Please see the roles of the different economic operators under Ecodesign here, and for Energy Labelling here to better understand relevant responsibilities.
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.
Placing on the market is defined under Ecodesign as 'making a product available on the Union market for the first time with a view to its distribution or use within the Union, whether for reward or free of charge and irrespective of the selling technique'.
'Placing on the market' can be done by the manufacturer or by an importer. According to Union legislation, each individual product can be placed on the Union market only once. Once placed on the market, compliant products may subsequently be made available along the delivery chain.
The Blue Guide, the guide to the implementation of EU product legislation, provides for some further explanations in relation to 'placing on the market'.
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.
Examples of situations which are NOT considered 'placing on the Union market' can be found on the Blue Guide point 2.3.
This is the case, when the product:
- has been transferred from a manufacturer in a third country to the manufacturer's authorized representative in the EU/EEA or Northern Ireland, who must ensure that the product complies with Ecodesign legislation (and other relevant legislation);
- has been transferred to a manufacturer for further measures (e.g. assembly, packaging, working or labelling);
- is the stocks of the manufacturer or the importer, but not yet provided for distribution or available for consumption;
- is showcased at a trade fair, exhibition or demonstration.
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.
‘Making a product available on the market' means any supply, whether in return for payment or free of charge, of a product for distribution, consumption or use on the Union market during a commercial activity. 'Making available' is a concept that applies to individual units or products.
Only compliant products can be made available along the delivery chain. The central role of the concept of 'making available' is to indicate that all economic operators which are part of the supply chain do play an active role in ensuring that only compliant products circulate. Member States authorities have also the obligation to ensure that only compliant products are made available. This means that compliance with those Ecodesign requirements that were applicable at the time of its placing on the market, can be checked at any point of the making available of the product until they reach the end-user.
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.
The concept of 'putting into service' (mentioned, e.g. in Article 2 point 5 of Directive 2009/125, generally applies to products which are not 'placed on the market'. The aim of this concept is to identify the moment at which economic operators need to demonstrate compliance. It means the moment of first use within the Union. It concerns for example products which can be only used only after an assembly, an installation or other manipulation has been carried, such as boilers and water heaters, or products made for the manufacturer's own use.
Even if the reference to two terms may create the impression that 'placing on the market' and 'putting into service' are two different moments when a product compliance is to be assessed, this is not the case: as these two terms are mutually exclusive, either one or the other is relevant.
'Placing on the market' (making a product available for the first time on the EU market) and 'putting into service' (first use of a product for its intended purpose by an end-user in the EU) refer to two different 'modalities' in the process of bringing a product to the market; compliance is required only once based either on whether the product is placed on the market or whether it is put into service. Only where a product is 'not placed on the market' in the literal meaning, the moment of compliance is the putting into service.
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.
A product is placed on the market when the manufacturing process is finished and has been offered by the manufacturer or the importer on the Union or EEA market. According to the Blue Guide, this requires an offer (e.g. an invitation to purchase, advertising campaigns) or an agreement for the transfer of ownership which can be free of charge or in exchange for a reward.
Placing on the market does not necessarily require the physical handover of the product. This means that the products can still physically be at the factory, but if the product has been offered and bought (perhaps on line), it is considered as placed on the Union market.
See more information in the Blue Guide, the guide to the implementation of EU product legislation.
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.
According to Article 1(2)(a) the Regulation (EU) 2017/1369 does not apply to 'second hand products unless they are imported from a third country' (first made available).
Products imported from a third country have to comply to Ecodesign and Energy Labelling regulations applicable at the moment of their import.
In addition, products which after their placing on the market are substantially modified, for example by a distributor or an importer, to the extent that the compliance of applicable requirements such as energy efficiency is affected, these are considered as 'new products'. The economic operator modifying the product is responsible of the compliance of the 'new product' (for more detail see Blue Guide chapter 2.1.
Some examples may further clarify:
a) Cancellation of contracts. The consumer withdraws the contract. The product is then resold.
No, this would be considered a second hand good only if if it has been used.
b) Products that have been repaired or refurbished and are then placed on the market and resold.
Yes, products can be subject to life extension. Depending on the processes to which it is submitted the repaired products is considered as second hand product or if it has been significantly changed and comes e.g. with a new warranty period; it can be considered as a new product.
c) Swap stocks: products that are held in stock for the purpose of warranty cases and are sold at a later stage as 'phase-out model'.
No, these are new products because they have not been offered for sale before.
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.
To date, all Ecodesign regulations allow the manufacturer's assessment of the products’ conformity via a self-declaration. This conformity assessment procedure is also called internal design control and is described in Annex IV of the Ecodesign legislation.
