This product does not have to bear an energy label, nor should it be registered in EPREL (European Product Registry for Energy Labelling).
EPREL Public website (europa.eu)
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.