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 It entered into force on 1 August 2017, the fourth day after publication, and applies from that date, when it repealed Directive 2010/30/EU; the supplier duties for the product database apply from 1 January 2019 (Art. 20(1) and Art. 21).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), or the consolidated text of 1 May 2021 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 · See plans and pricing
Sources
- Regulation (EU) 2017/1369 setting a framework for energy labelling, consolidated text of 1 May 2021 (EUR-Lex)
- Regulation (EU) 2017/1369 as published in OJ L 198, 28 July 2017 (EUR-Lex)
- Regulation (EU) 2020/740 on the labelling of tyres, amending Regulation (EU) 2017/1369 (EUR-Lex)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Commission Implementing Regulation (EU) 2024/994 on the operational details of EPREL (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2013 on electronic displays (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2014 on washing machines and washer-dryers (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2015 on light sources (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2016 on refrigerating appliances (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2017 on dishwashers (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2018 on refrigerating appliances with a direct sales function (EUR-Lex)
- Commission Delegated Regulation (EU) 2023/1669 on smartphones and slate tablets (EUR-Lex)
- Commission Delegated Regulation (EU) 2023/2534 on household tumble dryers (EUR-Lex)
- Report from the Commission on the implementation of Regulation (EU) 2017/1369, COM(2026) 319 (EUR-Lex)
- Understanding the energy label (European Commission)
- Product list under Directive 2009/125/EC and Regulation (EU) 2017/1369 (European Commission)
- EPREL, the European Product Registry for Energy Labelling (European Commission)
- Kontrol og tilsyn: ecodesign og energimærkning (Sikkerhedsstyrelsen)
- Sådan foregår kontrol med energimærkning (Sikkerhedsstyrelsen)
- Produktenergimærkningsloven, lovbekendtgørelse nr. 186 af 2. februar 2022 (Retsinformation)
- Bekendtgørelse nr. 1322 af 9. juni 2021 om kontrol af energimærkning af energirelaterede produkter (Retsinformation)
This guide is for general information and is not legal advice.