COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2017/1369 and Regulation (EU) 2020/740 as regards simplification and better use of digital options for energy and tyre labelling
Date: 2026-06-24
Institutions: Directorate-General for Energy, European Commission
Subjects: European standard, consumer information, energy consumption, energy efficiency, energy saving, environmental protection, labelling, pneumatic tyre

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   EUROPEAN COMMISSION  Brussels, 24.6.2026  SWD(2026) 566 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2017/1369 and Regulation (EU) 2020/740 as regards simplification and better use of digital options for energy and tyre labelling {COM(2026) 565 final} - {SEC(2026) 565 final} - {SWD(2026) 565 final}  
 
 
EXECUTIVE SUMMARY SHEET 

Impact Assessment on the omnibus to simplify energy efficient product legislation  

A. NEED FOR ACTION 

What is the problem and why is it a problem at EU level? 

Problem 1: Overly complicated obligations for suppliers and retailers 
Four drivers underpin this problem: 1. Cumulative obligations for suppliers for labels and EPREL. 
2. Lack of flexibility: One-size-fits-all rules for label delivery and display. For tyres, the 
framework lacks flexibility to adjust certain technical details 3. Complex transition rules from old 
to rescaled labels 4. ‘Once only’ principle not fully applied for EPREL data. 
Problem 2: Persistent non-compliance 
The problem has many drivers, including external factors. The IA addresses only aspects of non-
compliance rooted in unclear legal duties and concepts. 

The rules are fully harmonised today, hence only an EU-level amendment is feasible to maintain 
uniform application. 

What should be achieved? 

General objective: Simplify and improving the energy and tyre labelling framework without 
undermining its core purpose: i.e. enabling customers to choose more efficient products and reduce 
energy consumption. 
Specific objective 1: Simplify rules for suppliers and retailers  
Specific objective 2: Improve compliance through clarifications. 

What is the value added of action at the EU level (subsidiarity)? 

EU-level simplification provides a consistent legal baseline for enforcement authorities, cost 
reductions for businesses operating across the EU and improved EPREL usability.   

B. SOLUTIONS 

What are the various options to achieve the objectives? Is there a preferred option? 

Two policy options were assessed (against a baseline of no legislative change): 

•  Policy Option 1 (13 measures): Simplifies energy label rules; clarifies legal concepts, ‘once 
only’ principle for EPREL; wider empowerment for the Commission for tyre labelling, tyre 
testing reports in EPREL’s compliance part, no more tyre label display for vehicle dealers  
•  Policy Option 2 (15 measures, preferred): Includes all measures of Option 1 and in addition 
directly amends annexes of the tyre labelling regulation with full technical specifications for 
simplified/nested tyre label display and updates information requirements for tyres for 
immediate legal effect. 

What are different stakeholders’ views? Who supports which option? 

•  Suppliers/manufacturers: Support digital-only for label delivery and ‘once-only’ EPREL–DPP 
link. Tyre industry is wary of both policy options' requirements, save for the simplified label. 

 
 
 
•  Dealers (incl. SMEs): Oppose digital labels only and shift of label printing obligation, welcome 
extended transition periods for stock sell-through. Concerned about online marketplaces vs. 
other dealers. 

•  Market Surveillance Authorities (MSAs): Support measures that improve EPREL compliance. 

Oppose digital only for labels but see merits of removing the printed label by default.  

•  Consumer organisations and NGOs: Insist on continued printed label delivery and welcome 

improving compliance. 

C. IMPACTS OF THE PREFERRED OPTION (POLICY OPTION 2) 

What are the benefits? 

•  Administrative cost savings for suppliers: Up to EUR 83 million/year from removal of printed 
label default and up to EUR 66 million one-off from ‘once only’ for EPREL; EUR 2 million 
p.a. from simplified label transitions. Vehicle dealers EUR 40 million year.  

•  Savings for dealers: EUR 3 million per label transition cycle  
•  Savings for MSAs: EUR 3.7 million/year  
•  Compliance improvements  
•  Consumer/environmental benefits: Better tyre label/EPREL usability. Customers retain right to 

have label in display at point of sale. 

What are the costs? 

•  Authorised representatives: EUR 10 million one-off to upload mandate copies into EPREL  
•  Tyre suppliers: EUR 9.6 million one-off where APIs are not used  
•  Online marketplaces: Up to EUR 2 million/year where APIs are not used 
•  Dealers: EUR 7 million/year additional cost for label printing at point of sale (but can request 

from supplier) 

What are the impacts on SMEs and competitiveness? 

Increased competitiveness due to lower compliance costs for suppliers and retailers. More SME 
dominated retail sector has right to request printed label from supplier. No significant 
trade/international impacts as labelling rules apply also to suppliers from abroad (but clearer rules 
for authorised representatives) 

Will there be significant impacts on national budgets and administrations? 

MSAs will benefit from reduced administrative costs. No need for transposition. Benchmarking 
report on ICSMS reporting. 

Will there be other significant impacts? 

Environmental impacts are insignificant compared to energy/GHG savings generated by the overall 
labelling policy. Reduced destroyed stock with old labels. Advances digital agenda. 

Proportionality 

The preferred option does not exceed what is necessary. Full digitalisation of label delivery was 
discarded. New obligations are targeted and evidence based. 

D. FOLLOW UP 

 
 
When will the policy be reviewed? 

Continuous product-specific reviews and evaluations.