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Energy Efficient Products

The energy labelling act sets only two possible sizes for the energy label. What label should a supplier use with a packaging 50 mm wide and 54 mm high?

Commission Delegated Regulation (EU) 2019/2015 on Energy Labelling for light sources (including its amendment from Commission Regulation (EU) 2021/341), has a void regarding the size of the energy label. According to the Regulation Annex III:

“Suppliers shall choose a label format between point 1.1 and point 1.2 of this Annex. The label shall be:

- for the standard-sized label at least 36 mm wide and 72 mm high (correction from 75 to 72 post Omnibus);

- for the small-sized label (width less than 36 mm) at least 20 mm wide and 54 mm high. The packaging shall not be smaller than 20 mm wide and 54 mm high. Where the label is printed in a larger format, its content shall nevertheless remain proportionate to the specifications above. The small-sized label shall not be used on packaging with a width of 36 mm or more.”

a) Energy labels on existing products placed on the market before the application on 1 September 2021 of Commission Delegated Regulation (EU) 2019/2015:

• Existing labels are replaced by the rescaled labels in a format and size that permits it to cover the existing label e.g with stickers (according to Commission Delegated Regulation (EU) 2019/2015, Article 3(i), Article 4(e), annex III(1)). Thus the supplier can adapt the size depending on the existing label, keeping it proportionate to the specifications in the new delegated act.

b) Energy labels for new products placed on the market from 1 September 2021: Relevant provisions in Commission Delegated Regulation (EU) 2019/2015:

• According to Annex III(1), the customer is supposed to be able to see the whole label when s/he chooses the product, suggesting that the label should be on the part of the packaging meant to face the prospective customer. The label can be on another side, as long as an arrow containing the letter of the energy efficiency class is displayed on the side facing the customer, as detailed in the Annex.

• According to Article 4(a), the energy efficiency class must be clearly visible.

In the event that none of the size options from Annex III fits, there is nothing in the Regulation that impedes that the print of the energy label continues on an adjacent face of the packaging, as long as the provisions in Annex III(1) and Article 4(a) are met.

In the case of a box with four sides (front, back, bottom and top side) and assuming that the part of the packaging meant to face the prospective customer is the front side, the energy consumption and the QR code should be on the front side, while the supplier’s name and the model identifier (which are on the upper part of the label) should be on the top side. It should be avoided that part of the label ends up in a supposedly non-visible side such as the bottom part.

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.