What do dealers need to know?
Dealers have specific obligations in respect to the Energy Labelling Regulation (EU) 2017/1369 because the labelling of products targets end users, such as customers, and aims at orienting purchase choices. The dealer, consequently, is a crucial actor in the implementation of the policy, having to deliver the message by clearly displaying energy labels, when selling products, and having to provide the relevant complementary information, i.e. what included in the so-called "Product Information Sheet" or "Product Fiche".
The obligations on dealers, of facilitating the provision of information on product efficiency, covers not only classical, brick&mortar stores, but also on-line stores, distance selling, catalogues and promotional material: all European web stores, for example, must show the labelling information close to the price indication or "buy" button.
No definition and no specific obligation on dealers or retailers is set in the Ecodesign Directive 2009/125/EC for energy-related products, as it targets manufacturers and not final users.
What is a dealer?
Dealers are a retailer or other legal or natural 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. This definition is according to Article 2.(13) of the Energy Labelling Regulation (EU) 2017/1369.
What is a distributor?
Distributor means a legal or natural person in the supply chain, other than the supplier, who makes a product available on the market. This definition is according to Article 2.(16) of the 'Tyre Labelling' Regulation (EU) 2020/740. In the context of the tyre labelling the obligations of distributors are rather comparable to those of retailers but involve additional responsibilities, such as not supplying products not in compliance with the legislation (e.g. not registered in EPREL, not bearing the label, etc). A more extensive explanation of what a distributor is and its obligations can be found in the Commission notice The ‘Blue Guide’ on the implementation of EU product rules 2022 (Text with EEA relevance) 2022/C 247/01 (section 3.4).
Obligations on dealers
The Energy Labelling Regulation (EU) 2017/1369 as well as the Tyre Labelling' Regulation (EU) 2020/740, include general obligations on respectively dealers or retailers and on distributors.
Additional obligations and details are set in delegated regulations on specific products.
General obligations include in particular the display, in a visible manner, of the label provided and providing to customers the product information sheet (although via EPREL all can be downloaded freely). If the label has a QR code, it has to be readable, to let the interested user access the full information from EPREL.
Specific obligations and details on how to comply are set in delegated acts, such, e.g. how the label and the information sheet have to appear via a mouse-over or a click on a 'nested display', or how to show the letter of the energy efficiency class in distance selling or in catalogs, etc.
Physical stores (brick&mortar)
As a retailer, you are responsible for displaying the label at the point of sale clearly an unequivocably associated to the model on display (e.g. with the label sticker stuck on the product).
Product-specific regulations may include specific or additional requirements (e.g. if the product is not put on display and left the boxes on a pallet, the label shall be stuck in the box or, for small products such as light bulbs, the packaging shall bear the label, etc.)
The retailer is responsible for supplying the product with product data sheets, to be passed over to end-users.
On-line stores
For products offered for sale, rent or instalment via the Internet, the product energy label and data sheet must be made available close to the price indication. The energy label and product data sheet can be made visible via compacted energy class arrow working as 'nested on-screen display', with the appropriate colour, and the applicable range of classes. A click or a mouse-over on the class arrow shall display the full label.
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The responsibility for this lies with the dealers. The detailed rules (aspect of the class arrow, mechanism, coloured or monochrome, etc.) are set in in the product-specific regulations and Regulation (EU) 518/2014.
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Suppliers have the obligation to provide to the dealer or distributor the EPREL model registration number: this is intended to facilitate in particular on-line stores that can get, via an API (Application Programming Interface) the image of the label and of the nested label directly from the model registration record in EPREL.
Advertising products
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For advertising products in the scope of the labelling legislation (mail orders, catalogues, internet, telemarketing) or in any other way where the potential customer cannot see the product exhibited, the supplier or dealer shall indicate the energy efficiency class of the product and the range of classes. |
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Resources for dealers, distributors and retail service providers
Label and Product Information Sheet retrieval tool
Energy efficiency-related data, including
a) the nested arrow,
b) the energy efficiency label and
c) the product information sheet (formerly ‘product fiche’)
must be included in any online store for all product in the scope of the Energy Labelling Regulation, i.e. for all product models that have to be sold with an energy label.
This information must be placed close to the price of each product and is intended as information to help the consumer perform his/her purchase choice.
CLASP offers a Javascript, to be embedded in web pages, that let the dealer automatically retrieve the relevant nested arrow, label and product information sheet (or product fiche) from the EPREL database.
Please visit the CLASP website for detailed information on how to use this freely-available code and to download it.
Energy label templates
As the registration of products is mandatory, manual generation of labels is only intended to 'reproduce' labels for specific graphical needs (e.g. brochures or printouts on boxes): energy label templates are available for this purpose (InDesign and other file formats).
Source: CircaBC label templates repository
Guidelines
Source: www.seai.ie
Training
Installers
 ©AdobeStock-SimonP |
The new Energy Label will be supplied by the manufacturer. It will be the installer’s responsibility to ensure that customer has received the energy label, and additional documentation of the product at the point of sale. Source: Installer - label-pack-a-plus.eu |
Source: www.label-pack-a-plus.eu