The EU energy label for smartphones and tablets explained

Which devices are covered

The rules apply to smartphones, other mobile phones, cordless phones, and slate computers. The latter is the legal term for a tablet without a fixed keyboard. The boundary between these categories is determined by the screen diagonal, not by the brand name or the price range of the device.

A smartphone has a visible screen surface with a diagonal of at least 10.16 centimeters and at most 17.78 centimeters, i.e., 4 to 7 inches. A slate computer is between 17.78 and 44.20 centimeters, i.e., 7 to 17.4 inches. Furthermore, it must not have a fixed keyboard in its design configuration.

Devices with a flexible main screen that the user can unroll and roll up fall outside the regulation. Smartphones for high-security communication are also excluded. Note that a foldable screen is different from a rollable screen.

A tablet with a keyboard is excluded

The definition requires that the device, in its design configuration, does not have an integrated, physically attached keyboard. If you supply a tablet with a fixed keyboard as standard, it falls outside this regulation. A separate magnetic keyboard as an accessory is different from a fixed attachment.

What is on the label

The label shows the energy efficiency class of the device plus four sustainability metrics. These are the battery life per charge, drop resistance, protection against dust and water, and a repairability class. As such, it is no longer a pure energy label, but primarily a sustainability label for the consumer.

This changes what the label means for your marketing. Two devices with the same energy consumption can differ significantly in drop resistance or repairability. That difference is now displayed next to the price on your product page.

The design requirements behind the label

In addition to the label, ecodesign requirements apply to the product itself. The most well-known is battery longevity. Devices must still have 80% of their capacity after at least 800 cycles. This is tested under charging conditions where the battery management system limits the charging speed rather than the power supply.

Furthermore, requirements apply to protection against dust and water, screen scratch resistance, and drop resistance. For mobile phones, this means protection against the ingress of solid objects larger than 1 millimeter and against splashing water. For slate computers, the requirement is resistance to accidentally spilled water.

This is the part that is most often underestimated. You can have a label created, but the product itself must meet these requirements. If it does not comply, no amount of registration will help.

Seven years of spare parts

Manufacturers, importers, and authorized representatives shall make spare parts available to professional repairers for at least seven years after the date the product was last placed on the market. This period therefore continues after you have discontinued the model.

The list is specific and includes, among other things, the battery, the front and rear camera assemblies, and the external audio connections, including fasteners when they are not reusable.

For an importer, this is an obligation with a long tail. If your supplier stops producing a part, your obligation remains. Therefore, establish that availability contractually before you begin.

Does your device fall under these rules?

Briefly provide the type of device and the screen size. We will contact you regarding what applies to you.

What your webshop must display

For distance selling, the label must be visible near the price. An energy arrow with a link to the full label and the product information sheet is permitted. That display must then comply with the regulations in the annex of the labeling regulation itself.

It is therefore not just about presence, but about placement. A label at the bottom of the page or hidden in a specifications tab does not meet the requirement of being visible near the price.

Registration in the European product database also remains a condition for market access. How this registration works is explained in our article on EPREL.

What you need to have tested

The values on the label must be supported by actual measurements. This means tests on battery life per charge, battery longevity in cycles, drop resistance, protection against dust and water, and all data that together determine the repairability class.

Battery longevity in cycles. The 800 cycles with 80% remaining capacity, under the prescribed charging conditions.
Battery life per charge. Determines the class that the consumer sees on the label.
Drop resistance. Is expressed in a class and requires a series of drop tests.
Dust and water. Tested against the requirements of the regulation, resulting in an IP rating.
Repairability. Based on, among other things, the availability of parts and the disassembly steps.

These measurements are compiled in your technical documentation and must match what you enter into the database and what is shown on the label. Market surveillance usually begins with that comparison.

What you need to arrange

First, determine whether your devices fall within the definitions, as the screen diagonal and the keyboard are decisive. Then, have tests conducted on the points that populate the label. Finally, establish how you will ensure seven years of spare parts with your supplier.

Measure the screen diagonal and check if there is a fixed keyboard. This determines whether the device is covered.
Request the test reports for battery cycles, drop resistance, and protection against dust and water from your supplier.
Establish contractually that spare parts will remain available for seven years, even after phasing out.
Register the model in the database before you start selling.
Check on your product page whether the label is near the price and if the link works.

Frequently Asked Questions

Does my tablet with a keyboard fall under this?

Probably not. The definition of a slate computer requires that the device, in its design configuration, does not have an integrated, physically attached keyboard. If you supply a fixed keyboard as standard, the device falls outside this regulation. A separate accessory is different.

What exactly does the 800-cycle requirement entail?

The device must still have 80% of its capacity after at least 800 full charging cycles. The test is conducted under charging conditions where the battery management system limits the charging speed, not the power supply. This is a design requirement, not a label value.

For how long must I supply spare parts?

Until at least seven years after the date the product was last placed on the market. This period therefore continues after you have discontinued the model. You should therefore establish availability contractually with your supplier before you begin.

Does the label also apply to sales to businesses?

The obligation is linked to the placing on the market and the offering on the European market, not to the type of customer. If you offer the product in the EU, the requirements for registration, labeling, and documentation apply regardless of the sales channel.

May I use an energy arrow online?

Yes, for distance selling, an arrow may be displayed, provided it complies with the regulations in the annex of the labeling regulation and links through to the full label and the product information sheet. The arrow must be placed near the price.

Does this also apply to refurbished devices?

That depends on the route. If you bring a device in from outside the EU or if it has been substantially overhauled, it is considered placed on the market again and the requirements apply. For resale within the EU of a device that was already lawfully on the market, the situation is different.