--- title: "ELR — Energy Labelling Framework Regulation" description: "The Energy Labelling Framework Regulation sets the rules for the A to G energy label, product information sheet and EPREL database for energy-related products, with duties for suppliers (manufacturers, authorised representatives, importers) and dealers. It has applied since 1 August 2017; EPREL registration since 1 January 2019, and the newest rescaled labels from 1 July 2025 for tumble dryers." type: "guide" url: "https://www.conphora.com/regulations/elr/" markdown: "https://www.conphora.com/regulations/elr.md" locale: "en" language: "en" published: "2017-08-01" updated: "2026-09-12" author: "Conphora compliance team" publisher: "Conphora" reference: "Regulation (EU) 2017/1369" celex: "32017R1369" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R1369" tags: ["ELR", "Energy & Ecodesign"] license: "Free to quote with attribution and a link to the page" --- # ELR — Energy Labelling Framework Regulation The Energy Labelling Framework Regulation sets the rules for the A to G energy label, product information sheet and EPREL database for energy-related products, with duties for suppliers (manufacturers, authorised representatives, importers) and dealers. It has applied since 1 August 2017; EPREL registration since 1 January 2019, and the newest rescaled labels from 1 July 2025 for tumble dryers. ## Key facts - **Official title:** 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 - **Reference:** Regulation (EU) 2017/1369 - **CELEX:** 32017R1369 - **Act type:** Regulation - **In force:** 2017-08-01 - **Applies from:** 2017-08-01 - **Enforced by:** National market surveillance authorities enforce the regulation and its delegated acts with the powers of Regulation (EU) 2019/1020; in Denmark, Sikkerhedsstyrelsen, part of Erhvervsstyrelsen since January 2026, has carried out the market surveillance of ecodesign and energy labelling for Energistyrelsen since 1 August 2018 and is today named as the control authority in executive order nr. 1322 of 9 June 2021 (§ 2) under the produktenergimærkningsloven (lovbekendtgørelse nr. 186 of 2 February 2022), while Energistyrelsen keeps the overall responsibility for developing and interpreting the rules and is the Danish authority responsible for the EPREL database. The regulation's own surveillance article still cites Articles 16 to 29 of Regulation (EC) No 765/2008, read as Regulation (EU) 2019/1020 since 16 July 2021, and the toolkit is an evaluation of the product, an order to the supplier or dealer to take corrective action, to withdraw or to recall the product within a set period, provisional measures prohibiting or restricting its availability where the operator does not act, extension of those measures to all units of the model and its equivalent models, recovery of document inspection and testing costs from the supplier, and national penalties that must be effective, proportionate and dissuasive, in Denmark påbud, forbud, orders to online interfaces, publication of results and fines. - **Category:** Energy & Ecodesign ## Who it applies to **Covered by the act:** Energy-related products, meaning goods or systems with an impact on energy consumption during use, including parts intended to be incorporated into products, placed on the market or put into service in the Union; In practice the product groups covered by a delegated act: refrigerating appliances, washing machines and washer-dryers, dishwashers, tumble dryers, electronic displays including televisions and monitors, light sources, smartphones and slate tablets, space and combination heaters, water heaters and storage tanks, solid fuel boilers, local space heaters, air conditioners, domestic ovens and range hoods, residential ventilation units, refrigerating appliances with a direct sales function and professional refrigerated storage cabinets; Suppliers: the manufacturer established in the Union, the authorised representative of a manufacturer not established in the Union, or the importer, who places the product on the Union market; Dealers: retailers and any other natural or legal person who offers for sale, hire or hire purchase, or displays products to customers or installers in the course of a commercial activity, including online distance selling; Visual advertisements and technical promotional material for a specific model, which must show the energy class and the range of classes **Derived and downstream products:** Second-hand products are outside the regulation unless they are imported from a third country; means of transport for persons or goods are always outside it (Art. 1(2)); A product whose label-relevant characteristics change is a new model and needs its own EPREL registration; a product without a delegated act carries no label but may not carry a label that mimics the EU label (Art. 4(4) and Art. 6(d)); Delegated acts adopted under Directive 2010/30/EU and Directive 96/60/EC stay in force, with the obligations of this regulation, until a delegated act under Article 16 replaces them (Art. 20(4)); Tyres are labelled under Regulation (EU) 2020/740 but registered in the same product database (Art. 12(2)(a) as amended); Packages of space heaters, water heaters and solid fuel boilers assembled by the dealer are labelled by the dealer alone, and the supplier's database registration duty does not apply to them (Art. 4(5)) **Roles under the act:** - **Supplier: manufacturer established in the Union** — A manufacturer is a natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under its name or trademark; a manufacturer established in the Union who places a product on the Union market is a supplier and carries the supplier obligations. - **Supplier: authorised representative of a non-EU manufacturer** — A natural or legal person established in the Union who has received a written mandate from the manufacturer to act on its behalf in relation to specified tasks; the authorised representative of a manufacturer who is not established in the Union is the supplier when it places the product on the Union market. - **Supplier: importer** — A natural or legal person established in the Union who places a product from a third country on the Union market; an importer who places a product on the Union market is a supplier and carries the supplier obligations. - **Dealer (retailer, online shop, wholesaler displaying to installers)** — A retailer or other natural or legal person who offers for sale, hire, or hire purchase, or displays products to customers or installers in the course of a commercial activity, whether or not in return for payment. ## Key dates - 2017-07-04: Regulation (EU) 2017/1369 adopted by the European Parliament and the Council in Strasbourg - 2017-08-01: Entry into force, the fourth day after publication in OJ L 198 of 28 July 2017, and application; Directive 2010/30/EU repealed; existing delegated acts under the directive stay in force until replaced - 2018-11-02: Deadline for the Commission to adopt rescaled A to G labels for dishwashers, refrigerating appliances, washing machines, televisions, lamps and washer-dryers; the six delegated regulations were adopted on 11 March 2019 - 2019-01-01: Article 4 applies: suppliers must register every new model covered by a delegated act in the public and compliance parts of the product database (EPREL) before placing a unit on the market - 2019-06-30: Deadline to register in EPREL the models placed on the market between 1 August 2017 and 1 January 2019 - 2020-06-25: Regulation (EU) 2020/740 on tyre labelling in force, the twentieth day after publication in OJ L 177 of 5 June 2020; it amends Article 12(2)(a) so that the product database also supports surveillance of tyre labels - 2021-03-01: First rescaled A to G labels apply, in shops and online, for electronic displays, household washing machines and washer-dryers, household refrigerating appliances, household dishwashers and refrigerating appliances with a direct sales function; the 2010 delegated acts on televisions, washing machines, refrigerating appliances and dishwashers are repealed - 2021-05-01: Regulation (EU) 2020/740 applies: tyres carry their own label under that regulation and are registered in the product database; Regulation (EC) No 1222/2009 repealed - 2021-07-16: Regulation (EU) 2019/1020 on market surveillance applies; Chapter III of Regulation (EC) No 765/2008, which contains the Articles 16 to 29 that Article 8(1) applies to labelled products, is deleted, references to it are read as references to the new regulation, and Regulation (EU) 2017/1369 is listed in point 68 of its Annex I - 2021-09-01: Rescaled A to G label applies for light sources; Delegated Regulation (EU) No 874/2012 on lamps and luminaires repealed - 2023-08-02: Deadline for the Commission to adopt A to G rescaled labels for the remaining product groups labelled under Directive 2010/30/EU, other than the heaters in Article 11(5)(a); the deadline passed without those delegated acts, and in its implementation report of 24 June 2026 the Commission still lists the reviews of air conditioners, domestic ovens and range hoods, residential ventilation units, professional refrigerated storage cabinets and local space heaters as in preparation - 2024-04-22: Implementing Regulation (EU) 2024/994 on the operational details of the product database in force and applicable; its Articles 3, 4, 5, 7, 11 and 15 apply from 22 October 2024 - 2025-06-20: Energy label applies to smartphones and slate tablets under Delegated Regulation (EU) 2023/1669 - 2025-07-01: Rescaled label applies to household tumble dryers under Delegated Regulation (EU) 2023/2534, which repeals Delegated Regulation (EU) No 392/2012; the supplier's