REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Report on the Implementation of Regulation (EU) 2017/1369 setting a framework for energy labelling
Date: 2026-06-24
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy label, application of EU law, consumer information, database, energy consumption, energy saving, information system, labelling, market approval, market supervision

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.6.2026  COM(2026) 319 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Report on the Implementation of Regulation (EU) 2017/1369 setting a framework for energy labelling  
 
 
1. 

INTRODUCTION 

1.1. 

Policy and legal context 

The first formal EU act on consumer information about energy efficiency of appliances 
was adopted 50 years ago in the wake of the 1973 oil crisis (1). It was followed in 1979 by 
a first EU Energy Labelling Framework that was since revised and improved three times, 
last in 2017. The EU Energy Label has meanwhile become well-known and appreciated 
by consumers. A 2024 Eurobarometer (2) found that 75% of people stated that the energy 
label directly influences their purchasing decisions when buying home appliances.  

EU Energy labels provide easily understandable information to stimulate demand for, and 
development  of,  more  efficient  products.  They  work  in  tandem  with  minimum  energy 
efficiency and other requirements adopted under the EU ecodesign framework. The EU 
currently regulates over 30 product groups under ecodesign of which 15 have an energy 
label (3). Together these policies are estimated to have cut average household energy bills 
by ca. 317 EUR in 2024, set to increase to EUR 480 by 2030 with the label contributing 
an estimated average of 27 % to savings and the bulk from ecodesign (4). 

The  legal  basis  for  the  Energy  Labelling  Regulation  (5)  (“ELR”)  is  Article 194  of  the 
Treaty. The ELR sets out rules for creating product-specific labels through delegated acts. 
It  imposes  certain  obligations  on  suppliers  (manufacturers,  importers  and  authorised 
representatives) and dealers as regards the supply and display of labels and standardised 
product information. The Commission has issued two notices with specific clarifications: 
one on implementation during the COVID-19 pandemic (6) and one in 2024 on indications 
of the energy labelling range and the class following a prejudicial ruling by the Court (7). 

1.2.  Main changes in the 2017 revision of the energy labelling framework 

The 2017 revision changed the framework from a directive to a regulation and modified 
the existing rules to (i) provide for a gradual rescaling of labels to the familiar A-G scale, 
(ii)  strengthen  market  surveillance  and  (iii) introduce  mandatory  registration  in  an  EU-
wide product database (European Product Registry for Energy Labelling - EPREL(8) as a 
precondition  for placing  a model on the market.  Eight revised or new labels  have been 
introduced  under  the  new  framework.  Those  labels  are  language-neutral,  have  a 
modernised look and include a QR code linking to the model information in EPREL. Some 
for the first time include information icons on reparability or durability aspects. 

(1)  Council  recommendation  76/496/EEC  of  4  May  1976  on  the  rational  use  of  energy  for  electrical 

household appliances, OJ L 140, 28.5.1976, pp. 18–19. 

(2)   Special Eurobarometer 555 2024. 

(3)   https://energy-efficient-products.ec.europa.eu/product-list_en. 

(4)  Ecodesign  Impact  Accounting  2025  Overview  report,  https://circabc.europa.eu/ui/group/418195ae-

4919-45fa-a959-3b695c9aab28/library/c06608a7-9e47-4737-b0d2-da9aec097171/details.  

(5)  Regulation  (EU)  2017/1369 of  the  European  Parliament  and  of  the  Council  of  4 July 2017  setting  a 

framework for energy labelling and repealing Directive 2010/30/EU, OJ L 198, 28.7.2017, p. 1. 

(6)   Commission Notice 2020/C 182/02, OJ C 183, 2.6.2020. 

(7)   Case C-761/22. 

(8)   https://eprel.ec.europa.eu.  

 
 
 
1.3. 

Scope of this report 

Article 19 of the ELR tasks the Commission to submit a report on the implementation of 
the Regulation to the European Parliament and to the Council, assessing “how effectively 
this Regulation and the delegated and implementing acts adopted pursuant thereto have 
allowed customers to choose more efficient products, taking into account its impacts on 
business, energy consumption, greenhouse gas emissions, market surveillance activities, 
and the cost to establish and maintain the database”.  

