Many everyday products such as washing machines, refrigerators and cooking appliances carry energy labels and have been designed to meet minimum energy efficiency standards.
EU Requirements: Regulation 2017/1369 (the EU “Energy Labeling Regulation”) sets out a framework of rules that apply in the UK for providing information relating to the energy efficiency, the consumption of energy and other resources as part of a product label. The objective of the EU Energy Labeling Regulation is to enable customers to choose products that are more efficient in order to reduce their energy consumption.
It is your responsibility to comply with the EU Energy Labeling Regulation when selling relevant products in the EU. You must also comply with other national requirements in the Member States in which you sell these products.
Please see below for further information about EU requirements.
From 1 January 2021 energy labeling in the UK as a result of the Ecodesign for Energy Related Products and Energy Information Amendment EU Exit Regulations 2019 (the “UK Energy Information Regulations”) under a framework of rules that apply in the UK for providing information, an amended version of Regulation 2017/1369 (the “EU Energy Labeling Regulation”) relates to the energy efficiency, the consumption of energy and other resources as part of a product label. Different rules apply to goods you sell in: (1) Great Britain (England, Scotland and Wales); and (2) Northern Ireland.
It is your responsibility to comply with the UK requirements if you are selling relevant products in the UK. If you also sell such products on Amazon EU website(s), then you must also comply with the EU Energy Labeling Regulation and with other national requirements in the countries in which you sell these products.
Please see below for further information about UK requirements.
This material is for informational purposes and you should not take it as a substitute for legal advice. We encourage you to consult your legal counsel for any concerns about the laws and regulations concerning your product. This material only reflects the position at the date of writing and requirements across the EU and in the UK may change. You should refer to current UK Brexit guidance about your products (see below) to learn more about changes that may affect you from 1 January 2021.
The EU Energy Labeling Regulation apply to “energy-related products”, these are products which have an impact on energy consumption during use, which are sold to consumers or used in the EU.
Examples of energy-related products are: air conditioners and comfort fans, air heating and cooling products, lighting, televisions, tumble driers, computers, power transformers, vacuum cleaners, external power supplies and fridges.
The EU Energy Labeling Regulation does not apply to second hand products, unless the second hand product is imported from outside the EU.
The EU Energy Labeling Regulation sets out obligations for suppliers and dealers.
You are a “Supplier” if you are a manufacturer established in the EU, the authorized representative of a manufacturer who is not established in the EU, or an importer who makes a product available for sale/supply in the EU.
You are a “Dealer” if you offer energy-related products for sale, hire, or hire purchase, or display energy-related products to customers or installers in the course of a commercial activity, whether or not in return for payment.
All energy-related products must display labels on a scale from A (most efficient) to G (least efficient). Please note this A-G scale replaces a previous scale of A+++ to G labels that was used before 2017. Labels from before 2017 will be “rescaled” to the new scale over time.
Energy-related products must be accompanied by a product information sheet. For certain product types, there are specific regulations relating to energy labeling (including televisions, computers and services, and tumble dryers., amongst others).
Suppliers of energy-related products must: generally take the following steps. Additional requirements may apply for certain products – you should always consult the specific regulations and relevant delegated acts.
Dealers of energy-related products must: generally take the following steps. Additional requirements may apply for certain products – you should always consult the specific regulations.
If you are a supplier or a dealer, you must both cooperate with the authorities to remedy any non-compliance and also take action at your own initiative to do so.
We strongly encourage you to visit the European Commission’s website for more information on energy labeling requirements:
The EU Energy Labeling Regulation and UK Energy Information Regulations apply to “energy-related products”, these are products which have an impact on energy consumption during use, which are sold to consumers or used in the UK, but the provisions apply differently to Great Britain (England, Scotland and Wales, “GB”) and Northern Ireland. You can read more about the position in Northern Ireland (“NI”) below.
Examples of energy-related products are: air conditioners and comfort fans, air heating and cooling products, lighting, televisions, tumble driers, computers, power transformers, vacuum cleaners, external power supplies and fridges.
The legislation does not apply to second hand products, unless the second hand product is imported from outside the EU or UK).
The EU Energy Labeling Regulation and UK Energy Information Regulations set out obligations for suppliers and dealers.
You are a “Supplier” if you are a manufacturer established in the UK, the authorized representative of a manufacturer who is not established in the UK, or an importer who imports a product from outside GB. For details of importing into NI, see the “Northern Ireland” section below.
You are a “Dealer” if you offer energy-related products for sale, hire, or hire purchase, or display energy-related products to customers or installers in the course of a commercial activity, whether or not in return for payment.
All energy-related products must display labels on a scale from A (most efficient) to G (least efficient). Please note this A-G scale replaces a previous scale of A+++ to G labels that was used before 2017. Labels from before 2017 will be “rescaled” to the new scale over time. This change will still be implemented in the UK after Brexit as planned.
Energy-related products must be accompanied by a product information sheet. For certain product types, there are specific regulations relating to energy labeling (including televisions, computers and services, and tumble dryers, amongst others).
Suppliers of energy-related products must generally take the following steps. Additional requirements may apply for certain products – you should always consult the specific regulations.
Dealers of energy-related products must generally take the following steps. Additional requirements may apply for certain products – you should always consult the specific regulations.
If you are a supplier or a dealer, you must both cooperate with the Office for Product Safety and Standards, Trading Standards (in Great Britain) and the Department for the Economy (in Northern Ireland) to remedy any non-compliance and also take action at your own initiative to do so.
Northern Ireland
Please note that different rules apply in NI from 1 January 2021 as a result of the Northern Ireland Protocol. In particular:
Authorized representatives can be based in NI or the EU. From 16 July 2021, new rules come into force under EU Regulation 2019/1020 and some businesses may need to appoint a responsible person in the EU or NI to carry out compliance functions (if there is no other entity in the supply chain who is able to carry out the functions). Further guidance on the new rules will be made available by the UK Government.
BREXIT: UK Government Guidance
The UK Government has released guidance on selling products in GB and NI from 1 January 2021. This guidance provides information for suppliers and dealers regarding compliance requirements, including on:
We encourage you to review this guidance (linked below), alongside any other specific UK Government guidance that applies to your product. You should consult your legal counsel if you have questions about how the laws and regulations apply to your products from 1 January 2021.
The Brexit guidance for GB and NI can be found here:
We strongly encourage you to review UK Government guidance for more information on energy labelling requirements:
We also encourage you to review UK Government Brexit guidance on ecodesign and energy labelling compliance requirements from 1 January 2021:
More information on UK product compliance rules can be found on the Business Companion website: