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 these suppliers 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.