Impacts on businesses, energy use and emissions are assessed in detail for each product-
specific act  under this  framework, the present  report provides an aggregate view.  More 
horizontal  aspects  are  analysed  as  part  of  the  Impact  Assessment  accompanying  the 
omnibus simplification proposal on energy-efficient product legislation adopted in parallel 
with, and informed  by, this  report.  A separate report on the implementation of the tyre 
labelling regulation (Regulation (EU) 2020/740) is adopted in parallel to the present report.  

The present report thus in particular focuses on the following topics: 

•  Progress in rescaling and introducing new labels 
•  The label rescaling process (transition from old to new label) 
•  The product database (and related cost and benefits) 
•  Market surveillance 
•  The label as tool for lead markets for efficient products 
•  Effectiveness of the new energy labels. 

1.4.  Analytical basis 

This  report notably  builds  on a survey  (9) with a sample of 20,073 consumers who had 
purchased at least one – and at most three – of the product types covered within the past 
two  years,  conducted  across  10  EU  Member  States:  Czech  Republic,  Finland,  France, 
Germany,  Italy,  Netherlands,  Poland,  Portugal,  Romania  and  Sweden.  The  survey  also 
included a sample of  204 suppliers  and 207 retailers of energy labelled  products  in  the 
product groups with the new labels, and 123 professional users of commercial refrigerating 
appliances to test the new label for these.  

Input into the present report was received from 14 Member States (10) in the Ecodesign 
and  Energy  Labelling  Consultation  Forum  (11)  (the  EELCF)  and/or  the  Administrative 
Cooperation Expert Group on energy labelling and eco design (AdCo) (12) and from 7 other 
EELCF members (13). The analysis also draws on data from EPREL, the Information and 
Communication  System  for  Market  Surveillance  (ICSMS)  (14)  and  from  other  publicly 
available analyses and resources. 

(9)  Study on consumer understanding of the EU energy labels applied since 2011. 

(10)  AT, BG, DE, DK, EE, IE, IT, LT, LV, NL, PT, SI, NO, IS.  

(11)  Register of Commission expert groups. 

(12)  List of administrative cooperation groups. 

(13)  APPLIA, Digital Europe, EHI, EHPA, EPEE, EuroCommerce, Lighting Europe.  

(14)  ICSMS.  

2 

 
 
 
 
2.  PROGRESS IN RESCALING AND INTRODUCING NEW LABELS 

The ELR tasked the Commission with reviewing and rescaling all energy labels that were 
in force on 1 August 2017 and empowered it to introduce new labels. It set out a schedule 
for  reviewing  existing  labels  by  August  2018  (starting  with  a  priority  group:  washing 
machines, washer-dryers, dishwashers, refrigerators, light sources and electronic displays). 
It set a general deadline of August 2023 for rescaling and a longer deadline of August 2025 
for solid fuel boilers, space heaters and water heaters (15). 

Rescaling of the priority group was completed in March 2019 and labels were in display 
online and in shops from 1 March 2021 (16). An omnibus regulation corrected technical 
issues with these rules just in time for that date (17). 

State of play on product-specific label reviews under the ELR  

Product group 

Reference 

Electronic 
displays 
(including 
televisions) 

