Our product needs an energy label and EPREL registration

Regulation (EU) 2017/1369 is a framework. It applies to energy-related products placed on the market or put into service and provides for their labelling and for standard product information on energy efficiency and on the consumption of energy and other resources during use (Article 1(1)). The detailed requirements come from delegated acts, one per product group, which define the products covered, the design of the A to G label, the product information sheet, the technical documentation, verification tolerances and how the label is shown in distance selling (Article 16(1), (3) and (4)). The regulation applies from 1 August 2017; its database article applies from 1 January 2019 (Article 21).^[1]

The duties fall mainly on the supplier: the manufacturer established in the Union, the authorised representative of a non-EU manufacturer, or the importer that places the product on the Union market (Article 2(14)). The supplier ensures that each unit is accompanied, free of charge, by an accurate printed label and a product information sheet, delivers labels and sheets to a dealer within five working days of a request, and produces technical documentation sufficient to assess their accuracy (Article 3(1)–(3)). Products may not be designed to change their performance in test conditions (Article 3(5)).^[1]

The product database sits at the centre. Implementing Regulation (EU) 2024/994 names it EPREL, the European Product Registry for Energy Labelling (Article 2(1)), and from 22 October 2024 only verified suppliers may register or change models in it; a legal person proves its identity and establishment in the Union with a qualified electronic seal (Articles 3 and 4). Before placing on the market a unit of a new model covered by a delegated act, the supplier enters the model in the public and compliance parts of the database (Article 4(1)). The public part holds the supplier's details, the model identifier, the electronic label, the classes and parameters and the product information sheet; the compliance part holds equivalent models and specified parts of the technical documentation, such as the measured parameters, the calculations and the standards applied (Article 12(5) and Annex I). A product with label-relevant changes is a new model (Article 4(4)), and the compliance information is kept for 15 years after the final unit unless a delegated act sets a shorter period (Article 4(6)).^[1][6]

Dealers display the label visibly, including for online distance selling, and make the product information sheet available (Article 5(1)). Suppliers and dealers refer to the energy class and the range of classes in visual advertisements and technical promotional material, and do not display misleading labels, or labels that mimic the energy label on products outside its scope (Article 6). The Court has held that the advertising duty in Article 6(a) also applies to product groups covered by a delegated act adopted under the old Directive 2010/30/EU; where that act does not say how, the class and range are shown as on the label, provided this stays legible and visible, or otherwise in an equivalent way (Case C-761/22, order of 5 October 2023). The delegated act fills in the detail. For refrigerating appliances, for example, the supplier makes an electronic label available to dealers and the dealer shows it close to the price on the web page, possibly through a nested display (Delegated Regulation (EU) 2019/2016 Articles 3(1)(g) and 4(b), Annex VIII).^[1][2][7]

Enforcement is national within an EU frame. Member States set the penalties (Article 7(4)), authorities may recover testing costs from the supplier (Article 8(5)), and the regulation is listed in Annex I to Regulation (EU) 2019/1020, so that regulation's corrective measures apply (Article 16). Many labelled product groups also carry ecodesign requirements: where models in class E, F or G may no longer be placed on the market because of an ecodesign implementing measure under Directive 2009/125/EC, those classes are shown in grey on the label (Article 11(10)). For products regulated by implementing measures under Directive 2009/125/EC, that directive's CE marking and declaration rules continue to apply under the transitional provisions of Regulation (EU) 2024/1781 until those measures are repealed or declared obsolete (Article 79(1)(b)). A Commission proposal, COM(2026) 565, would amend Regulations (EU) 2017/1369 and 2020/740 on simplification and digital options for energy and tyre labelling; on 4 October 2026 EUR-Lex lists it as a proposal only.^[1][3][4][5]