Regulation (EU) 2017/1369 indicates that only economic operators either manufacturers or importers or authorised representatives in the case of non EU manufacturers of products which are themselves established in the Union, can register models in EPREL. This obligation is to be fulfilled before placing any unit of those products on the EU market.
Regulation (EU) 2024/994 provides for the means to prove both the identity of suppliers and their establishment in the Union in an electronic manner.
For already registered models before 22 October 2024, products compliance is not at stake.
BUT if you have not undergone electronic verifications, you will be considered an unverified supplier AFTER 22 October 2024, not having fulfilled the condition of having provided evidence of identity and of being established in the Union.
As of 22 October 2024, suppliers of energy-related products and tyres, specified in Article 1(1) points (a) and (b), shall be verified suppliers, i.e. having completed the supplier verification process in the EPREL compliance system according to Articles 4, 5 and 6 of Regulation (EU) 2024/994 this applies to both legal persons and to natural persons.
As of 22 October 2024 only verified suppliers may register product models in EPREL and perform any modification relating to existing ones .
On the contrary, as of 22 October 2024, foreseen in Regulation (EU) 2024/994, modification of existing models and registration for new product models will not be possible for unverified suppliers.
Also models registered in EPREL by entities not verified shall not be listed in the search results in public EPREL website. When such a model is retrieved from EPREL by scanning a QR code or by any other means a text shall indicate that the model was registered by an unverified supplier.
More info here.
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.