label and product information sheet duties in Article 3(1)(a) and (b) applied from 1 March 2025 - 2025-08-02: Deadline for the Commission's evaluation report on the regulation and for its reviews of the space heater, water heater and solid fuel boiler labels with a view to rescaling; the implementation report was published on 24 June 2026 and records that the reviews of space and combination heaters, water heaters and solid fuel boilers were still in preparation at that date - 2026-08-02: Deadline for the Commission, where appropriate, to adopt A to G rescaled labels for space heaters, water heaters and solid fuel boilers; the deadline passed without such a delegated act, and in any event the rescaled heater labels must be adopted no later than 2 August 2030 ## What you must do ### Supplier: manufacturer established in the Union - Ensure that every unit you place on the market is accompanied, free of charge, by an accurate printed label and a product information sheet in the form fixed by the delegated act for the product group; where the delegated act allows it, entering the sheet's parameters in EPREL replaces the paper sheet, which you then print for the dealer on request, and the label may be printed on the packaging. - Deliver printed labels, including rescaled labels, and product information sheets to dealers free of charge, promptly and in any event within five working days of the dealer's request. - Ensure the accuracy of the labels and product information sheets you provide and produce technical documentation sufficient for market surveillance authorities to assess that accuracy, including test reports or similar technical evidence. - Ensure the accuracy of the labels and product information sheets you provide. - Produce technical documentation sufficient for market surveillance authorities to assess the accuracy of the label and product information sheet, including test reports or similar technical evidence. - Register every new model covered by a delegated act in the public and compliance parts of EPREL before placing a unit on the market, entering the Annex I information: your identity and contact details, the model identifier, the label in electronic form, the energy class and label parameters, the product information sheet parameters, the identifiers of equivalent models and the specific parts of the technical documentation listed in Article 12(5). - Treat a product whose label-relevant characteristics change as a new model, indicate in EPREL when you no longer place units of a model on the market, and keep the model's information in the compliance part for 15 years after the final unit was placed on the market unless the delegated act sets a shorter period; public data is never deleted. - Treat a product whose label-relevant characteristics change as a new model and register it in EPREL as such. - Indicate in EPREL when you no longer place units of a model on the market. - Keep the model's information in the compliance part of EPREL for 15 years after the final unit was placed on the market, unless the delegated act sets a shorter period; public data is never deleted. - Do not place on the market products designed so that their performance is automatically altered under test conditions to reach a more favourable value for any label or documentation parameter, and once a unit is in service ask the customer's explicit consent before any update that would worsen a label parameter, explaining the change and offering the option to refuse it without avoidable loss of functionality. - Do not place on the market products designed so that their performance is automatically altered under test conditions to reach a more favourable value for any label or product information sheet parameter. - Once a unit is in service, ask the customer's explicit consent before any update that would worsen a label parameter, explaining the change and offering the option to refuse it without avoidable loss of functionality. - Reference the energy efficiency class and the range of classes on the label in every visual advertisement and technical promotional material for a specific model, as the delegated act prescribes, and do not provide or display other labels, marks, symbols or inscriptions that could mislead or confuse customers about energy or resource consumption. - When a label is rescaled, supply both the existing and the rescaled label and product information sheet with products placed on the market during the four months before the display date fixed in the delegated act, and deliver rescaled labels for earlier products on the dealer's request from the start of that period. - Cooperate with market surveillance authorities, take immediate action to remedy any non-compliance under your responsibility, on your own initiative or when required, extend corrective or restrictive action to all products concerned across the Union and to all units of the model and its equivalent models, and bear the cost of document inspection and testing where a product is found non-compliant. - Cooperate with market surveillance authorities on the products you supply. - Take immediate action to remedy any non-compliance under your responsibility, on your own initiative or when required, extend corrective or restrictive action to all products concerned across the Union and to all units of the model and its equivalent models, and bear the cost of document inspection and testing where a product is found non-compliant. ### Supplier: authorised representative of a non-EU manufacturer - As the authorised representative who places a non-EU manufacturer's product on the Union market you are the supplier: ensure each unit is accompanied by an accurate printed label and product information sheet free of charge and deliver them to dealers within five working days of a request. - As the authorised representative who places a non-EU manufacturer's product on the Union market, you are its supplier and carry the supplier obligations. - Ensure each unit is accompanied, free of charge, by an accurate printed label and product information sheet in the form the delegated act prescribes. - Deliver printed labels and product information sheets to dealers free of charge, promptly and in any event within five working days of a request. - Ensure the accuracy of the labels and sheets and hold technical documentation sufficient for the authorities to assess it, including test reports. - Ensure the accuracy of the labels and product information sheets you provide. - Hold technical documentation sufficient for market surveillance authorities to assess the accuracy of the label and product information sheet, including test reports. - Register every new model in EPREL before placing a unit on the market, keep the compliance data for 15 years after the final unit, and register any changed model as a new model. - Register every new model in EPREL before placing a unit on the market, and register any changed model as a new model. - Keep the model's compliance data in EPREL for 15 years after the final unit was placed on the market. - Show the energy class and class range in visual advertisements and technical promotional material, cooperate with market surveillance authorities and remedy non-compliance immediately. - Show the energy class and the range of classes in visual advertisements and technical promotional material for a specific model. - Cooperate with market surveillance authorities on the products you supply. - Take immediate action to remedy any non-compliance under your responsibility. - Make the technical documentation available electronically within 10 days of a request for models placed on the market under Directive 2010/30/EU before 1 August 2017, for five years after the final unit was manufactured. ### Supplier: importer - As the importer who places a product from a third country on the Union market you are the supplier: ensure each unit is accompanied, free of charge, by an accurate printed label and product information sheet in the form the delegated act prescribes, and deliver them to dealers within five working days of a request. - As the importer who places a product from a third country on the Union market, you are its supplier and carry the supplier obligations. - Ensure each unit is accompanied, free of charge, by an accurate printed label and product information sheet in the form the delegated act prescribes. - Deliver printed labels and product information sheets to dealers free of charge, promptly and in any event within five working days of a request. - Ensure the accuracy of the labels and sheets and hold technical documentation sufficient for the authorities to assess it, including test reports; this applies also to second-hand products you import from a third country. - Ensure the accuracy of the labels and product information sheets you provide, also for second-hand products you import from a third country. - Hold technical documentation sufficient for market surveillance authorities to assess the accuracy of the label and product information sheet, including test reports. - Register every new model covered by a delegated act in the public and compliance parts of EPREL before placing a unit on the market, treat a changed model as a new model, mark the end of marketing in the database and keep the compliance data for 15 years after the final unit. - Register every new model covered by a delegated act in the public and compliance parts of EPREL before placing a unit on the market, with the Annex I information, and treat a changed model as a new model. - Indicate in EPREL when you no longer place units of a model on the market. - Keep the model's compliance data in EPREL for 15 years after the final