Energy labels are among the most visible elements of European product regulation, but the familiar efficiency scale displayed to customers represents only one part of a wider technical and regulatory system.
Regulation (EU) 2017/1369 establishes the European framework for energy labelling of energy-related products. Product-specific delegated acts determine which products require an energy label, which performance characteristics must be declared, how efficiency classes are calculated and what information must accompany the product.
Energy Labelling operates alongside Ecodesign legislation. While Ecodesign establishes mandatory performance and design requirements for products within its scope, Energy Labelling communicates defined performance information so that purchasers can compare products.
For many regulated products, suppliers must also register product models in the European Product Registry for Energy Labelling — EPREL — and provide the technical and product information required by the applicable legislation.
Compliance therefore involves considerably more than printing the correct coloured label. The efficiency class, declared values, product-information sheet, technical documentation, EPREL record and physical product must all be supported by consistent technical evidence.
This GAR Insight explains the Energy Labelling framework, its relationship with Ecodesign, product classification, energy-efficiency classes, testing, EPREL registration, supplier and dealer responsibilities, technical documentation and the practical pathway to EU market compliance.
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Explore the Energy Labelling framework, efficiency classes, product information, testing, EPREL registration and the relationship between labelling and Ecodesign compliance.
Understanding Regulation (EU) 2017/1369
Regulation (EU) 2017/1369 establishes the European framework for energy labelling of energy-related products and replaced the earlier framework under Directive 2010/30/EU.
Its objective is to enable customers to compare the energy efficiency and other relevant performance characteristics of products using standardised information.
Which Products Require Energy Labelling?
Energy Labelling requirements apply through product-specific delegated legislation rather than through a universal label requirement for all products that consume energy.
Manufacturers and importers should therefore begin by determining whether the exact product category is covered by an applicable Energy Labelling measure.
Household Appliances
Refrigerators, washing machines, dishwashers and certain other household appliances can be subject to dedicated labelling rules.
Lighting Products
Applicable light sources are subject to prescribed energy-performance and labelling information.
Electronic Displays
Televisions, monitors and other covered displays can require energy labels and supporting product information.
Heating Equipment
Certain space heaters, combination heaters and related systems are subject to product-specific energy-labelling measures.
Water Heating
Water heaters, storage tanks and relevant packages can fall within specific labelling requirements.
Other Regulated Products
Additional product groups can be brought within the Energy Labelling framework through dedicated delegated legislation.
Ecodesign vs Energy Labelling
Ecodesign and Energy Labelling are closely connected but serve different regulatory purposes.
Ecodesign
Establishes mandatory product design, energy-performance and, increasingly, environmental requirements that applicable products must satisfy before being placed on the European market.
Energy Labelling
Communicates standardised efficiency and product-performance information so customers can compare products within the same regulated category.
Understanding the A-to-G Energy Scale
The modern EU Energy Label uses a clear efficiency classification intended to make performance comparison easier for customers.
For product groups that have been rescaled, classes generally run from A through G. The applicable delegated regulation determines the exact calculation methodology and class boundaries.
Class A
Represents the highest efficiency class available under the applicable product-specific scale.
Intermediate Classes
B through F provide graduated performance categories based on the relevant efficiency index or calculation methodology.
Class G
Represents the lowest class within an applicable A-to-G scale.
Product-Specific Calculation
The energy class cannot be selected subjectively; it must result from the method prescribed by the applicable regulation.
What Does the Energy Label Communicate?
The information appearing on an Energy Label depends on the product category. In addition to the efficiency class, the label can contain product-specific performance information relevant to purchaser comparison.
Supplier & Model
The label connects the declared performance with an identifiable supplier and product model.
Energy Class
The applicable efficiency rating is displayed according to the prescribed classification scale.
Energy Consumption
Applicable labels can include annual, cycle-based or other standardised energy-consumption values.
Capacity
Refrigeration volume, load capacity or other relevant product capacity may be displayed.
Noise
Acoustic performance information can be included for applicable product categories.
QR Code
Modern rescaled labels can provide digital access to product information associated with the EPREL database.
Testing, Measurement & Calculation
The declared energy class must be supported by measurements and calculations performed according to the methodology applicable to the relevant product group.
Energy Consumption
Electrical or fuel consumption is measured under the operating conditions defined by the applicable methodology.
Efficiency Index
Certain products use calculated efficiency indices to determine the appropriate energy class.
Functional Performance
Capacity, washing performance, cooling performance or other functional parameters may influence the assessment.
Standby Consumption
Low-power operating modes may form part of the regulated energy-performance assessment.
Acoustic Performance
Where required, airborne noise emissions may also be measured and declared.
Representative Model
The product used for evaluation must appropriately represent the model or model family placed on the market.
EPREL Registration
EPREL — the European Product Registry for Energy Labelling — is the European database established to support implementation of the Energy Labelling framework.
For models subject to applicable Energy Labelling registration requirements, suppliers must complete the required product registration before placing the first unit of the model on the Union market.
