8 Feb 2019
Suppliers Required to Register in European Product Database for Energy Labelling
The European Commission has announced that suppliers – manufacturers, importers or authorised representatives – need to register their appliances, which require an energy label, in the European Product Database for Energy Labelling (EPREL), before selling them on the European Union market. A range of data and documentation will need to be uploaded into the database, for all products that are subject to EU energy labelling rules. The product database will serve the following purposes: to support market surveillance authorities, including inspection and enforcement actions; to provide the public with information about the products and their energy labels; and to provide the Commission with up-to-date energy efficiency information for products for reviewing energy labels. The database has a public part that can be accessed by anyone, and a compliance part that can be accessed by the authorities.
Hong Kong sellers of household electrical appliances such as washing machines, dryers and refrigerators will recall that the energy labelling requirements for individual product groups have been created under the EU's Energy Labelling framework Regulation (2017/1369). The legal basis for the development of the product database stems from this Regulation on Energy labelling, and the database is said to have started applying from 1 January 2019. The Energy Labelling Regulation 2017/1369 itself resulted from a revision of the previously existing Directive 2010/30/EU.z
Regulation 2017/1369 makes reference to the obligations of the supplier. The supplier is defined as “a manufacturer established in the Union, the authorised representative of a manufacturer who is not established in the Union, or an importer, who places a product on the Union market”. Thus, in the case of Hong Kong sellers, the supplier for the purposes of registration would be either the importer of electrical appliances or else the Hong Kong manufacturer’s authorised representative in the EU.
For products placed on the EU market between 1 August 2017 and 1 January 2019, the registration by the suppliers can be done until 1 July 2019. For products placed on the EU market before 1 August 2017, registration is carried out on a voluntary basis.
Product information to be entered in the database relates to the energy label, technical documentation and compliance information. Prior to registration, suppliers will have to create an EU login account. The EPREL guidelines explain how to register as a new supplier-user and how to upload product models in the database.
According to a European Commission announcement, the label generator is an easy-to-use tool for creating a tailor-made energy label for a product in high-resolution pdf format, for printing or online publication.
The following product groups are subject to registration:
- Air conditioners
- Cooking appliances (domestic)
- Dishwashers (household)
- Heaters (space and water heaters)
- Local space heaters
- Refrigerating appliances (household)
- Refrigeration (professional)
- Solid fuel boilers
- Tumble dryers
- Vacuum cleaners
- Ventilation units (residential)
- Washing machines (household)
As for the data that needs to be uploaded, Article 12 and Annex I of Regulation 2017/1369 specify what the database should look like, and which data will need to be uploaded to it. The database consists of a public part, a compliance part and an online portal giving access to those two parts. For suppliers, the following is required:
- the name or trademark, address, contact details and other legal identification of the supplier (public part);
- the model identifier (public part);
- the label in electronic format (public part);
- the energy efficiency class(es) and other parameters of the label (public part);
- the parameters of the product information sheet in electronic format (public part);
- the model identifier of all equivalent models already placed on the market (compliance part);
- the following technical documentation (compliance part):
- a general description of the model, sufficient for it to be unequivocally and easily identified;
- references to the harmonised standards applied or other measurement standards used;
- specific precautions that shall be taken when the model is assembled, installed, maintained or tested;
- the measured technical parameters of the model;
- the calculations performed with the measured parameters;
- testing conditions if not described sufficiently in another point.
Customers using the public part of the product database must be able to easily identify the best energy class populated for each product group, allowing them to compare model characteristics and to choose the most energy-efficient products.
Customers will be able to search the EPREL database for energy labels and product information sheets as from the second quarter of 2019.
For hyperlinks to logging in and obtaining the guidance, please see the following Commission's webpage.