unit was placed on the market. - Do not import products with defeat mechanisms that alter performance under test conditions, and seek the customer's consent before updates that worsen a label parameter. - Do not import products with defeat mechanisms that alter their performance under test conditions to reach a more favourable label value. - Seek the customer's explicit consent before any update to a unit in service that would worsen a label parameter. - Show the energy class and the range of classes in visual advertisements and technical promotional material for a specific model, and do not display other labels or symbols likely to mislead customers about energy consumption. - When a label is rescaled, supply both labels with products placed on the market in the four months before the display date and rescaled labels for earlier products on request; cooperate with the authorities, remedy non-compliance immediately across all units of the model and its equivalent models, and bear inspection and testing costs where the product is non-compliant. - When a label is rescaled, supply both the existing and the rescaled label with products placed on the market in the four months before the display date, and rescaled labels for earlier products on request. - Cooperate with market surveillance authorities on the products you supply. - Take immediate action to remedy any non-compliance under your responsibility across all units of the model and its equivalent models, and bear the cost of document inspection and testing where the product is found non-compliant. ### Dealer (retailer, online shop, wholesaler displaying to installers) - Display the label provided by the supplier in a visible manner for every unit of a model covered by a delegated act, in the shop and in online distance selling, in the position and form the delegated act prescribes. - Make the product information sheet available to customers, including in physical form at the point of sale on request. - If you have no label or sheet for a product, request them from the supplier, who must deliver within five working days; the sheet may instead be printed or downloaded from EPREL where that function is available. - Reference the energy efficiency class and the range of classes in every visual advertisement and technical promotional material for a specific model, and do not display other labels, marks or symbols likely to mislead customers, nor labels that mimic the EU label on products without a delegated act or on non-energy-related products. - When a label is rescaled, replace the existing labels on products on display, in shops and online, with the rescaled labels within 14 working days after the date fixed in the delegated act, and do not display the rescaled label before that date; obtain rescaled labels for earlier stock from the supplier, and where the supplier has ceased activities you may sell that stock with the old label for up to nine months. - For packages of space heaters, water heaters or solid fuel boilers that you assemble with controls or solar devices, provide the package label yourself; the supplier's EPREL duty does not cover such packages. - Cooperate with market surveillance authorities, take immediate action to remedy non-compliance under your responsibility, and where required take corrective or restrictive action, including withdrawal, for all the products concerned that you have made available in the Union. - Cooperate with market surveillance authorities on the products you make available. - Take immediate action to remedy any non-compliance under your responsibility and, where required, take corrective or restrictive action, including withdrawal, for all the products concerned that you have made available in the Union. ## Requirements Each duty above as an identified requirement (47); ids are permanent and shared with the compliance engine. ### evidence - `elr-mfr-deliver-printed-labels` (Supplier: manufacturer established in the Union, product, on-event) — Deliver printed labels, including rescaled labels, and product information sheets to dealers free of charge, promptly and in any event within five working days of the dealer's request. [Art. 3(2) and Art. 11(13)] - `elr-mfr-ensure-label-accuracy` (Supplier: manufacturer established in the Union, product, before-market) — Ensure the accuracy of the labels and product information sheets you provide. [Art. 3(3)] - `elr-mfr-draw-technical-documentation` (Supplier: manufacturer established in the Union, product, before-market) — Produce technical documentation sufficient for market surveillance authorities to assess the accuracy of the label and product information sheet, including test reports or similar technical evidence. [Art. 3(3) and Art. 2, point (23)] - `elr-mfr-avoid-defeat-mechanisms` (Supplier: manufacturer established in the Union, product, before-market) — Do not place on the market products designed so that their performance is automatically altered under test conditions to reach a more favourable value for any label or product information sheet parameter. [Art. 3(5)] - `elr-oth-deliver-labels-dealers` (Supplier: authorised representative of a non-EU manufacturer, product, on-event) — Deliver printed labels and product information sheets to dealers free of charge, promptly and in any event within five working days of a request. [Art. 3(2)] - `elr-oth-ensure-label-accuracy` (Supplier: authorised representative of a non-EU manufacturer, product, before-market) — Ensure the accuracy of the labels and product information sheets you provide. [Art. 3(3)] - `elr-oth-draw-technical-documentation` (Supplier: authorised representative of a non-EU manufacturer, product, before-market) — Hold technical documentation sufficient for market surveillance authorities to assess the accuracy of the label and product information sheet, including test reports. [Art. 3(3)] - `elr-imp-deliver-labels-dealers` (Supplier: importer, product, on-event) — Deliver printed labels and product information sheets to dealers free of charge, promptly and in any event within five working days of a request. [Art. 3(2)] - `elr-imp-ensure-label-accuracy` (Supplier: importer, product, before-market) — Ensure the accuracy of the labels and product information sheets you provide, also for second-hand products you import from a third country. [Art. 1(2)(a) and Art. 3(3)] - `elr-imp-draw-technical-documentation` (Supplier: importer, product, before-market) — Hold technical documentation sufficient for market surveillance authorities to assess the accuracy of the label and product information sheet, including test reports. [Art. 3(3)] ### data - `elr-mfr-reference-energy-efficiency` (Supplier: manufacturer established in the Union, product-market, at-listing) — Reference the energy efficiency class and the range of classes on the label in every visual advertisement and technical promotional material for a specific model, as the delegated act prescribes, and do not provide or display other labels, marks, symbols or inscriptions that could mislead or confuse customers about energy or resource consumption. [Art. 6(a) and Art. 6(c)] - `elr-oth-reference-energy-class` (Supplier: authorised representative of a non-EU manufacturer, product-market, at-listing) — Show the energy class and the range of classes in visual advertisements and technical promotional material for a specific model. [Art. 6(a)] - `elr-imp-show-energy-class` (Supplier: importer, product-market, at-listing) — Show the energy class and the range of classes in visual advertisements and technical promotional material for a specific model, and do not display other labels or symbols likely to mislead customers about energy consumption. [Art. 6(a) and Art. 6(c)] - `elr-dist-make-product-information` (Dealer (retailer, online shop, wholesaler displaying to installers), product-market, at-listing) — Make the product information sheet available to customers, including in physical form at the point of sale on request. [Art. 5(1)(b)] - `elr-dist-reference-energy-efficiency` (Dealer (retailer, online shop, wholesaler displaying to installers), product-market, at-listing) — Reference the energy efficiency class and the range of classes in every visual advertisement and technical promotional material for a specific model, and do not display other labels, marks or symbols likely to mislead customers, nor labels that mimic the EU label on products without a delegated act or on non-energy-related products. [Art. 6(a), Art. 6(c), Art. 6(d) and Art. 6(e)] ### mark - `elr-mfr-ensure-unit-place` (Supplier: manufacturer established in the Union, product, before-market) — Ensure that every unit you place on the market is accompanied, free of charge, by an accurate printed label and a product information sheet in the form fixed by the delegated act for the product group; where the delegated act allows it, entering the sheet's parameters in EPREL replaces the paper sheet, which you then print for the dealer on request, and the label may be printed on the packaging. [Art. 3(1)] - `elr-mfr-supply-existing-rescaled` (Supplier: manufacturer established in the Union, product, on-event) — When a label is rescaled, supply both the existing and the rescaled label and product information sheet with products placed on the market during the four months before the display date fixed in the delegated act, and deliver rescaled labels for earlier products on the dealer's request from the start of that period. [Art. 11(13)(a) and Art. 11(13)(b)] - `elr-oth-accompany-label-sheet` (Supplier: authorised representative of a non-EU manufacturer, product, before-market) — Ensure each unit is accompanied, free of charge, by an accurate printed label and product