EPREL: who must register and when?

What EPREL is

EPREL is the European Product Registry for Energy Labelling, established under Regulation (EU) 2017/1369. It consists of a public part, a compliance part for market surveillance authorities, and a portal providing access to both parts. The database does not replace market surveillance but supports it.

The compliance part is particularly relevant for you. It contains the data that the regulator uses to check whether your label matches your technical documentation. Therefore, what you enter there must correspond with what you record elsewhere.

The public part feeds, among other things, the energy labels that consumers see. If someone looks up your model, they will find the data you entered yourself.

Who registers and when

The obligation lies with the supplier, meaning the manufacturer or the party placing the product on the EU market under their own name. They enter the data before placing a unit of a new model on the market. Not afterwards and not at the time of the first sale.

This sequence is strict. You may not place a product on the market if the model is not in the database. Registration is therefore not administrative aftercare but a condition for market access.

If you import under your own brand, you are the supplier and therefore the one who registers. Your Chinese manufacturer cannot do this for you, as they are not placing the product on the EU market.

Which products it applies to

Only for product groups for which a delegated act prescribes an energy label. Examples include refrigerating and freezing appliances, washing machines, dishwashers, tumble dryers, televisions, light sources, and tires. Since June 20, 2025, smartphones and tablets also fall under a label. Consequently, they are also subject to the registration obligation.

There is no energy label for laptops. This is often assumed otherwise, likely because laptops and tablets are often in the same product range. No label means no registration obligation.

Even within a product group, a portion may fall outside the labelling requirement. For example, local space heaters are excluded from the labelling regulation for space heaters. For those devices, there is no energy label and no EPREL registration, even though ecodesign requirements do apply.

What your webshop must display

The dealer shall display the label visibly, explicitly including online distance selling. In addition, they shall make the product information sheet available to the customer at the point of sale. If the customer requests it in physical form, that must also be possible for them.

This makes your product page a checkpoint. The label must be visible there, not hidden behind a tab or only in the specifications. If you do not have the label, you must request it from the supplier.

If the product information sheet is also missing, you can download it from the database when that function is available for the product concerned. This is useful for ranges that you source from multiple suppliers.

When a change creates a new model

A product to which changes are made that are significant for the label or the product information sheet is considered a new model. This means a new registration with its own data. It is therefore not an adjustment of the existing entry in the database.

Think of a modified compressor, a different motor, or an adjustment that affects consumption or the performance class. The question is not whether the article number changes, but whether the label changes.

There is another obligation that is almost always forgotten: you must indicate in the database when you are no longer placing units of a model on the market. A database full of models you haven’t sold for years is a signal that records are not being maintained.

What goes wrong in practice

Four problems recur constantly for us. Registration after the fact instead of beforehand. Data in the database that deviates from the technical documentation. A label that is not visible online. And models that simply remain in the database after being phased out.

• Registering too late. The obligation applies before placing on the market. If you are already selling, you are too late and not ‘almost finished’.
• Deviating data. The values in the database must match the label and your documentation. Surveillance often begins precisely with that comparison.
• Label not visible online. A label that only appears after three clicks does not meet the requirement for visible display.
• Old models remain listed. The end of sales should be reported in the database.

What you need to arrange

First, determine if a delegated act with an energy label exists for your product group. If so, register before selling and ensure that the entered values match your label and your documentation. Then check your own product pages for label visibility.

1. Find out per product group whether an energy label applies. No label means no registration obligation.
2. Determine who the supplier is. If you sell under your own brand, it is you.
3. Register before the first unit goes on the market, not after.
4. Compare the entered values with the label and with your technical documentation.
5. Check ten product pages to see if the label is visible and the information sheet is available.