Washing 
machines/ 
washer driers 

Light sources  

Household 
refrigerators  

Household 
dishwashers  

Refrigerating 
appliances  with 
direct 
sales 
function 

Smartphones 
and tablets 

Vacuum 
cleaners 

Tumble driers  

Regulation 
(EU) 
2019/2013 

Regulation 
(EU) 
2019/2014 
Regulation 
(EU) 
2019/2015 

Regulation 
(EU) 
2019/2016  

Regulation 
(EU) 
2019/2017 
Regulation 
(EU) 
2019/2018 

Regulation 
(EU) 
2023/1669 

Label 
annulled  by 
the  Court  in 
2018 

Regulation 
(EU)2023/25
34 

Review 
deadline in 
ELR 
2018-08-02 

Entry into 
force of 
review 
2019-03-31 

Status 

Date of 
application 
of new label 
2021-03-01   Adopted  

2018-08-02 

2019-03-31 

2021-03-01 

Adopted  

2018-08-02 

2019-03-31 

2021-09-01 

Adopted  

2018-08-02 

2019-03-31 

2021-03-01 

Adopted  

2018-08-02 

2019-03-31 

2021-03-01   Adopted  

New 

New 

2021-03-01 

Adopted 

New 

New 

2025-06-20 

Adopted 

- 

- 

- 

Re-introduction 
in preparation  
Have your say 

2023-08-02 

2023-11-22   2025-07-01 

Adopted  

Ovens and range 
hoods  

Regulation 
(EU) 65/2014 

2023-08-02 

- 

- 

In preparation 
 Have your say 

(15)  These deadlines should be seen as complementing the five-year review dates set out in the delegated 

acts for each product. 

(16)  The rescaled label for lighting products was on display in shops from 1 September 2021.  

(17)  Regulation (EU) 2021/340. 

3 

 
 
 
Residential 
ventilation  

Professional 
refrigerating 
storage cabinets 

Air  conditioners 
incl. 
air-to-air 
heat pumps  

Local 
heaters  

space 

and 

Space 
combination 
heaters  

Solid 
Boilers  

fuel 

Water heaters 

Regulation 
(EU) 
1254/2014 

Regulation 
(EU) 
2015/1095 

Regulation 
(EU) 
626/2011 

Regulation 
(EU) 
2015/1186 

Regulation 
(EU) 
811/2013  

Regulation 
(EU) 
2015/1187 

Regulation 
(EU) 
812/2013  

2023-08-02 

2023-08-02 

2023-08-02 

2023-08-02 

2025-08-02 

2025-08-02 

2025-08-02 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

In preparation 
 Have your say 

In preparation  
Have your say 

In preparation  
Have your say 

In preparation  
Have your say 

In preparation  
Have your say 

In preparation  
Have your say 

In preparation  
Have your say 

The  vacuum  cleaner  label  was  annulled  by  a  General  Court  ruling  in  2018 (18)  and  is 
therefore  no  longer  in  force.  Work  is  also  ongoing  on  possible  new  energy  labels  for 
(i) photovoltaic modules, (ii) vacuum cleaners, (iii) computers, (iv) low-temperature heat 
emitters (radiators), (v) professional dishwashers and (vi) professional laundry appliances.  

The review process for an EU energy label is set out in detail in the ELR and follows better 
regulation  rules.  It  involves  work  to  (i) understand  the  market  as  part  of  a  review, 
(ii) develop reproducible and representative test methodologies, (iii) collect input from the 
consultation forum and (iv) produce an evaluation and impact assessment. The draft act is 
then  published  for  feedback  from  stakeholders  and  notified  to  the  World  Trade 
Organisation.  Member  State  experts  are  consulted  before  adoption  by  the  Commission. 
The Commission notifies the act to the European Parliament and the Council. Finally, the 
act is published in the Official Journal and enters into force provided neither institution 
objects. The energy labels revised in 2019 took between four and five years from start of 
the review to publication. Since then, progress has tended to be slower because of parallel 
work on EPREL, court proceedings, emergencies linked to COVID-19 and the 2022 energy 
crisis and the renegotiation of the ecodesign framework.  

Nine decisions or communications referring to harmonised standards for presumption of 
conformity under the ELR have so far been adopted and published in the Official Journal. 

3.  THE LABEL RESCALING PROCESS 

The ELR establishes a four-month transition period when a rescaled label is introduced. 
During this period, suppliers must supply both the old label, the new label and the product 
information sheet. Dealers must replace old labels in display within 14 working days of 
the date specified in the delegated act of each product. Technical material for advertising 
must also be updated. Most dealers (63%) responding to the survey carried out in support 
of this report found the relabelling process to be easy or very easy. Some manufacturer 

(18)  Case T-544/13. 

4 

 
 
 
 
 
associations (e.g. lighting products) pointed to challenges to change labels when products 
are already in transit or were previously placed on the market.  