information sheet in the form the delegated act prescribes. [Art. 3(1)] - `elr-imp-accompany-label-sheet` (Supplier: importer, product, before-market) — Ensure each unit is accompanied, free of charge, by an accurate printed label and product information sheet in the form the delegated act prescribes. [Art. 3(1)] - `elr-imp-supply-rescaled-labels` (Supplier: importer, product, on-event) — When a label is rescaled, supply both the existing and the rescaled label with products placed on the market in the four months before the display date, and rescaled labels for earlier products on request. [Art. 11(13)] - `elr-dist-display-label-provided` (Dealer (retailer, online shop, wholesaler displaying to installers), product-market, at-listing) — Display the label provided by the supplier in a visible manner for every unit of a model covered by a delegated act, in the shop and in online distance selling, in the position and form the delegated act prescribes. [Art. 5(1)(a) and Art. 16(3)(e) and (g)] - `elr-dist-replace-existing-labels` (Dealer (retailer, online shop, wholesaler displaying to installers), product-market, on-event) — When a label is rescaled, replace the existing labels on products on display, in shops and online, with the rescaled labels within 14 working days after the date fixed in the delegated act, and do not display the rescaled label before that date; obtain rescaled labels for earlier stock from the supplier, and where the supplier has ceased activities you may sell that stock with the old label for up to nine months. [Art. 11(13)(b) and Art. 11(13)(c)] - `elr-dist-water-heaters-solid` (Dealer (retailer, online shop, wholesaler displaying to installers), product, before-market) — For packages of space heaters, water heaters or solid fuel boilers that you assemble with controls or solar devices, provide the package label yourself; the supplier's EPREL duty does not cover such packages. [Art. 4(5)] ### procedure - `elr-mfr-seek-consent-updates` (Supplier: manufacturer established in the Union, product, on-event) — Once a unit is in service, ask the customer's explicit consent before any update that would worsen a label parameter, explaining the change and offering the option to refuse it without avoidable loss of functionality. [Art. 3(4)] - `elr-imp-seek-consent-updates` (Supplier: importer, product, on-event) — Seek the customer's explicit consent before any update to a unit in service that would worsen a label parameter. [Art. 3(4)] - `elr-dist-request-them-supplier` (Dealer (retailer, online shop, wholesaler displaying to installers), product, on-event) — If you have no label or sheet for a product, request them from the supplier, who must deliver within five working days; the sheet may instead be printed or downloaded from EPREL where that function is available. [Art. 5(2), Art. 5(3) and Art. 3(2)] ### submission - `elr-mfr-register-new-model` (Supplier: manufacturer established in the Union, product, before-market) — Register every new model covered by a delegated act in the public and compliance parts of EPREL before placing a unit on the market, entering the Annex I information: your identity and contact details, the model identifier, the label in electronic form, the energy class and label parameters, the product information sheet parameters, the identifiers of equivalent models and the specific parts of the technical documentation listed in Article 12(5). [Art. 4(1), Art. 12(5) and Annex I, points 1 and 3] - `elr-mfr-register-changed-model` (Supplier: manufacturer established in the Union, product, on-event) — Treat a product whose label-relevant characteristics change as a new model and register it in EPREL as such. [Art. 4(4)] - `elr-mfr-indicate-end-of-marketing` (Supplier: manufacturer established in the Union, product, on-event) — Indicate in EPREL when you no longer place units of a model on the market. [Art. 4(4)] - `elr-mfr-remedy-non-compliance` (Supplier: manufacturer established in the Union, product, on-event) — Take immediate action to remedy any non-compliance under your responsibility, on your own initiative or when required, extend corrective or restrictive action to all products concerned across the Union and to all units of the model and its equivalent models, and bear the cost of document inspection and testing where a product is found non-compliant. [Art. 6(b), Art. 8(5), Art. 9(2), Art. 9(4) and Art. 10(5)] - `elr-oth-register-model-eprel` (Supplier: authorised representative of a non-EU manufacturer, product, before-market) — Register every new model in EPREL before placing a unit on the market, and register any changed model as a new model. [Art. 4(1) and Art. 4(4)] - `elr-oth-remedy-non-compliance` (Supplier: authorised representative of a non-EU manufacturer, product, on-event) — Take immediate action to remedy any non-compliance under your responsibility. [Art. 6(b)] - `elr-imp-register-model-eprel` (Supplier: importer, product, before-market) — Register every new model covered by a delegated act in the public and compliance parts of EPREL before placing a unit on the market, with the Annex I information, and treat a changed model as a new model. [Art. 4(1), Art. 4(4) and Annex I] - `elr-imp-indicate-end-of-marketing` (Supplier: importer, product, on-event) — Indicate in EPREL when you no longer place units of a model on the market. [Art. 4(4)] - `elr-imp-remedy-non-compliance` (Supplier: importer, product, on-event) — Take immediate action to remedy any non-compliance under your responsibility across all units of the model and its equivalent models, and bear the cost of document inspection and testing where the product is found non-compliant. [Art. 6(b), Art. 8(5), Art. 9(2) and Art. 10(5)] - `elr-dist-remedy-non-compliance` (Dealer (retailer, online shop, wholesaler displaying to installers), product, on-event) — Take immediate action to remedy any non-compliance under your responsibility and, where required, take corrective or restrictive action, including withdrawal, for all the products concerned that you have made available in the Union. [Art. 6(b), Art. 9(2) and Art. 9(4)] ### verification - `elr-imp-avoid-defeat-mechanisms` (Supplier: importer, product, before-market) — Do not import products with defeat mechanisms that alter their performance under test conditions to reach a more favourable label value. [Art. 3(5)] ### standing - `elr-mfr-keep-compliance-data` (Supplier: manufacturer established in the Union, product, ongoing) — Keep the model's information in the compliance part of EPREL for 15 years after the final unit was placed on the market, unless the delegated act sets a shorter period; public data is never deleted. [Art. 4(6)] - `elr-mfr-cooperate-authorities` (Supplier: manufacturer established in the Union, company, ongoing) — Cooperate with market surveillance authorities on the products you supply. [Art. 6(b)] - `elr-oth-keep-compliance-data` (Supplier: authorised representative of a non-EU manufacturer, product, ongoing) — Keep the model's compliance data in EPREL for 15 years after the final unit was placed on the market. [Art. 4(6)] - `elr-oth-cooperate-authorities` (Supplier: authorised representative of a non-EU manufacturer, company, ongoing) — Cooperate with market surveillance authorities on the products you supply. [Art. 6(b)] - `elr-oth-make-technical-documentation` (Supplier: authorised representative of a non-EU manufacturer, product, ongoing) — Make the technical documentation available electronically within 10 days of a request for models placed on the market under Directive 2010/30/EU before 1 August 2017, for five years after the final unit was manufactured. [Art. 20(3)] - `elr-imp-keep-compliance-data` (Supplier: importer, product, ongoing) — Keep the model's compliance data in EPREL for 15 years after the final unit was placed on the market. [Art. 4(6)] - `elr-imp-cooperate-authorities` (Supplier: importer, company, ongoing) — Cooperate with market surveillance authorities on the products you supply. [Art. 6(b)] - `elr-dist-cooperate-authorities` (Dealer (retailer, online shop, wholesaler displaying to installers), company, ongoing) — Cooperate with market surveillance authorities on the products you make available. [Art. 6(b)] ## Penalties Member States lay down the rules on penalties and enforcement mechanisms for infringements of the regulation and its delegated acts and take all measures to implement them; the penalties must be effective, proportionate and dissuasive. Where an authority has sufficient reason to believe that a product presents a risk to the public interests the regulation protects, it evaluates the product against all relevant labelling requirements, requires the supplier or dealer to take corrective action, to withdraw or to recall it within a period commensurate with the risk, and if the operator does not act takes provisional measures to prohibit or restrict its availability, withdraw or recall it and informs the Commission and the other Member States; the measures extend to all units of the model and its equivalent models unless the supplier shows they comply, and the authority may recover the costs of document inspection and testing from the supplier. Market surveillance and border control follow Regulation (EU) 2019/1020, since the Articles 16 to 29 of Regulation (EC) No 765/2008 cited in Article 8 were deleted from 16 July 2021. In Denmark the produktenergimærkningsloven (lovbekendtgørelse nr. 186 of 2 February 2022) makes Erhvervsministeren or the authority it empowers the control authority, and executive order nr. 1322 of 9 June 2021 names Sikkerhedsstyrelsen, part of Erhvervsstyrelsen since January 2026, as that authority; it can order suppliers to carry out measurement and product testing at their own expense where the product fails, enter business premises and means of transport without a court order, issue påbud to bring the product into conformity, to stop misleading marketing, to withdraw or to recall it, forbud against placing it on the market or making it available, orders to owners of online interfaces to change or remove content or to display a warning and, by court order, blocking, and publish the results; its decisions may be appealed to Energiklagenævnet within four weeks. Failing the supplier duties under Articles 3, 4, 12(5) and 20(3), the dealer duties under Article 5 or the advertising duties under Article 6 is punishable by a fine, with companies liable under chapter 5 of the criminal code. ## Checklist 1. Confirm the product is energy-related under Article 2, point (1), and that no Article 1(2) exclusion applies (second-hand products already on the Union market, means of transport). 