How to Comply with the EU Energy Labeling Requirements in 2022

This article describes everything you need to know about the EU energy labeling requirements and regulations. Read on if you want to learn more about the Ecodesign directive and energy labeling regulations, know how to comply with the EU requirements on energy labeling, how to create your energy label and how to register your product.


Ecodesign directive (2009/125/EC)

The Ecodesign directive was introduced in 2009 in order to establish ecological requirements for energy-related products placed on the market of the European Union.

The directive lays out requirements for manufacturers, their authorised representative and importers concerning energy consumption and the environmental impact of their products.

The aim of the Ecodesign directive is:

  • to stimulate sustainable market development by increasing product energy efficiency;
  • to minimize the environmental impact of products placed on the EU market;
  • to ensure a continuous availability of energy supplies.

A variety of these goals can be achieved by taking into account energy-related factors in the design and consideration of the life cycle of the product.

The directive provides guidance through which these goals can be achieved, which includes:

  • Set requirements of the directive related to product design, taking into account environmental impact;
    • Raw material selection, predicted future material consumption;
    • Manufacturing choices, the amount of waste and emissions generated through manufacturing;
    • Packaging, transport and distribution;
    • Installation and maintenance.
  • Requirements that consider the supply of information from market operator to consumer;
    • Providing consumers information on environmental characteristics and the energy-related performance of the product;
    • Obligations for market operators to provide information on spare parts available for their products. This may be required for years on end, even if the production of the product has been discontinued.
  • Requirements for manufacturers which shall be considered during the product’s design;
    • Product-life-cycle assessment, with a consideration of the product’s environmental impact and its ecological profile;
      • Using this assessment to make the appropriate design solutions whilst maintaining a balance between relevant environmental aspects and other considerations, such as functionality, consumer safety and health, and economic aspects including costs related to manufacturing costs and the marketability of the product.

The scope of the directive covers more than 40 product groups for which energy-related requirements have been laid out. The directive also forms a part of the new approach directives and is part of legislation requiring CE-Marking.

A product that falls within the scope of the Ecodesign directive must therefore fulfill the essential requirements of the directive in order for it to be legally CE-marked.

What do EU energy labels mean?

Regulation (EU) 2017/1369 on energy labeling

The EU Energy Label provides for a clear rating on the energy-related performance of product groups. The performance is related to the energy consumption of the product, but also to other consumed resources, such as water, depending on the product group.

The rating is provided in the form of energy efficiency classes, which range from A to G, with A being the most energy efficient and G the least.

The label was first introduced in 1994 for household refrigerators and freezers. Its scope was later expanded through the addition of washing machines and tumble dryers in 1995.

Nowadays, many more product groups are required to be supplied with energy labels and comply with the applicable regulations.

The aforementioned energy label scaling metrics were rescaled under Regulation (EU) 2017/1369 for 15 product groups, including appliances such as washing machines and refrigerators.

It re-introduced the A-G scale and eliminated any energy labels with a greater rating (A+ – A+++). Due to fast paced innovations being introduced, most appliances (90%) were rated A+ or higher by 2017, leaving the only options to introduce even greater rated labels, or rescale the existing system.

By 2nd August 2023, rescaling must have taken place for all product groups requiring an energy label.

Certain appliances that received these new ratings through rescaling are now also provided with a QR-code. Consumers can use this to find more specific details on the performance of the product than the Energy Label provides.

Why do manufacturers use energy labels?

Consumers are constantly seeking ways to reduce costs within their household, especially for products that are used on a day-to-day basis. Energy labels should therefore serve as a means for consumers to identify energy-efficient products and thus make comparisons between appliances with regards to their energy-related performance.

A 2019 Eurobarometer study revealed that 93% of the EU population recognized the energy label and for 79% it influenced their choice of purchase, further showing consumer interest in the energy related performance of their household appliances.

The official website of the European Union provides information on energy savings relating to households and the environment. Here for instance, is a case example applicable to fridges and freezers:

‘’By switching to more energy efficient refrigerating appliances, you can save up to €200 over the lifetime of an average product. More efficient refrigerating appliances will also allow Europe to save up to 9.6 TWh of electricity per year by 2030. This is close to the annual household electricity consumption of Lithuania, and will prevent around 3.1 million tonnes of CO2 from being emitted every year.’’

By manufacturing products that are increasingly energy-efficient, product manufacturers are also able to gain a competitive advantage over other suppliers in their field. This creates an environment in which manufacturers develop more and more innovative technologies in order to provide the consumer with the most energy-efficient appliance.

Lastly, as sustainability and Corporate Social Responsibility (CSR) are becoming increasingly emerging topics, market operators are able to use adequate energy performance results to further benefit the marketing of their products.

Energy label classification

What products require an energy label?

As mentioned earlier, legislation for many product groups requires the providing market operator to supply an energy label with them.

