Stress free guide to product compliance

2021-02-23
ProductIP
Experienced

New energy labels and the EPREL register

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

A new framework for energy labelling

Regulation (EU) 2017/1369 sets a new framework for energy labelling. It replaced the energy label directive 2010/30/EU and came into force on 1 August 2017.

The Regulation also introduces a new obligation to register all energy labels in a central database:
EPREL - the EU Product Register for Energy Labelling. The registration is mandatory per 1 January 2019.

Some remains the same

The legislation applies to all 'energy-related products'. Energy labels are already mandatory for air conditioners, dishwashers, domestic ovens, fridges and freezers, lamps and luminaires, professional refrigerated storage cabinets, range hoods, solid fuel boilers, space heaters, televisions, tumble driers, vacuum cleaners, ventilation units, washing machines, water heaters and even tyres.

The provisions of the new Regulation are broadly in line with those of Directive 2010/30/EU. Suppliers or manufacturers of energy-related products remain obliged to provide information to dealers.
Dealers must still affix energy labels to products, make product information sheets available to customers and, in case of internet sales, do this digitally. In this way consumers will be informed about the energy consumption of the products and they can make an informed decision before purchase.

The EU facilitates the implementation of the labelling regulations with a very convenient online application; the Energy Label Generator creates tailor-made labels for your products in high resolution pdf format.

EPREL Database

The supplier must still ensure that each energy- related product sold, and for which a delegated regulation exists, is accompanied by an accurate printed energy label and a product data sheet. However, in specific cases, the product data sheet may now be replaced by a reference to the newly introduced EU-product database (e.g. via a QR code).

The Regulation establishes an EU-product database. Starting at 1 January 2019 suppliers are obligated to enter the necessary data on energy consumption into the EPREL-database for each product it places on the market.
For products already on the Union-market, from 1 August 2017, a transitional regime applies; for these products the database must be filled in by 30 June 2019 at the latest.
For products placed on the market before 1 August 2017 it is permitted to enter the product data in the EU-product database, but it is not obliged.

The EU-product database contains a public area, where traders and consumers can consult the product information sheets, and a closed area on product compliance, accessible only to market surveillance authorities.

Products that are altered are considered as new models and must be (re)registered if the changes are significant for the label or for the product information sheet. Registrations and alterations made in the database are kept for 15 years.

You can access the EPREL database via this link.

Back to the old classes

Initially energy labels applicable for energy-related products had classes from A to G, dependent on the measured energy parameters. This label was such a success that mostly products were sold in classes A and B (very efficient energy consumption).
Even more energy efficient products were then developed. The EU responded by this introduction with categories A+, A++ and A+++ for most efficient products for specific product groups.

This new classes however led to confusion with consumers who were unable to compare these products. Secondly, it has been shown that the current A+, A++ and A+++ scale is less effective in stimulating the purchase of efficient products than the original A-G scale.

The Regulation provides for a return to the 'original' A- G scale. All products with an energy-label must therefore be reclassified. Priority was given to specific product groups: household dishwashers, household refrigerators, household washing machines and washer-driers, televisions and lamps.
The 'reclassification' for all product groups must be completed by 2 August 2023.

Future proof classification

When the EC has reclassified the energy-related products, no product may be in the highest energy class A, so that there is later space for reclassifying new, even more energy-efficient products.
The Commission must classify the scale so that 'it is estimated that it takes at least 10 years' for most of the models to fall into class A. In sectors where technology is developing very rapidly, the EC may even keep two classes (A and B) free for future, even more energy efficient products.

The EC may also still introduce energy labels for product groups for which there are currently no energy labels. These must also comply with the new regulations: classification on an A-G scale, no A-class products at the time of declaration, valid for at least 10 years.

In order to maintain an overview, the EC must draw up a long-term work plan listing the product groups for which it is working on implementing provisions. This plan must be made public.

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