2. Identify the delegated regulation for the product group, for example 2019/2016 for refrigerating appliances, 2019/2014 for washing machines, 2019/2013 for displays, 2019/2015 for light sources, 2023/1669 for smartphones and tablets or 2023/2534 for tumble dryers, and note its display date and label design; tyres follow Regulation (EU) 2020/740. 3. Decide who is the supplier for each model: the EU manufacturer, the authorised representative of a non-EU manufacturer, or the importer (Article 2, point (14)); everyone else who sells or displays the product is a dealer. 4. Test or calculate the label parameters with the measurement methods of the delegated act and harmonised standards, and compile technical documentation sufficient to prove the label and sheet (Article 3(3) and Article 13). 5. Register the model in EPREL before the first unit is placed on the market, with the label, the product information sheet parameters, equivalent models and the Article 12(5) documentation; register any changed model as a new model and keep the data for 15 years (Article 4 and Annex I). 6. Supply each unit with the printed label and product information sheet, or use the EPREL sheet where the delegated act allows it, and answer dealer requests within five working days (Article 3(1) and 3(2)). 7. Display the label and the sheet in the shop and next to the price online, and put the energy class and class range in every visual advertisement and technical promotional material (Articles 5 and 6). 8. Plan each rescaling: double labels for the four months before the display date, dealers swap labels within 14 working days after it, and the old label never appears after the nine-month tail for stock from a supplier that has closed (Article 11(13)). 9. Check that no product carries mimic labels or misleading energy symbols, that firmware updates do not silently worsen label parameters, and that no test-detecting behaviour exists (Articles 3(4), 3(5) and 6(c) to (e)). ## Questions ### When did the Energy Labelling Framework Regulation start to apply? Regulation (EU) 2017/1369 was adopted on 4 July 2017, published in the Official Journal of 28 July 2017, entered into force on the fourth day after publication and applies from 1 August 2017, when it repealed Directive 2010/30/EU. Article 4 on the product database applies from 1 January 2019, and models placed on the market between 1 August 2017 and 1 January 2019 had to be registered by 30 June 2019. For models placed on the market under the directive before 1 August 2017, suppliers must still make the technical documentation available electronically within 10 days of a request, for five years after the final unit was manufactured. ### Which products must carry the EU energy label? Only energy-related products in a group covered by a delegated act: today refrigerating appliances, washing machines and washer-dryers, dishwashers, tumble dryers, electronic displays, light sources, smartphones and slate tablets, space and combination heaters, water heaters and storage tanks, solid fuel boilers, local space heaters, air conditioners, domestic ovens and range hoods, residential ventilation units, refrigerating appliances with a direct sales function and professional refrigerated storage cabinets. Second-hand products are outside the regulation unless imported from a third country, and means of transport are always outside it. Tyres carry a label under Regulation (EU) 2020/740 instead. ### Who is the supplier and who is the dealer? The supplier is the manufacturer established in the Union, the authorised representative of a manufacturer not established in the Union, or the importer, who places the product on the Union market. The dealer is a retailer or any other person who offers for sale, hire or hire purchase, or displays products to customers or installers in the course of a commercial activity, including online shops. Suppliers label, document and register; dealers display the label and the sheet and use them in advertising. ### What is EPREL and what must I register? EPREL is the product database the Commission runs under Article 12, with a public part, a compliance part reserved for market surveillance authorities and the Commission, and an online portal. Since 1 January 2019 the supplier must enter, before placing a new model on the market, its name and contact details, the model identifier, the label in electronic format, the energy class and label parameters and the product information sheet parameters in the public part, and in the compliance part the identifiers of equivalent models and the technical documentation parts of Article 12(5): a general description of the model, the standards applied, precautions for assembly and testing, the measured parameters, the calculations and the test conditions. Implementing Regulation (EU) 2024/994 sets the operational details, and tyres are registered there too. ### Why did the A+++ classes disappear and when does each product group switch? The regulation defines the label as a closed scale from A to G in seven colours and ordered the Commission to rescale the labels that existed on 1 August 2017, so that no product falls into class A when a new label is introduced and most models reach it only after at least 10 years. The first rescaled labels applied on 1 March 2021 to refrigerating appliances, washing machines and washer-dryers, dishwashers, electronic displays and refrigerating appliances with a direct sales function, on 1 September 2021 to light sources, on 20 June 2025 to smartphones and tablets and on 1 July 2025 to tumble dryers. Heaters follow later: the Commission was to review them by 2 August 2025 and adopt rescaled labels where appropriate by 2 August 2026, and in any event no later than 2 August 2030. Neither date was met. In its implementation report of 24 June 2026 the Commission lists the reviews of space and combination heaters, water heaters and solid fuel boilers, and those of air conditioners, domestic ovens and range hoods, residential ventilation units, professional refrigerated storage cabinets and local space heaters, as still in preparation, so all of those groups keep their existing labels until a rescaled delegated act applies. A label is reviewed again once the Commission estimates that 30 % of the units sold reach class A, or 50 % reach classes A and B, and further technological development can be expected. ### How must the label appear in online shops and advertising? Dealers must display the supplier's label in a visible manner including for online distance selling and make the product information sheet available; the delegated act for each group fixes how the label and sheet are shown in distance selling. Every visual advertisement and technical promotional material for a specific model, by supplier or dealer, must reference the energy efficiency class and the range of classes available on the label. Sikkerhedsstyrelsen checks Danish web shops exactly like physical shops, and its guidance accepts showing only the energy arrow if the full label opens on click or hover and the sheet is linked under the name Datablad. ### What happens during a rescaling for products already in stock? From four months before the display date fixed in the delegated act, the supplier delivers both the existing and the rescaled label with new units and, on request, rescaled labels for units placed on the market earlier. Dealers replace the labels on products on display, in shops and online, within 14 working days after the display date and must not show the rescaled label before it. If the supplier has ceased its activities, the dealer may sell the units in stock with the old label for up to nine months after the display date; where the two labels require different testing, the supplier may skip the rescaled label for units placed on the market before the four-month period if no further units of that model are placed on the market afterwards, and the dealer sells them with the old label within the same nine months. ### Who enforces energy labelling in Denmark and what are the sanctions? Since 1 August 2018 Sikkerhedsstyrelsen has carried out the market surveillance of ecodesign and energy labelling for Energistyrelsen, and since January 2026 it is part of Erhvervsstyrelsen; Energistyrelsen keeps the overall responsibility for developing and interpreting the rules and is the Danish authority responsible for the EPREL database. The legal basis is the produktenergimærkningsloven, lovbekendtgørelse nr. 186 of 2 February 2022, and executive order nr. 1322 of 9 June 2021 on control of energy labelling. The authority inspects shops and web shops, checks supplier documentation and tests products at accredited laboratories; non-compliance leads to a