation and compliance monitoring, into this database, before placing their products on the EU market. In return, EPREL database generates the energy labels based on the data the suppliers entered when they registered their product models.

In order to register their products, suppliers must initially create a ‘new supplier organisation' (the suppliers’ company) on the EPREL website. This will require the creation of an EU login account. This EU login account will also provide access to the EPREL guidelines including information on the registration process.

Since the 22^nd of October 2024, the suppliers’ verification in EPREL database is mandatory. A demonstration by the European Commission of how to upload products and going through the supplier verification process on the EPREL database according to the latest novelties introduced by Regulation (EU) 2024/994, can be accessed here: https://www.youtube.com/watch?v=TSh-VukeCx8, while the corresponding EC presentation can also be accessed, from here: https://www.lightingeurope.org/images/2024-10-25-Webinar-Verification-pt.pdf.

General obligations of suppliers

The general obligations of suppliers include:

1. The supplier must supply each product with a printed energy label. They must also either supply a printed product information sheet with each product or insert the parameters of the product information sheet in the product database, depending on the relevant delegated act.
2. The supplier shall ensure accuracy of the energy labels, the product information sheets and the technical documentation.
3. The supplier must inform consumers if software or firmware updates that could reduce a product's energy efficiency and provide them with the opt-out option.
4. The supplier shall not use 'defeat devices', which alter a product's performance under test conditions.

Obligations of suppliers in relation to the product database

The obligations of suppliers in relation to the product database include:

1. From 1 January 2019, the supplier must, before placing on the market a new model covered by a delegated act, enter in the public and compliance parts of the product database the information for that model.
2. Where models covered by a delegated act are placed on the market between 1 August 2017 and 1 January 2019, the supplier must, by 30 June 2019, enter in the product database the information in relation to those models.
3. The supplier may enter in the product database the information for models that were placed on the market before 1 August 2017.
4. If changes that are made to a product, effect the energy label or the product information sheet, that product must be considered as a new model.
5. After the final unit of a model has been placed on the market, the supplier must keep the information concerning that model in the compliance part of the product database for 15 years. The information in the public part of the database must not be deleted.

Obligations of dealers

The obligations of dealers include:

1. The dealer must display, in a visible manner, the energy label for each product covered by a delegated act.
2. They must also make available to customers the product information sheet, including, upon request, in physical form at the point of sale.

Other obligations of suppliers and dealers

Other obligations of suppliers and dealers include:

1. The suppliers and dealers must make reference to the energy efficiency class of the product and the range of the efficiency classes available on the energy label in visual advertisements or technical promotional material for a specific model in accordance with the relevant delegated act. Thus, for internet sales, the product's energy label or the product’s energy class with a nested arrow that links to the energy label must be clearly displayed, near the price and in the same font size.

2. They must cooperate with market surveillance authoritiesand take immediate action to remedy any case of non-compliance with the requirements set out in the Regulation and the relevant delegated acts.
3. They must not provide or display other labels, marks, symbols or inscriptions, on products covered by delegated acts, which do not comply with the requirements of the Regulation and the relevant delegated acts.
4. They must not supply or display labels which mimic the labels provided for under the Regulation and the relevant delegated acts, on products not covered by delegated acts and on non-energy related products.

Enforcement and penalties

The regulations provide powers to Technical Regulations Division (TRD), to take action against economic operators for products that are not in conformity with the regulations. TRD is required to take all appropriate measures to withdraw from the market or to prohibit or to restrict the supply of products requiring CE Marking which may endanger the health and safety of persons, property or the environment.

Economic operators are required to co-operate with the enforcement authority and on request, must provide information and take action as appropriate. Economic operators failing to comply with the requirements of the regulations are subject to the provisions of the Product Safety Act.

Further Information

The European Commission has produced a guidance site on the energy-related products having the Energy Labelling and/or Ecodesign legislation. The products in this guidance site are divided into separate categories and each product link contains several information, such as on energy savings, energy labelling and ecodesign requirements: https://energy-efficient-products.ec.europa.eu/product-list_en.

More information on Ecodesign and Energy Labelling legislation of the energy-related products are found at: https://europa.eu/youreurope/business/product-requirements/labels-markings/energy-labels/index_en.htm and https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/ecodesign_en

The European Commission has also produced an EPREL Wiki Workspace, which can be accessed by using an EU login account:

https://webgate.ec.europa.eu/fpfis/wikis/pages/viewpage.action?spaceKey=EPREL&title=European+Product+Registry+for+Energy+Labelling+Workspace

The European Commission has further produced guidance regarding CE marking, which can be found at: https://ec.europa.eu/growth/single-market/ce-marking

The European Commission has also produced guidance document called the Blue Guide intended to contribute to a better understanding of EU product safety rules and to their more uniform and coherent application across different sectors and throughout the single market. The Blue Guide can be found at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2022.247.01.0001.01.ENG

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