This allows the manufacturer to carry out himself the conformity assessment and to draw the necessary technical information showing how the conclusions have been reached. This documentation is to be established in one of the official languages of the Union. In the case of compliance with limit values, a measurement protocol stating the measurement standard or equivalent measurement specification retained, information about the equipment used and the selection of test samples is sufficient. The EU declaration of conformity then only contains the reference to the compliance with the regulation and the measurement. specifications or standards.
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.
Manufacturers are to ensure compliance with those Ecodesign requirements that are applicable at the time of the placing on the market of an individual unit. However, a number of obligations are to be fulfilled by manufacturers prior to the placing on the market of individual products such as carrying out the conformity assessment, issuing the EU declaration of conformity and affixing the CE marking on the product.
When more than one piece of EU legislation apply to a product and require the issuing of EU declarations of conformity, the manufacturer can fulfil its commitment via an unique EU declaration of conformity and can also establish a consolidated technical documentation.
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.
A product with more than one function, regulated by one or more ecodesign regulations has to comply with the requirements applicable to each function, unless specifically excluded from their scope.
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.
Member States market surveillance authorities have the powers to investigate the compliance of any product made available on the Union market. In order to do so, they can require economic operators to provide the technical documentation and other relevant information demonstrating compliance. They can also obtain samples and carry out the necessary physical checks on the products.
In case of non-compliance, they can require the economic operator to take necessary actions such as bringing the product into compliance, preventing the product from being made available on the market or withdrawing or recalling the product. Their powers includes the adoption of effective, proportionate and dissuasive sanctions, where appropriate.
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.
Upon inspection of the documents related to the product, a market surveillance authority can declare a product non-compliant without testing it if the technical documentation or the absence of it does not provide evidence that the product complies with the relevant requirements .
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.
If the product is considered non-compliant by the market surveillance authorities and the economic operator fails to follow the instructions from competent authorities to bring the concerned products into compliance, the market surveillance authorities can take all necessary measures including the temporary or permanent withdrawal of the concerned units from the Union market and sanctions on economic operators.
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.
Ensuring conformity during the design and the manufacturing process is generally the responsibility of the manufacturer. In this process, the manufacturer has to carry out all required controls and checks, to establish the necessary technical documentation and give access to the economic operator placing products on the Union market (or putting them into service). These obligations apply in an equal manner to EU and non-EU manufacturers, regardless of where the manufactured product is imported from.
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.
The Ecodesign and Energy Labelling legislation (note: Energy Labelling legislation is not a CE regulation) do not require suppliers to make the Declaration of Conformity available on a specific website or tool, such as EPREL.
Supplier must provide the DoC upon request by the national market surveillance authorities . To facilitate and streamline communication with those national market surveillance authorities, suppliers may upload the DoC in EPREL’s compliance part on a voluntary basis.
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.
Registration of models in EPREL is limited to suppliers established in the EU. In order to provide evidence of their identity and their establishment in the Union they need to successfully pass the verification process set under Regulation 2024/994, to be verified electronically in this respect.
Only suppliers that have successfully completed the verification process in EPREL and provided evidence of their identity and establishment in EU Member States (plus EEA or Northern Ireland) can register models in EPREL database, modify existing registrations or perform any other action on models registered by them.
In the case of products manufactured by third country operators, they are to designate an authorized representative established in the EU or the importer of their products that needs to register in EPREL and that will register the products. The authorized representative is a legal or natural person independent from the manufacturer, who is performing a number of administrative tasks, as for example the registration of models on behalf of a third country manufacturer.
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.
Via the verification process provided under Regulation (EU) 2024/994, suppliers are to provide evidence of their identity and of their establishment in the Union. Suppliers that are legal persons shall submit evidence of their identity and of their establishment within the Union by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider (QTSP) pursuant to Regulation (EU) 910/2014 (eIDAS) has been possible on a voluntary basis until start of application of such Regulation and was not a pre-requisite to register models before start of application of that Regulation.
Regulation (EU) 2024/994 provides for mandatory verification of suppliers after a transition period. It also sets the type of accepted certificates, in electronic form.
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.
Both types of suppliers need to undertake the electronic verification process as required by Regulation (EU) 2024/994, however the deadlines and conditions to pass verification are slightly different as qualified electronic seals are required for legal persons and qualified electronic signatures are required for natural persons.
Suppliers which are legal persons shall submit evidence of their identity and of their establishment within the Union by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider (QTSP) pursuant to Regulation (EU) 910/2014 (eIDAS). Suppliers that are natural persons shall submit evidence of their identity by means of a qualified electronic signature and evidence of establishment within the Union and, if appropriate, of having received a written mandate as authorised representative of a manufacturer not established in the Union, to act on its behalf for registering in EPREL product models of that manufacturer.