Consumers  may  receive  products  accompanied  with  two  labels  during  this  transition 
period, the non-rescaled and the rescaled one. These labels are rarely comparable because 
the test and calculation methods often change, and the stringency of the scale increases. 
For  example,  products  that  were  previously  A+++  may  be  rated  B  or  C  under  the  new 
scale.  The  ELR  anticipated  that  the  label  change  could  be  challenging  for  consumers, 
suppliers  and  dealers,  and  therefore  required  the  Member  States  to  launch  information 
campaigns. Some of these campaigns were organised under EU-funded projects such as 
Label2020 (19), Belt (20) and Compliance Services (21). Some Member States reported good 
outreach, whereas others pointed to the challenges faced in introducing the first rescaled 
labels due to COVID-19 restrictions.  

4.  THE PRODUCT DATABASE 

One  of  the  major  elements  in  the  2017  revision  was  a  step  forward  in  terms  of  the 
digitalisation of the EU Energy Label. Article 12 of the ELR tasked the Commission with 
setting up and maintaining a database (EPREL) with a public part, a compliance part and 
an  online  portal  giving  access  to  both  parts.  The  objectives  were  to  (i) support  market 
surveillance authorities, (ii) provide the public with information on products placed on the 
market  and  (iii) provide  the  Commission  with  up-to-date  information  for  reviewing 
labelling legislation. This database is a reality today after a major collaborative effort by 
the  Commission,  manufacturers  and  other  stakeholders,  is  populated  with  around  two 
million models and was visited 6.6 million times in 2025. 

4.1. 

Implementation 

Product registration for manufacturers was possible in time for the first reviewed labels in 
2019, with market surveillance authorities receiving access soon after. A helpdesk service 
has been available since the launch to assist with registration. EU business associations 
often help their members with this task. The public part of EPREL was accessible via QR 
codes as of March 2021 when the first rescaled product labels became applicable. Since 
2022, an EPREL search interface has offered many features (such as selection filters and 
sorting). The online portal for public access to EPREL referred to in Article 12 and Annex 
I point 2 of the ELR has been operational since April 2022 (22). 

The implementing regulation adopted in 2024 (23) sets out further operational details for 
EPREL, inter alia clarifying the rules for managing sensitive information and introducing 
mandatory verification of suppliers using e-IDAS signatures and seals. 

In implementing EPREL, the Commission aimed to: 

(19)  LABEL2020. 

(20)  BELT. 

(21)  https://www.product-compliance-services.eu. 

(22)  https://energy-efficient-products.ec.europa.eu/. 

(23)  Implementation Regulation (EU) 2024/994. 

5 

 
 
 
•  minimise the administrative burden for suppliers through bulk registrations, 

application programming interface (API) services (24) and automatic generation of 
labels and product information sheets in all official EU languages; 
facilitate compliance with obligations for online display of energy labels and 
product information (API download) 
facilitate use by individual consumers, bulk purchasers and public buyers and 
authorities to identify the most populated efficiency classes  

• 

• 

Manufacturers welcomed the fact that the product-specific delegated acts do not require 
systematic  delivery  of  printed  product  information  sheets  (under  the  alternative  option 
provided by Article 3(1) of the ELR), which instead are available via EPREL. 

EPREL also allows anyone to monitor developments in the markets for energy-labelled 
product model registrations. However, the ELR does not require suppliers to provide sales 
data for models, so additional information is usually needed to estimate the market share 
of models – and to establish whether there is a need to trigger a label review.  

National market surveillance authorities state that EPREL reduces the time and effort spent 
for compliance checking.  

The database is accessed mainly via QR codes on labels rather than through the website. 
Survey data and feedback from national authorities confirm that EPREL is not yet widely 
known by the public or public procurement buyers. Similar product databases for energy-
related products exist in other regions of the world (e.g. in the United States (25), China (26), 
Canada (27) and Australia (28).  