hearing, a påbud with a follow-up unannounced visit, forbud, orders to online interfaces, publication of results and, where a påbud is ignored, police report and fines under § 12 of the act. Decisions of the control authority may be appealed to Energiklagenævnet within four weeks. ## What changed - 2026-09-12 (guidance): **Guide rebuilt from the consolidated text and the delegated regulations** — The body was rewritten from the consolidated text of 1 May 2021, Regulation (EU) 2020/740, Regulation (EU) 2019/1020, Implementing Regulation (EU) 2024/994 and the product-specific delegated regulations. Corrections to the previous text: the regulation entered into force on 1 August 2017 (not 2017 in general), the EPREL duty dates from 1 January 2019 with a 30 June 2019 catch-up deadline, the Danish market surveillance authority is Sikkerhedsstyrelsen (now Erhvervsstyrelsen, Markedsovervågning) acting for Energistyrelsen since 1 August 2018, and the rescaling rules, dates per product group and the tyre exception are now stated with their articles. - 2026-06-24 (guidance): **Commission proposes to amend the regulation: simplification and digital labelling** — Together with its implementation report the Commission adopted COM(2026) 565, a proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2017/1369 and Regulation (EU) 2020/740 as regards simplification and better use of digital options for energy and tyre labelling. The proposal is not yet law: the framework, the label duties and the EPREL registration duty are unchanged until the co-legislators adopt it. - 2026-06-24 (guidance): **Commission report on the implementation of the regulation** — The Commission published its report to the European Parliament and the Council on the implementation of Regulation (EU) 2017/1369, the evaluation required by Article 19 by 2 August 2025. - 2025-07-01 (applies): **Rescaled label applies to household tumble dryers** — Delegated Regulation (EU) 2023/2534, in force since 1 January 2024 and amended by Delegated Regulation (EU) 2025/1353 on repairability information, applies to electric and gas-fired household tumble dryers and repeals Delegated Regulation (EU) No 392/2012; the supplier's label and sheet duties applied from 1 March 2025. - 2025-06-20 (applies): **Energy label applies to smartphones and slate tablets** — Delegated Regulation (EU) 2023/1669 of 16 June 2023 applies: smartphones and slate tablets carry an energy label and supplementary product information, with the exception of mobile phones and tablets with a flexible main display that the user can unroll and roll up, and of smartphones for high security communication. - 2024-04-22 (applies): **Implementing Regulation (EU) 2024/994 on EPREL operational details** — The implementing regulation of 2 April 2024 sets the operational details of the product database and the rules for suppliers placing energy-related products and tyres on the Union market; its Articles 3, 4, 5, 7, 11 and 15 apply from 22 October 2024. - 2021-09-01 (applies): **Rescaled label applies to light sources** — Delegated Regulation (EU) 2019/2015 applies to light sources with or without integrated control gear, including light sources placed on the market in a containing product, and repeals Delegated Regulation (EU) No 874/2012. - 2021-07-16 (applies): **Regulation (EU) 2019/1020 takes over market surveillance** — Chapter III of Regulation (EC) No 765/2008, containing Articles 15 to 29 and with them the Articles 16 to 29 that Article 8(1) of the energy labelling regulation applies to labelled products, is deleted, and references to it are read as references to Regulation (EU) 2019/1020, whose Annex I lists Regulation (EU) 2017/1369 as point 68. - 2021-05-01 (applies): **Tyre labelling regulation applies; tyres enter the product database** — Regulation (EU) 2020/740 applies to C1, C2 and C3 tyres and repeals Regulation (EC) No 1222/2009; from this date the amended Article 12(2)(a) lets the product database support the surveillance of tyre labels. - 2021-03-01 (applies): **First rescaled A to G labels in shops and online** — The delegated regulations of 11 March 2019 on electronic displays, household washing machines and washer-dryers, household refrigerating appliances, household dishwashers and refrigerating appliances with a direct sales function apply; the 2010 delegated acts on televisions, washing machines, refrigerating appliances and dishwashers and Directive 96/60/EC are repealed. - 2020-06-25 (amendment): **Regulation (EU) 2020/740 in force: product database extended to tyres** — The tyre labelling regulation of 25 May 2020, published in OJ L 177 on 5 June 2020, replaced Article 12(2), point (a), so that the product database also supports market surveillance under Regulation (EU) 2020/740; it applies from 1 May 2021. - 2019-01-01 (applies): **EPREL registration duty applies** — Article 4 applies: suppliers register every new model covered by a delegated act in the public and compliance parts of the product database before placing a unit on the market, and models placed on the market between 1 August 2017 and 1 January 2019 must be registered by 30 June 2019. - 2017-08-01 (in-force): **Regulation (EU) 2017/1369 enters into force and applies** — Adopted on 4 July 2017 and published in OJ L 198 on 28 July 2017, the regulation entered into force on the fourth day after publication and applies from the same date; Directive 2010/30/EU is repealed, while the delegated acts adopted under it remain in force until replaced. ## ELR in plain terms The Energy Labelling Framework Regulation (ELR), formally Regulation (EU) 2017/1369, is the EU law behind the A to G energy label. It lays down a framework for energy-related products placed on the market or put into service, providing for their labelling and for standard product information on energy efficiency, on the consumption of energy and other resources during use and on supplementary characteristics, so that customers can choose more efficient products (Art. 1(1)). The framework itself fixes the roles, the label concept, the product database and the enforcement machinery; the product groups, the label designs, the measurement methods and the display rules are set in a separate delegated regulation for each group (Art. 16). As a regulation it applies directly in every Member State. It entered into force on 1 August 2017, the fourth day after publication, and applies from that date, when it repealed Directive 2010/30/EU; the supplier duties for the product database apply from 1 January 2019 (Art. 20(1) and Art. 21). Delegated acts adopted under the old directive stay in force, with the obligations of the new regulation, until a delegated act under Article 16 replaces them (Art. 20(4)). > **Official text** > Read the regulation on EUR-Lex: [Regulation (EU) 2017/1369 (CELEX 32017R1369)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R1369), or the [consolidated text of 1 May 2021](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R1369-20210501) that includes the tyre amendment to Article 12(2). ## Scope An energy-related product is a good or system with an impact on energy consumption during use which is placed on the market or put into service, including parts with such an impact that are placed on the market for customers and intended to be incorporated into products (Art. 2, point (1)). The regulation does not apply to second-hand products, unless they are imported from a third country, nor to means of transport for persons or goods (Art. 1(2)). The label, sheet and database duties bite only where a delegated act covers the product group. The groups with an energy labelling act today are refrigerating appliances, washing machines and washer-dryers, dishwashers, tumble dryers, electronic displays including televisions, monitors and digital signage, light sources, smartphones and slate tablets, space and combination heaters, water heaters and hot water storage tanks, solid fuel boilers, local space heaters, air conditioners, domestic ovens and range hoods, residential ventilation units, refrigerating appliances with a direct sales function and professional refrigerated storage cabinets (Commission product list; Delegated Regulations (EU) 2019/2013 to 2019/2018, 2023/1669, 2023/2534, No 811/2013, No 812/2013, 2015/1186, 2015/1187, No 626/2011, No 65/2014, No 1254/2014 and 2015/1094, each Art. 1). Tyres are labelled under Regulation (EU) 2020/740 but registered in the same product database (Art. 12(2)(a) as amended). For a product group without a delegated act there is no label, but no label mimicking the EU label may be supplied or displayed (Art. 6(d)); the Commission selects new groups by their saving potential and lists them in its working plan (Art. 15 and Art. 16(2)). Two roles carry the duties. The supplier is a manufacturer established in the Union, the authorised representative of a manufacturer who is not established in the Union, or an importer, who places a product on the Union market (Art. 2, point (14)). The dealer is a retailer or other natural or legal person who offers for sale, hire or hire purchase, or displays products to customers or installers in the course of a commercial activity, whether or not in return for payment (Art. 2, point (13)). Distance selling covers mail order, catalogue, internet, telemarketing or any other method by which the potential customer cannot be expected to see the product displayed (Art. 2, point (15)). ## What you must do ### The label and the product information sheet The label is a graphic diagram, printed or electronic, with a closed scale using only the letters A to G, each letter a class, in seven colours from dark green to red (Art. 2, point (19)). The