Article 4.4 of the Framework Regulation for Energy Labelling (EU) 2017/1369 reads:
4. A product for which changes are made that are relevant for the label or the product information sheet shall be considered to be a new model. The supplier shall indicate in the database when it no longer places on the market units of a model.
If the energy label class changes because of modifications changes of the product, then the supplier must register the product as a new model and calculate the updated energy class. The supplier can create a new model with the same protocol and add an appendant, e.g. a '-V2' or '-1' or '_x' or '-[year]' to the model identifier. For the products already placed on the EU market and present in shops with an outdated energy class, the supplier should set in EPREL for that model the date of end of placing on the EU market.
Changes to existing registrations are instead allowed for these reasons (and do not require the supplier to make a brand-new registration):
- correct typo: supplier has done a mistake when declaring a value and needs correction
- change in standards: the testing standards can change and some values need to be modified
- label scale-range change: in a same Delegated Regulation, the scale of energy efficiency may change with the years (i.e. reversible air conditioners classified in energy efficiency classes A-G from 01/01/2013 to 31/12/2014, A+ -F from 01/01/2015 to 31/12/2016, etc..) and model needs to be modified
- request to change declaration by market surveillance: if MSA detects an error or a mistake tat does not need a new model registration, it can ask the supplier to modify some values of a registered model
- correction without changes in the declaration: during the lifecycle of of a model, it might be that either the company itself produces more helpful information, or clarification, or that it turns out that for communication with MSA, this information speeds up their understanding (though strictly speaking not legally necessary). Additional information, that does not change in such a case the model, this cannot lead to a forced change in model number (= no new registration), a change of model would then not make any sense
- request to change declaration by external body: a Certification Body very frequently detects error in declared data, sometimes typing mistakes, many times performance data that, after test in Independent Laboratory, needs correction ("re-rating"). Data linked to a product can represent up to dozens of values, and it can happen that one, a few or more, need adjustment. New models each time is not sustainable.
- set date of end of placement on the market: to set the date of end of placement on the market of a model
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.