Supplier Identification
The relevant economic operator must be correctly established and, where required, verified within the EPREL system.
Model Registration
Each regulated model must be entered according to the applicable EPREL data requirements.
Label & Product Sheet
Required energy-labelling documentation is connected with the registered product model.
Technical Information
Required technical data supports regulatory and market-surveillance access to product information.
Supplier Responsibilities
Under the Energy Labelling framework, suppliers have central responsibilities for ensuring that regulated products are accompanied by correct labels and product information.
Dealer Responsibilities
Dealers play an important role because the purpose of Energy Labelling is to ensure that relevant information is visible to customers when making purchasing decisions.
Label Display
Required energy labels should be displayed correctly at the point of sale in accordance with the applicable requirements.
Customer Information
Required supplementary product information should be available to purchasers.
Advertising
Energy-related information may need to appear in promotional materials where required by applicable legislation.
Online Sales
Digital product listings must also satisfy relevant energy-label display and product-information requirements.
Technical Documentation Behind the Energy Label
The information displayed to customers should be supported by a coherent technical evidence package demonstrating how each regulated value was established.
Online, Distance Sales & Digital Product Information
Energy Labelling requirements are not limited to physical retail environments. Products sold online or through other distance-selling channels may also need prescribed energy information presented to the customer before purchase.
E-Commerce Listings
Relevant product pages should display required energy information according to the applicable legislation.
Visual Energy Class
Digital display rules can prescribe how the energy class and label are presented.
Product Sheet Access
Customers should be able to access required product information where applicable.
Consistent Model Data
Online specifications should correspond with the registered and technically supported product model.
Market Surveillance & Verification
Energy labels rely on declared technical values, but those declarations must remain capable of verification by competent authorities.
Market-surveillance activity can involve review of documentation, product information, EPREL data and testing of representative products against prescribed verification procedures.
Documentation Review
Authorities can examine the evidence supporting declared performance and classification.
Product Testing
Representative products can be independently tested according to applicable verification procedures.
EPREL Comparison
Registered product information can be compared with the product actually supplied to the market.
Corrective Action
Significant discrepancies can lead to required corrections, restrictions or other enforcement measures under applicable law.
Common Energy Labelling Compliance Mistakes
Assuming Every Product Needs a Label
The manufacturer fails to determine whether a current product-specific delegated act actually applies.
Using an Obsolete Label
An earlier label scale or outdated product-specific format continues to be used after regulatory changes.
Wrong Energy Class
The declared class is not calculated according to the applicable regulatory methodology.
Incorrect Test Method
Testing is carried out under conditions that do not correspond with the required method.
Missing EPREL Registration
A regulated model is placed on the Union market without completing applicable registration requirements.
Inconsistent Product Data
Different performance values appear on the label, technical file, product sheet and EPREL entry.
Ignoring Online Sales
Energy information is correct on the physical product but absent or incorrect in digital sales channels.
Confusing CE Marking & Energy Labelling
The manufacturer incorrectly treats the Energy Label as evidence replacing the broader CE conformity process.
From Product Classification to EU Market Placement
An effective Energy Labelling compliance programme should establish the applicable product legislation and technical methodology before preparing labels or registering product data.
Define Product
Establish model, function, intended use and technical configuration.
Classify Product
Determine the applicable European product category.
Identify Labelling Rules
Determine whether an Energy Labelling delegated act applies.
Check Ecodesign
Identify related minimum performance and design requirements.
Select Test Methods
Establish applicable standards and regulatory measurement methods.
Test Product
Generate representative technical performance data.
Calculate Energy Class
Apply the prescribed efficiency classification methodology.
Prepare Product Sheet
Compile prescribed product and performance information.
Prepare Energy Label
Generate the correct label using validated model data.
Register in EPREL
Complete required supplier and model-registration processes.
Verify Sales Information
Check physical retail, advertising and online product information.
Place on Market
Supply the product once applicable labelling and wider EU conformity requirements have been fulfilled.
From Technical Performance to Transparent Energy Information
Energy Labelling has transformed complex technical product-performance information into a format that customers can understand and compare. Behind that apparently simple label, however, sits a detailed conformity structure involving product classification, testing, calculation, technical documentation and regulatory data management.
Regulation (EU) 2017/1369 provides the overall framework, while product-specific delegated acts determine which products are covered, how performance must be measured and which information must be provided.
The Energy Label must also be considered together with Ecodesign requirements. Ecodesign determines whether applicable products satisfy mandatory market-entry requirements, while Energy Labelling communicates comparative product performance to purchasers.
EPREL adds another important layer by connecting regulated product models with a European product database. The supplier must therefore maintain consistency between the physical product, laboratory evidence, efficiency calculations, technical documentation, label, product-information sheet, EPREL registration and sales information.
The Technical Question
Can every performance value displayed on the Energy Label be traced back to the applicable regulatory methodology, representative testing and controlled technical evidence?
The Market Question
Does the product information visible in EPREL, retail stores, advertising and online sales channels accurately represent the regulated product being supplied?