Verification has been possible on a voluntary basis since February 2022 and until 22 October 2024 as set out in Regulation (EU) 2024/994; during that period, verification was not a pre-requisite to register models. Regulation (EU) 2024/994 requires mandatory verification of suppliers as from 22 October 2024. It also sets the type of accepted certificates, in electronic form. The voluntary phase is still open until 22 October 2024.
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. Only verified suppliers may register product models in EPREL and perform any modification relating to existing ones; this applies to both legal persons and to natural persons.
As of 22 October 2024, 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.
Until 22 April 2025, suppliers that are legal persons may submit a qualified electronic seal where the three-character legal person identity type reference may be set to one of the values in Article 6(1). By 22 April 2027 thesesuppliers that have been verified with an electronic seal according to the format of Article 6(1) shall renew their verification by providing a qualified electronic seal as set out in Article 4.
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.
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.
Until 22 October 2024, any existing supplier can continue registering products in EPREL.
Until 22 April 2025, suppliers that are legal persons may submit a qualified electronic seal where the three-character legal person identity type reference may be set to one of the values in Article 6(1).
By 22 April 2027 thesesuppliers that have been verified with an electronic seal according to the format of Article 6(1) shall renew their verification by providing a qualified electronic seal as set out in Article 4.
As of 22 October 2024, products from unverified suppliers will still be published (at the start date of placement on the market) in the Compliance Site, remaining visible only to MSAs. These products will be also accessible when scanning the QR Code on a label or by entering the EPREL ID in the Public site, with a text indicating that the model was registered by an unverified supplier. However, published products from unverified suppliers will not “appear” in the search results in Public site when searched by consumers.
Newly registering suppliers will have to complete the electronic verification process before registering their first product 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.
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 of22 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.
In the EPREL database, the date of first placement on the market relates to the date on which a supplier makes the first unit of the product model recorded available for distribution or use on the Union market.
The date of end of placement on the market refers to when a product model is removed or discontinued from production being placed on the EU market. date of end of placement on the market' means the date of placing on the market of the last unit of a product model;
Some examples of dates that are considered dates of end of placement are as follows:
- in the case of products from third country imported, the 'date of end of placement on the market' could be the date of the last customs declaration, provided the importer is not going to import that model anymore and that no later document mentions that model (e.g. an invoice or any 'transportation' document).
- in case of products from EU manufacturers, it can be the date of the last document related to the last unit of a model leaving the factory (i.e. the transport document, or the invoice, if later…).
On the contrary, the date of sale to the final or the intermediate customer is an operation that is beyond the control of the supplier is not relevant to EPREL.
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.
The supplier shall deliver printed labels, including rescaled labels and product information sheets, to the dealer free of charge, promptly and in any event within five working days upon the dealer's request in accordance with Article 3 (2).
As an alternative to supplying the product information sheet (in a printed form) with the product, the specific Energy Labelling act may provide that it is sufficient for the supplier to enter the parameters of such product information sheet into the product database. In such a case, the supplier shall provide however the product information sheet in printed form to the dealer on request.
The supplier shall ensure that products that are placed on the market are accompanied, for each individual unit, free of charge, with accurate printed labels and with product information sheets in accordance with this regulation and the relevant delegated acts.
Dealers obligations are set under Articles 5 and 6 of Regulation (EU) 2017/1369.
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.
It is possible to download all registered product models of a supplier on the EPREL database, with model identifier and registration number, by going to the Export page and selecting the button 'Export all models'.
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.
The registration of a model can be 'completed' any moment before the model is placed on the Union market. The recorded information becomes only publicly available from the day that the supplier indicates in a specific field as 'date of placing on the market'. Similarly, both the public and the technical information becomes accessible to Market Surveillance authorities from that same day.
To have the model really published at the scheduled date, all mandatory fields of the registration have to be filled and the model registration marked as 'complete'. Needless to say that the day that the first unit of that model appears anywhere on the EU market, including at customs, the model has to be already publicly accessible. Similarly, scanning the QR will provide a return only from the day of placement on the market.
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.
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):
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.
The product information sheet fiche has to be written in a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned.
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.
The Qualified Electronic Seal, provided by a validated service provider, is necessary for the electronic verification of your organisation during registration on the EPREL database.
Please check this link for more information on registration and verification.
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.
Measured values:
Measured values result directly from measurement by manufacturers, carried out in the context of conformity assessment. These values must be available in the technical documentation e.g. in test reports (See definition (23) ‘technical documentation’ means documentation sufficient to enable market surveillance authorities to assess the accuracy of the label and the product information sheet of a product, including test reports or similar technical evidence).