4.2.  Costs and benefits of EPREL 

The Commission spent EUR 9.5 million setting up and maintaining EPREL between 2017 
and  2024.  The  annual  operational  budget  increased  to  EUR 1.9 million  in  2024.  The 
anticipated  one-off  cost  of  EUR 3 million  for  setting  up  EPREL  and  the  annual 
maintenance budget of EUR 300 000 underestimated the needs. This was mainly because 
these figures were based on estimates for a radio equipment database (29) with far fewer 
registrations and registering parties and without the publicly accessible part that EPREL 
has.  EPREL  also  eventually  had  far  more  registrations  than  anticipated  in  the  impact 
assessment.  This  was  in  part  due  to  the  later  decision  to  include  tyres  in  EPREL 
(representing  13%  of  all  EPREL  registrations).  Finally,  e-IDAS  verification  was  not 
originally planned for but was later found to be necessary to ensure the registry’s integrity 
and involved additional one-off development costs.  

Opinions diverge amongst suppliers interviewed in the survey on whether EPREL results 
in higher or lower overall compliance cost compared to before. 38% reported that the costs 
of complying – including time, financial expenses and staff resources – have increased. 

(24)  Around 1000 API keys were provided so far, mostly to dealers (54 %), but also suppliers, researchers, 

search engines, etc. 

(25)  https://www.regulations.doe.gov/ccms;  https://www.energystar.gov/products. 

(26)  https://www.energylabel.com.cn/. 

(27)  Searchable product list | Natural Resources Canada. 

(28 ) Energy Rating - Search the Registration Database. 

(29)  SWD (2012) 329. 

6 

 
 
 
28% indicated that costs have decreased compared to before 2019. The remaining 33% 
stated that the costs have remained unchanged. Most manufacturers enter data themselves, 
with a quarter of the interviewed suppliers outsourcing registration tasks (30). Dealers can 
access EPREL information free of charge and get printed labels from suppliers. Dealers 
report higher levels of satisfaction with the policy than suppliers but point to the missing 
level playing field with online marketplaces.  

5.  MARKET SURVEILLANCE AND ENFORCEMENT 

Market surveillance in the Single Market is framed by the Market Surveillance Regulation 
(Regulation (EC) No 765/2008) which also applies to products under the ELR. The ELR 
strengthened these general provisions in 2017 with i) provisions to encourage cooperation 
between national MSAs ii) clarification of how to deal with risky products and iii) a (so 
far unused) Union safeguard procedure. Article 7(4) of the ELR obligated Member States 
to lay down rules for penalties and enforcement mechanisms and notify such rules by 1 
August 2017 if not previously notified under the labelling Directive.  

Compliance with energy efficient product legislation mainly relies on self-declaration (31). 
This  requires  a  sufficient  level  of  market  surveillance  and  enforcement  to  ensure  fair 
competition and achieve the expected energy savings. Market surveillance is an exclusive 
power of national authorities, but the EU provides financial support:  between 2017 and 
2024,  more  than  EUR 20  million  for  national  market  surveillance  activities  and  wider 
implementation support through Horizon Europe, the Single Market Programme and LIFE. 
As regards compliance with energy efficient product legislation on products entering the 
EU market, customs controls at the EU external borders remained limited and, accordingly, 
the discovery of non-compliance cases low.   

Evidence from EU-funded actions, Member State checks and a 2020 special report by the 
European Court of Auditors (32) suggests persistent and significant non-compliance levels 
(particularly by online shops). Price-comparison websites also often fail to fully display 
the required information. The EEPLIANT 3 Concerted Action (33), funded by the EU and 
involving 24 national surveillance authorities, in a non-representative risk-based exercise 
for six product groups (34) found 82% of products in stores and 97% in online shops had 
minor  or  major  issues  around  the  label  display,  declaration  of  conformity  or  technical 
documentation (hence covering all documentation including under ecodesign, not only  for 
labelling). Online non-compliance was a particular issue for light sources (35). Missing or 
wrong data on labels, product information sheet or other technical documentation does not 
always mean that a product is non-compliant. Laboratory testing in accredited laboratories 
is needed to establish non-compliance and this is costly (typically EUR 1 000-10 000 per 
model, more for large or complex products). 43% of the 265 laboratory-tested products in 
the EEPLIANT 3 compliance verification project had energy performance issues above 
the tolerance level. The overall level of non-compliance in the single market is difficult to 
estimate  though,  since  checks  are  almost  always  risk-based  and  MSAs  target  limited 

(30)  Analysis for the EPREL services project funded under LIFE, May 2025 (unpublished). 

(31)  Third-party certification is mandatory for boilers. 

(32)  Special Report 01/2020. 

(33)  EEPLIANT3_Public_Report_Final.pdf. 

(34)  Air conditioners, lighting, tumble driers, water heaters, space heaters and ventilators.  

(35)  Online shopping study - CLASP. 

7 

 
 
 
resources  on  products  for  which  most  problems  are  expected.  The  findings  cannot  be 
extrapolated to all product groups and across the EU.  

The total number of products inspected per year under this framework ranged from 10-100 
in some Member States to 24 000 in Ireland and 73 000 in Germany in 2024. Most cases 
involved  document  checks  in  shops  and  online  and  only  some  in-depth  performance 
checks. As required under the Market Surveillance Regulation, Member States have as of 
end 2025  encoded 3 147 cases of in-depth  ELR inspections (36) in  the  ICSMS database 
since 2017 (of which 57% were cases of non-compliance). The Commission launched two 
infringement  proceedings  in  mid-2025  against  Portugal  and  Romania  for  not  having 
reported any in-depth checks in 2023 and sent a reasoned opinion to Portugal in November 
2025. 

450 product models have a cross link between ICSMS and EPREL, which should make 
inspections for those more effective. An option for users to easily report any issues with 
registered models or related information directly in EPREL has so far been used for 3 300 
model  registrations.  Bigger  online  platforms  often  cooperate  to  remove  non-compliant 
products, but do not have responsibilities for label display themselves and their wide ranges 
of products offered have also increased the overall enforcement task.  

The Commission launched the European Product Compliance Network (EUPCN) under 
the  Market  Surveillance  Regulation  in  2021.  It  set  up  the  first  EU  testing  facility  for 
ecodesign and energy labelling in 2024 (37). The Commission and Member States jointly 
ensure  that  the  energy  label  is  not  mimicked  for  products  not  covered  by  delegated 
measures or for non-energy products and have in this respect notably engaged with the 
industry behind a voluntary unified water label to have its design adapted (38). 

6.  THE LABEL AS TOOL FOR LEAD MARKETS FOR EFFICIENT PRODUCTS 

Article  7(2)  of  the  ELR  requires  that  any  incentives  provided  by  Member  States  for 
products  subject  to  EU  energy  labelling  shall  target  products  in  the  two  highest 
significantly populated label classes of energy efficiency, or at higher classes. The aim is 
to  focus  demand-side  incentives  (such  as  low-interest  loans,  grants,  tax  rebates  or 
vouchers) on the most efficient products, thus creating a lead market for these products.  

The same or very similar criteria are also used in other legislation including the Energy 
Efficiency Directive requirements on public procurement (39), the EU Taxonomy (40) and 
the VAT rules on reduced rates for efficient heating systems (41). Four EU Member States 
currently apply the reduced VAT rate on his basis.  

The 2010 labelling framework directive already had provisions to promote the use of the 
label as the basis for lead markets, but the more precise formulation of the criterion and 

(36)  In-depth checks are understood as comprising laboratory checks and document checks with a view to 

assessing whether a product is compliant. 

(37)  Commission Implementing Decision (EU) 2024/1456. 

(38)  Unified Water Label. 

(39)  Directive (EU) 2023/1791. 

(40)  Regulation (EU) 2023/2486. 

(41)  Council Directive (EU) 2022/542. 

8 

 
 
 
the EPREL feature allowing easy insights into the distribution across classes of any sub-
selection  of  products  facilitates  operationalising  such  policies.  The  Commission  and 
national authorities can use EPREL to apply the criterion in Article7(2) of the ELR with a 
simple  search  in  EPREL  as  the  starting  point,  reducing  the  need  for  dedicated  market 
surveys and reinforcing competition through transparency of what is placed on the Single 
Market.  To  support  application  of  the  criterion,  the  Commission  presented  guidance 
thereon (42). 