supplier ensures that every unit placed on the market is accompanied, free of charge, by an accurate printed label and a product information sheet as the delegated act prescribes; the delegated act may allow the sheet's parameters to be entered in the product database instead, in which case the supplier prints the sheet for the dealer on request, and may allow the label to be printed on the packaging (Art. 3(1)). Dealers who lack a label or sheet request them from the supplier, who delivers within five working days, and may download the sheet from the database where that function exists (Art. 3(2), Art. 5(2) and Art. 5(3)). The supplier must ensure the accuracy of the labels and sheets and produce technical documentation sufficient to enable that accuracy to be assessed, including test reports or similar technical evidence (Art. 3(3) and Art. 2, point (23)). Products may not be designed so that their performance is automatically altered under test conditions to reach a more favourable value, and once a unit is in service the supplier needs the customer's explicit consent for any update that would worsen a label parameter, must explain the change and must let the customer refuse it without avoidable loss of functionality (Art. 3(4) and Art. 3(5)). Harmonised standards published in the Official Journal give a presumption of conformity with the measurement and calculation requirements of the delegated act (Art. 13). ### EPREL, the product database The Commission establishes and maintains a product database with a public part, a compliance part and an online portal; the database does not replace the responsibilities of the market surveillance authorities (Art. 12(1)). Since 1 January 2019 the supplier must enter, before placing a unit of a new model on the market, the Annex I information: in the public part its name or trademark, address and contact details, the model identifier, the label in electronic format, the energy class and other label parameters and the parameters of the product information sheet; in the compliance part the model identifiers of all equivalent models already placed on the market and the specific parts of the technical documentation listed in Article 12(5), namely a general description of the model, the standards applied, precautions for assembly, installation, maintenance or testing, the measured technical parameters, the calculations performed with them and the testing conditions (Art. 4(1), Art. 12(4), Art. 12(5) and Annex I). Models placed on the market between 1 August 2017 and 1 January 2019 had to be registered by 30 June 2019 (Art. 4(2)). A product whose label-relevant characteristics change is a new model; the supplier indicates in the database when it no longer places units of a model on the market, keeps the compliance data for 15 years after the final unit unless the delegated act sets a shorter period, and the public data is never deleted (Art. 4(4) and Art. 4(6)). The compliance part is accessible only to market surveillance authorities and the Commission (Art. 12(4)), and the supplier keeps access and editing rights to its own entries, with a record of changes (Art. 12(10)). Heater packages under Delegated Regulations (EU) No 811/2013, No 812/2013 and 2015/1187, whose label is the dealer's sole responsibility, are exempt from the registration duty (Art. 4(5)). Implementing Regulation (EU) 2024/994 sets the operational details of the database for energy-related products and for tyres (its Art. 1). ### Display and advertising The dealer displays the supplier's label in a visible manner, including for online distance selling, for every unit of a covered model, and makes the product information sheet available to customers, including in physical form at the point of sale on request (Art. 5(1)). Both supplier and dealer must reference the energy efficiency class and the range of classes available on the label in visual advertisements and technical promotional material for a specific model, as the delegated act prescribes (Art. 6(a)); the delegated acts also fix where the label is shown, how it is provided in distance selling and how the class appears in advertising (Art. 16(3)(e), (g) and (j)). Neither may provide or display other labels, marks, symbols or inscriptions that would be likely to mislead or confuse customers about energy or resource consumption, nor mimic labels on products without a delegated act or on non-energy-related products (Art. 6(c) to (e)). ### Rescaling: from A+++ back to A to G The Commission had to rescale the labels in force on 1 August 2017, so that a homogenous A to G scale returns (Art. 11(1) and Art. 11(4)). When a label is introduced or rescaled, no products are expected to fall into class A at that moment, and the time within which a majority of models reaches that class must be at least 10 years, or classes A and B stay empty where technology moves faster (Art. 11(8) and Art. 11(9)). The rescaled labels for dishwashers, refrigerating appliances, washing machines, washer-dryers, televisions and lamps had to be adopted by 2 November 2018 and displayed 12 months after entry into force (Art. 11(5)(b)); the six delegated regulations of 11 March 2019 apply from 1 March 2021, light sources from 1 September 2021 (Delegated Regulations (EU) 2019/2013, 2019/2014, 2019/2016, 2019/2017 and 2019/2018, each Art. 11 or Art. 9; 2019/2015, Art. 10). The other groups labelled under the directive were to be rescaled by 2 August 2023 with display 18 months after entry into force (Art. 11(4)); smartphones and tablets received a label from 20 June 2025 and tumble dryers from 1 July 2025 (Delegated Regulation (EU) 2023/1669, Art. 8; 2023/2534, Art. 10). Space heaters, water heaters and solid fuel boilers were to be reviewed by 2 August 2025 with rescaled labels adopted where appropriate by 2 August 2026, and in any event no later than 2 August 2030 (Art. 11(5)(a)). Neither the 2023 deadline nor the heater deadlines were met: in its implementation report of 24 June 2026 the Commission lists the reviews of air conditioners, domestic ovens and range hoods, residential ventilation units, professional refrigerated storage cabinets, local space heaters, space and combination heaters, water heaters and solid fuel boilers as still in preparation, so those groups keep their existing labels until a rescaled delegated act applies (COM(2026) 319, section 2). A label is reviewed again once the Commission estimates that 30 % of the units sold fall into class A, or 50 % into classes A and B, and further technological development can be expected (Art. 11(6)). Where an ecodesign measure bans classes E, F or G, those classes are shown in grey (Art. 11(10)). During a rescaling the supplier provides both the existing and the rescaled label and sheet with products placed on the market during the four months before the display date fixed in the delegated act, and delivers rescaled labels for earlier products on request from the start of that period; the dealer replaces the labels on display, in shops and online, within 14 working days after the display date and never shows the rescaled label before it (Art. 11(13)(a) to (c)). A dealer who cannot obtain a rescaled label because the supplier has ceased its activities may sell that stock with the old label for up to nine months after the display date, and where the two labels require different testing the supplier may skip the rescaled label for units placed on the market before the four-month period if no further units of that model follow, again with a nine-month sell-off (Art. 11(13)(b)(i) and (ii)). ### Obligations by role Suppliers, whether EU manufacturer, authorised representative or importer, carry the label, sheet, accuracy, documentation, database, update-consent, anti-circumvention and advertising duties (Art. 3, Art. 4 and Art. 6). Dealers display the label and sheet, request missing ones, swap labels on rescaling, label heater packages they assemble and follow the advertising rules (Art. 4(5), Art. 5, Art. 6 and Art. 11(13)). Both cooperate with the authorities and remedy non-compliance immediately, on their own initiative or when required (Art. 6(b)). ## Enforcement and penalties Article 8 applies Articles 16 to 29 of Regulation (EC) No 765/2008 to covered products; those articles were deleted by Regulation (EU) 2019/1020 from 16 July 2021 and are read as references to that regulation, which lists Regulation (EU) 2017/1369 in its Annex I (Regulation (EU) 2019/1020, Art. 39, Art. 44 and Annex I, point 68). Market surveillance authorities may recover from the supplier the costs of document inspection and physical testing where a product is non-compliant (Art. 8(5)). Where an authority has sufficient reason to believe that a product presents a risk to the public interests the regulation protects, it evaluates the product, requires the supplier or dealer to take corrective action, to withdraw or to recall it within a period commensurate with the risk, and if the operator does not act takes provisional measures to prohibit or restrict its availability, withdraw or recall it and informs the Commission and the other Member States, whose objections are settled through the Union safeguard procedure (Art. 9 and Art. 10). The measures extend to all units of the non-compliant model and its equivalent models unless the supplier shows they comply (Art. 10(5)). Penalties are national: Member States lay down effective, proportionate and dissuasive penalties and enforcement mechanisms (Art. 7(4)). In Denmark the produktenergimærkningsloven (lovbekendtgørelse nr. 186 of 2 February 2022) supplements the regulation and Regulation (EU) 2019/1020, makes Erhvervsministeren or the authority it empowers the