Measured values and test reports are not part of the mandatory information to be provided in the EPREL database, but can be uploaded on a voluntary basis.
Declared values:
The declared values are the values declared by the manufacturer for the purpose of verification of compliance by market surveillance authorities. These must be provided in EPREL as parameter values to be entered in the Technical Information (generally these are listed in the Regulation in Annex V). The declared values are used by market surveillance authorities for the calculations set out in the calculation and measurement annexes.
Declared values may differ from measured values in that manufacturers may decide to declare values that are less favourable than measured values, e.g. by applying a safety margin to cover their own uncertainties of measurement and possible variations of performance due the manufacturing process in order to reduce the likelihood that products are placed on the market with lower performance than actually declared.
As specified in the delegated acts, declared values and the values used to calculate them may not be more favourable than the corresponding measured values.
Published values:
Published values are those that are communicated to potential buyers, through the product information sheet (or product fiche), visual advertisement or other means (public information). Some of them also appear in the label.
Manufacturers may decide to publish values that are less favourable than the declared values because of rounding or any other reason e.g. commercial reasons.
As specified in the delegated acts, published values may not be more favourable than the declared values.
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.
Each model placed on the market must be registered in EPREL and is attributed a unique registration number in the database.
This number can be retrieved via the QR code present on the labels for the concerned product groups. For other product groups, a search in the public part of the database is an option.
For dealers who use Tradeplace as a source of information, the PI standard also contains the EPREL registration number.
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.
For products already covered by Energy Labelling, it is not allowed to 'provide or display other labels, marks, symbols or inscriptions' which do not comply with the applicable energy labelling requirements, if doing so would be likely to mislead or confuse customers [...];
For products not covered by Energy Labelling, it is not allowed to supply or display labels which mimic the labels provided for under Energy Labelling regulations;
Energy labels fulfilling the requirements from a third country would be in breach these of obligations.
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.
Registering products in EPREL is the pre-condition required under EU law before placing products on the Union market. The same requirement applies to products placed on Northern Ireland market that can then be freely distributed in the Union.
Registration in EPREL of products manufactured by a third-country company can only be done by economic operators established in the Union: either the importer (s) or an authorized representative fulfilling the conditions to act as such.
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.
The QR-Code gives access to information on the specific model, as registered in the EPREL database by the supplier. The EPREL database includes the mandatory information requested by the the various Energy Labelling regulations.
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.
The supplier must ensure that a printed version of the energy label is provided with the product, inside the packaging, or printed on the packaging of the product in the case of light bulbs and displays.
The product information sheet does not have to be printed and inserted into the packaging. It is accessible in the EPREL database, via the QR code for the new labels.
The supplier must deliver printed labels and product information sheets to the dealer free of charge, promptly and in any event within five working days upon the dealer's request.
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.
The format and dimensions of the label are laid down in each Regulation have to be respected. Member States are responsible for assessing compliance with the requirements of the Energy Labelling regulations, including the label format.
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.
All products placed on the Union market for the first time, including imported second-hand products, when made available on the Union market for the first time, fall within the scope of the Energy Labelling Framework Regulation (EU) 2017/1369, see recital (5).
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.
If the supplier provides a software update to the dealer which changes the product, including its efficiency, the supplier has to provide a new label and the dealer has to display it. The dealer is not at fault if the supplier did not actively communicate that the update is connected to a change of the label. If the software update is done after the product is put in service, the supplier shall request explicit consent from the customer regarding any changes that would be detrimental to the parameters of the energy efficiency label, as set out in the relevant delegated act.
For a period proportionate to the average lifespan of the product, the supplier shall give the customer the option of refusing the update without avoidable loss of functionality as provided for in Article 3.4 of the Energy Labelling regulation.
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.
The Energy Labelling regulation is clear in stating that labels shall be printed. This provision applies from the entry into force of the Regulation to all existing delegated acts.
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.
Professionals are also customers, so the products they use are not a priori excluded from Energy Labelling provisions. Each specific Energy Labelling regulation has its own scope, which determines the coverage of products that need to bear the energy label. Where applicable, the scope specifies whether the products for use in domestic, commercial and industrial environment are in scope.
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.
No. By definition, ”equivalent models” are registered under different identifiers and have their own label each. The Regulations setting requirements for energy labels set in an exhaustive manner the information to be part of the label in particular the relevant model of the unit in question has to be part of the label. This is without prejudice of the possibility offered by EPREL to suppliers to establish internally a link between a so -called “base model” and other “equivalent model(s)” this may imply that the information related to the energy labelling and the product information sheet is not to be uploaded again depending on the judgment of the supplier registering them.
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.