What ELR is and why it matters
The Energy Labelling Regulation (ELR) — formally Regulation (EU) 2017/1369 setting a framework for energy labelling — is the EU law that puts the familiar A–G energy label on products and governs how that label is produced, registered and displayed. If you supply or sell energy-related products such as household appliances, lighting, displays or heating products, ELR almost certainly shapes how you can market them. The Regulation establishes the overarching framework; the precise label design and the rules for each product group are then set out in product-specific delegated regulations adopted under it.
ELR matters because it replaced the older Directive-based regime with a directly applicable regulation, introduced the rescaled A–G labels that removed the confusing “A+++” classes, and created the EPREL product database in which every covered model must be registered before it can be placed on the market. The practical effect is that the energy label is no longer just a sticker: it is tied to a registered dataset, mandatory in advertising, and enforced across the whole supply chain from supplier to retailer.
📄 Official text: Regulation (EU) 2017/1369 on energy labelling — on EUR-Lex →
Who ELR applies to
ELR applies across the supply chain rather than to a single actor. The Regulation distinguishes two principal roles, and the duties scale accordingly:
- Suppliers — the manufacturer established in the Union, or the authorised representative of a manufacturer not established in the Union, or the importer who places the product on the Union market. Suppliers carry the heaviest obligations, including producing the label, the product information sheet and the technical documentation, and registering the model in EPREL.
- Dealers — retailers and other actors who sell, hire, offer for hire-purchase or display products to customers. Dealers must show the label and use it correctly in their stores and in their advertising.
The Regulation applies to energy-related products placed on the market or put into service that are covered by a delegated regulation. It does not apply to second-hand products, nor to means of transport for persons or goods, and the framework leaves the precise product groups — refrigerating appliances, washing machines, dishwashers, televisions and electronic displays, light sources, tyres, space and water heaters and others — to be defined by their own delegated acts.
Key dates and timeline
- 2017 — Regulation (EU) 2017/1369 was adopted, replacing the earlier Energy Labelling Directive 2010/30/EU and setting the new framework.
- 1 August 2017 — the Regulation applies from this date, repealing Directive 2010/30/EU. From this point the EPREL database and the rescaling mechanism became part of the legal framework.
- From 2021 onwards — the first rescaled A–G labels began appearing in shops as product-specific delegated regulations took effect, starting with groups such as refrigerators, dishwashers, washing machines and displays, and later light sources. The “A+”, “A++” and “A+++” classes are being phased out group by group as each delegated act applies.
Because each product group is governed by its own delegated regulation, the exact rescaling dates differ from group to group; the framework Regulation itself has applied since 2017.
Core requirements
The A–G energy label
The centrepiece of ELR is a standardised label showing a product’s energy efficiency class on a closed A to G scale, where A is the most efficient and G the least. The label uses a consistent colour-coded arrow design and, depending on the product group, additional information icons covering parameters such as energy consumption, capacity, noise emissions or water use. The rescaling introduced by ELR deliberately leaves the top classes empty at first so that there is room for future, more efficient products. Suppliers must provide printed labels for each unit, and the exact content and layout for each product group is fixed by the relevant delegated regulation.
Registration in the EPREL database
Before placing a covered model on the market, the supplier must enter the information for that model into the European Product Registry for Energy Labelling (EPREL), the public database run by the Commission. Registration covers the label, the product information sheet and the technical documentation. The model’s identifier must be registered before the product is offered for sale, and the public-facing part of EPREL lets consumers and authorities look up the label and key data, including via the QR code printed on the label. Suppliers must keep the registered information accurate and keep records for a defined period after the last unit is placed on the market.
The product information sheet and technical documentation
Alongside the label, the supplier must produce a product information sheet for each model, presenting the standardised parameters set out in the applicable delegated regulation. The supplier must also compile technical documentation sufficient to allow authorities to assess the accuracy of the label and information sheet, including a general description of the model, references to standards applied, test parameters and measurement results. This documentation must be made available to market surveillance authorities on request, and the information sheet must be available to dealers so they can pass it to customers.
Supplier and dealer obligations
ELR splits practical duties between the two roles. Suppliers must supply correct printed labels and information sheets free of charge to dealers, register models in EPREL, ensure the accuracy of labels, and not provide products designed to alter their performance under test conditions in order to appear more favourable. Dealers must display the label visibly — on the product or near it in store — and make the information sheet accessible to customers, including for distance and online selling where the label and sheet must be shown next to the product.
Energy labels in advertising
A distinctive ELR requirement is that visual advertisements and technical promotional material for a covered product must reference the product’s energy efficiency class. Where an advertisement or promotional material discloses energy-related or price information for a specific model, it must also show the energy efficiency class and the range of the available classes on the label. This applies to advertising by both suppliers and dealers, including online, so the label’s information follows the product into the way it is marketed.
Obligations by role
- Suppliers — design and provide the printed label and product information sheet, compile technical documentation, register every covered model in EPREL before placing it on the market, ensure accuracy, and reference the efficiency class where they advertise.
- Dealers — display the correct label visibly in store and online, make the information sheet available to customers, and include the energy efficiency class and class range in their visual advertising and promotional material.
Enforcement
Each Member State designates market surveillance authorities to enforce ELR, drawing on the EU market surveillance framework. In Denmark, the Danish Energy Agency (Energistyrelsen) is the competent authority for energy labelling and ecodesign. Authorities can check that models are correctly registered in EPREL, that labels and information sheets are accurate, that dealers display labels and that advertising references the efficiency class.
Authorities can require corrective action, order products to be brought into conformity, and act against missing or false labels — including where laboratory testing shows a model does not meet its declared class. Consequences for non-compliance are set at national level and can include orders to stop sales, withdrawal from the market, fines and reputational damage. Because EPREL is EU-wide and public, an inaccurate label is visible to authorities and competitors across the Union.
Getting compliant
- Confirm which delegated regulation applies to each of your products and which rescaled label and parameters it requires.
- Generate the correct A–G label and product information sheet for every model.
- Compile technical documentation supporting the declared energy efficiency class.
- Register each model in the EPREL database before placing it on the market and keep the entry accurate.
- Provide labels and information sheets free of charge to your dealers.
- Ensure dealers display the label and show the information sheet, including in online listings.
- Reference the energy efficiency class and class range in all visual advertising and technical promotional material.
Related guides
How Conphora helps
Conphora monitors ELR and its delegated regulations and maps your products against their requirements, flagging gaps in labelling, the product information sheet, EPREL registration and advertising before they become enforcement problems. The platform helps you generate and keep the right documentation, and alerts you when product-specific delegated acts or rescaling dates change so your compliance stays current.
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Sources and further reading
- Regulation (EU) 2017/1369 on energy labelling — EUR-Lex
- Energistyrelsen (Danish Energy Agency) — ens.dk
This guide is for general information and is not legal advice.
Last updated: 12 June 2026