The EU Energy Labeling Framework Regulation (2017/1369) requires the following product groups to be supplied with an energy label:

  • Air conditioners
  • Cooking appliances (domestic)
  • Dishwashers (household)
  • Heaters (space and water heaters)
  • Light bulbs and lamps
  • Local space heaters
  • Fridges and freezers (household)
  • Refrigeration (professional)
  • Refrigeration with a direct sales function
  • Solid fuel boilers
  • Electronic displays including televisions
  • Tumble driers
  • Ventilation units (residential)
  • Washing machines (household)
  • Tires


What information can be found on an energy label?

First of all, the energy label displays the energy efficiency class of a product.  In addition to this, the energy label states the product’s energy consumption.

Often, the labels also provide specific data about other relevant features of usage, such as the product’s noise level or water consumption.

EU Energy labeling requirements

Is the energy label mandatory?

Certain product groups are required to carry an energy label in order to be placed on the EU market.

These product groups have an applicable regulation, which inherently is a binding legislative act. Once your product falls within the scope of an applicable Energy Labeling Regulation, the enclosure of the EU Energy Label becomes mandatory.

Furthermore, the European Energy Labeling Regulation is derived from the Ecodesign directive (2009/125/EC), which is a CE-Marking directive. Products that are subject to energy labeling requirements should therefore be provided with an Energy Label in order to be legally CE-Marked.

The applicable regulation and standard(s) that were used to perform the conformity assessment of the product should also be listed on the EU Declaration of Conformity.

How to create an energy label with the Energy Label Generator

As a simplified alternative for manufacturers to create their own energy label, the EU Commission created the EU Energy Label Generator. The tool allows manufacturers to generate energy labels without having to design these themselves.

Before you start the process of creating an energy label, you must make sure you comply with the essential requirements of the Ecodesign directive. Furthermore, you must comply with the specific requirements of the applicable energy-performance related regulation.

These regulations require you, or another party that can facilitate testing, to perform tests on energy performance according to standards referenced in the legislation. The results of these tests are used as input for the content of the energy label.

These tests do not necessarily require an assessment by an independent notified body and therefore can be conducted through self assessment.

An energy label is created as follows:

  1. Select the product category that corresponds with the product that you will be placing on the EU market.
  2. In case it is applicable, select the sub-category that corresponds with your product.

Note: Before proceeding to step three, please make sure that the product you will be selling is included in the scope of the product group. In case of any doubt, open up the corresponding legislation and use CTRL + F followed by the word ‘scope’ to find out which products are exactly included in the scope.

  1. Provide the requested information which will be displayed on your European Energy Label.

The EU commission still allows manufacturers to create their own energy label and upload it into the EPREL Database.

A key difference between both methods of creating the energy label is that the Energy Label Generator does not allow users to upload their own trademark or logo for inclusion in the Energy Label.

In order to create an energy label including either of these, the user is required to design it themselves. Regulation (EU) 2017/1369 allows for the inclusion of a custom trademark or logo.

Displaying the energy label

The EPREL Database and how to register an energy label

On 1 January 2019, the requirements under Regulation (EU) 2017/1369 were increased.

Manufacturers and importers became required to register energy labels for their products in the online database ‘European Product Registry for Energy Labeling’ (EPREL).

EPREL serves as a product database to be consulted by consumers, traders and market surveillance authorities for energy-related products.

Whereas these products were originally solely accompanied by a physical energy label and product data sheet (fiche), the EPREL database adds a digital option to communicate data on energy-related performance to potential consumers.

Before you start the process of registering an energy label, you must make sure you comply with the essential requirements of the Ecodesign directive.

Furthermore, you must comply with the specific requirements of the applicable energy-performance related regulation. These regulations require you, or another party that can facilitate testing, to perform tests on energy performance according to standards referenced in the legislation.

The results of these tests are used as input for the content of the energy label. These tests do not require a mandatory assessment by an independent notified body and therefore can be conducted through self assessment.

To register a product in the EPREL Database contact us or do the following:

  1. Access the EPREL Registration Portal and create an EU Login (in case you haven’t created a profile yet)
  2. Register your organization
  3. Select the applicable product group
  4. Provide the requested information on energy-related parameters, which has already been used to create your energy label
  5. Create the corresponding energy label and enclose this physically with the related products

As established in the section How to create an EU Energy Label, it is important for you to determine the correct product group by checking the scope of a group-specific Energy Labeling Regulation.

Certain product groups have sub-categories, so it is important to determine the correct product category here as well. Again, the applicable regulations will provide information on the correct sub-category.

The development of energy labeling requirements is ongoing. New product groups are identified and are made part of the scope of the Ecodesign directive. In order to ensure that your products are compliant with this regulation it is important to stay up-to-date with the latest amendments made regarding ecodesign.
Do you require any assistance with the registration of your products in EPREL, or would you like the registration to be performed by an experienced party? 24hour-AR can help. Do not hesitate to contact us


By Ferry | April 21, 2022
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