control authority, lets it require suppliers to test products at their own expense where they fail, enter business premises without a court order, issue påbud to bring the product into conformity, to stop misleading marketing, to withdraw or recall it, forbud against placing it on the market, orders to owners of online interfaces to change or remove content and, by court order, blocking, and publish the results; failing the supplier duties in Articles 3, 4 and 12(5), the dealer duties in Article 5 or the advertising duties in Article 6 is punishable by a fine (§ 2, § 3, § 4, § 5, § 5 b, § 5 c, § 8 and § 12). Executive order nr. 1322 of 9 June 2021 names Sikkerhedsstyrelsen as the control authority (§ 2); Sikkerhedsstyrelsen has carried out the market surveillance of ecodesign and energy labelling for Energistyrelsen since 1 August 2018, inspects shops and web shops, checks supplier documentation and tests products at accredited laboratories, and has been part of Erhvervsstyrelsen since January 2026, while Energistyrelsen keeps the overall responsibility for developing and interpreting the rules and is the Danish authority responsible for the EPREL database. Decisions of the control authority may be appealed to Energiklagenævnet within four weeks (§ 11 of the act; § 7 of the executive order). ## How Conphora helps Conphora monitors ELR and every delegated regulation adopted under it and maps your products against the label, product information sheet, technical documentation and EPREL requirements of their group, flagging gaps before a shop inspection or a document check finds them. The platform keeps the registered data and the documentation together per model, and alerts you when a delegated act is adopted, a rescaling display date approaches or the Commission's working plan reaches your product group. [See how Conphora works](/how-it-works) · [See plans and pricing](/pricing) ## Sources - [Regulation (EU) 2017/1369 setting a framework for energy labelling, consolidated text of 1 May 2021 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R1369-20210501) - [Regulation (EU) 2017/1369 as published in OJ L 198, 28 July 2017 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R1369) - [Regulation (EU) 2020/740 on the labelling of tyres, amending Regulation (EU) 2017/1369 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0740) - [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020) - [Commission Implementing Regulation (EU) 2024/994 on the operational details of EPREL (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R0994) - [Commission Delegated Regulation (EU) 2019/2013 on electronic displays (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2013) - [Commission Delegated Regulation (EU) 2019/2014 on washing machines and washer-dryers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2014) - [Commission Delegated Regulation (EU) 2019/2015 on light sources (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2015) - [Commission Delegated Regulation (EU) 2019/2016 on refrigerating appliances (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2016) - [Commission Delegated Regulation (EU) 2019/2017 on dishwashers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2017) - [Commission Delegated Regulation (EU) 2019/2018 on refrigerating appliances with a direct sales function (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2018) - [Commission Delegated Regulation (EU) 2023/1669 on smartphones and slate tablets (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1669) - [Commission Delegated Regulation (EU) 2023/2534 on household tumble dryers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2534) - [Report from the Commission on the implementation of Regulation (EU) 2017/1369, COM(2026) 319 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026DC0319) - [Understanding the energy label (European Commission)](https://energy-efficient-products.ec.europa.eu/ecodesign-and-energy-label/understanding-energy-label_en) - [Product list under Directive 2009/125/EC and Regulation (EU) 2017/1369 (European Commission)](https://energy-efficient-products.ec.europa.eu/product-list_en) - [EPREL, the European Product Registry for Energy Labelling (European Commission)](https://energy-efficient-products.ec.europa.eu/eprel_en) - [Kontrol og tilsyn: ecodesign og energimærkning (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/eco-design-og-energimaerkning/kontrol-og-tilsyn-ecodesign-og-energimaerkning) - [Sådan foregår kontrol med energimærkning (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/eco-design-og-energimaerkning/saadan-foregaar-kontrol-energimaerkning) - [Produktenergimærkningsloven, lovbekendtgørelse nr. 186 af 2. februar 2022 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2022/186) - [Bekendtgørelse nr. 1322 af 9. juni 2021 om kontrol af energimærkning af energirelaterede produkter (Retsinformation)](https://www.retsinformation.dk/eli/lta/2021/1322) *This guide is for general information and is not legal advice.* ## Sources - [Regulation (EU) 2017/1369 setting a framework for energy labelling, consolidated text of 1 May 2021 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R1369-20210501) - [Regulation (EU) 2017/1369 as published in OJ L 198, 28 July 2017 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R1369) - [Document information, dates and relationships for CELEX 32017R1369 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32017R1369) - [Regulation (EU) 2020/740 on the labelling of tyres, amending Regulation (EU) 2017/1369 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0740) - [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020) - [Commission Implementing Regulation (EU) 2024/994 on the operational details of the product database EPREL (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R0994) - [Commission Delegated Regulation (EU) 2019/2013 on energy labelling of electronic displays (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2013) - [Commission Delegated Regulation (EU) 2019/2014 on energy labelling of household washing machines and washer-dryers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2014) - [Commission Delegated Regulation (EU) 2019/2015 on energy labelling of light sources (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2015) - [Commission Delegated Regulation (EU) 2019/2016 on energy labelling of refrigerating appliances (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2016) - [Commission Delegated Regulation (EU) 2019/2017 on energy labelling of household dishwashers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2017) - [Commission Delegated Regulation (EU) 2019/2018 on energy labelling of refrigerating appliances with a direct sales function (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2018) - [Commission Delegated Regulation (EU) 2023/1669 on energy labelling of smartphones and slate tablets (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1669) - [Commission Delegated Regulation (EU) 2023/2534 on energy labelling of household tumble dryers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2534) - [Commission Delegated Regulation (EU) 2025/1353 amending Delegated Regulation (EU) 2023/2534 on tumble dryers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1353) - [Commission Delegated Regulations (EU) No 811/2013 and No 812/2013 on energy labelling of space heaters and water heaters (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0811) - [Commission Delegated Regulations (EU) 2015/1186 and 2015/1187 on energy labelling of local space heaters and solid fuel boilers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015R1187) - [Commission Delegated Regulations (EU) No 626/2011, No 65/2014, No 1254/2014 and 2015/1094 on energy labelling of air conditioners, ovens and range hoods, residential ventilation units and professional refrigerated storage cabinets (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015R1094) - [Report from the Commission on the implementation of Regulation (EU) 2017/1369, COM(2026) 319 of 24 June 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026DC0319) - [Proposal amending Regulation (EU) 2017/1369 and Regulation (EU) 2020/740 on simplification and digital labelling, COM(2026) 565 of 24 June 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026PC0565) - [Energy efficient products: understanding the energy label (European Commission)](https://energy-efficient-products.ec.europa.eu/ecodesign-and-energy-label/understanding-energy-label_en) - [Energy efficient products: product list under Directive 2009/125/EC and Regulation (EU) 2017/1369 (European Commission)](https://energy-efficient-products.ec.europa.eu/product-list_en) - [EPREL, the European Product Registry for Energy Labelling (European Commission)](https://energy-efficient-products.ec.europa.eu/eprel_en) - [Kontrol og tilsyn: ecodesign og energimærkning (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/eco-design-og-energimaerkning/kontrol-og-tilsyn-ecodesign-og-energimaerkning) - [Sådan foregår kontrol med energimærkning (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/eco-design-og-energimaerkning/saadan-foregaar-kontrol-energimaerkning) - [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Sikkerhedsstyrelsen)](https://www.sik.dk/sikkerhedsstyrelsen-del-erhvervsstyrelsen) - [Produktenergimærkningsloven, lovbekendtgørelse nr. 186 af 2. februar 2022 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2022/186) - [Bekendtgørelse nr. 1322 af 9. juni 2021 om kontrol af energimærkning af energirelaterede produkter (Retsinformation)](https://www.retsinformation.dk/eli/lta/2021/1322) _Reviewed 2026-09-24 by Conphora compliance team_