Is a range hood sold without a motor a range hood, and does it have to be labelled as such?

Yes, it marketed as such a range hood without a motor is a range hood, and the label should show the most common combination and other possible combinations should be made available upon request (or at the website). This is in line with the provisions of the Commission Guidelines for cooking appliances:

[3.2.4 Labelling for multiple combination hoods - Range hoods may be combined with different external fans and thus more than one label could be applicable. For each domestic range hood, suppliers shall provide at least one printed label with the product representing the most likely combination. For other combinations – the hood/control with associated fan – the information is provided by suppliers on a free access web site.]

_{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.}