7.  EFFECTIVENESS OF THE NEW LABELS  

7.1.  Understanding of the new labels  

Most consumers interviewed for the survey say they understand labels and more than 90% 
said they found the label and its elements (very) easy to understand. Only a few product-
specific  pictograms  were  reported  by  more  than  10%  of  survey  respondents  as  being 
difficult to understand. This positive result is probably because label designs are generally 
tested  before  they  are  proposed.  77-87%  of  surveyed  consumers  found  the  amount  of 
information on a label was appropriate. The rest felt there was either too much or too little 
(or had no view). Overall, these results thus show no evidence of information overload or 
insufficient information. 

62% of consumers in the survey said they had used the main energy-related information at 
the top of the label. 37% said they had also used the non-energy pictograms in the lower 
part. Recent buyers of white goods were most likely to say that they had used the energy 
label when making their purchase decision (around 90% of those who saw the label). The 
label helped buyers of commercial refrigerators in 80 % of cases and for 70 % of buyers 
of  TVs  and  monitors,  where  performance  criteria  such  as  resolution  or  screen  size  are 
important in buying decisions.  

7.2. 

Impact on availability of affordable efficient products 

A  2021  report  on  appliance  efficiency  standards  and  labelling (43)  by  the  International 
Energy Agency (IEA) found that energy performance requirements and labelling generally 
increase the underlying rate of improvement for new models by a factor of two or three. 
This translates over time into an increase in the average efficiency of the total stock. The 
IEA notes that average purchase prices tend to fall by 2-3% per year due to competition 
(after briefly increasing when new rules come into force), but price reductions observed 
for different products vary, reflecting the degree of competition in any particular market. 
These estimates are global, a recent evaluation on vacuum cleaners in the EU found a 1 % 
annual decrease in purchase prices during the period the label was in application. Recently 
published  research  confirms  that  the  EU  Energy  Label  is  effective  regarding  the 
environmental  objective  of  shifting  consumer  choices,  and  finds  that  supply-side 
competition  is  a  key  driver  behind  the  market  adjustment  thanks  to  a  pattern  of  falling 

(42)  https://energy-efficient-products.ec.europa.eu/consumers_en#what-does-significantly-populated-mean.  

(43)  IEA 2021Energy Efficiency Appliance and Equipment Standards and Labelling Programmes. 

9 

 
 
 
prices as entry increases and more producers begin to offer products at the higher label 
classes, generating consumer surplus whilst stimulating further innovation (44).  

To  guarantee  the  innovation  effect  the  ELR  states  that  where  a  label  is  introduced  or 
rescaled, the Commission shall ensure that no products are expected to fall into class A at 
the moment of the introduction and that the estimated time before a majority of models 
falls into that class is at least 10 years later. EPREL data show that class distributions for 
light sources, refrigerating appliances, TVs and dishwashers have largely developed in line 
with  these  requirements  since  2019.  However,  90%  of  the  washing  machine  models 
registered  in  EPREL  achieved  A-class  within  just  six  years  of  the  review.  In  contrast, 
performance of electronic displays  has  developed more slowly  than anticipated and  are 
clustered in the bottom classes (25% of models are in class G) (45).  

The market share of best-in-class washing machines increased by 50% in 2024 according 
to independent market analysis (46). Academic research based on actual market data from 
2021 suggests that the rescaled label increased people’s willingness to pay for top-rated 
refrigerators compared to the previous label which was less well understood (47). 

8.  CONCLUSION 

The  ELR  has  laid  the  foundation  for  modernised  labels  that  so  far  work  well,  but  the 
transition is not yet complete. Six of the 15 product group labels have been revised so far, 
and  two  new  labels  have  been  introduced  under  this  framework.  The  lengthy  revision 
cycles  of  product-specific  delegated  acts  have  reduced  the  overall  impact  of  the  policy 
framework until  now.  Insufficient  national  market  enforcement  and high  levels  of non-
compliance in at least some market segments (notably online) distort the level playing field 
and reduce projected energy savings.  

The broader policy context has changed substantially since 2017 as a result of (i) the rise 
in online sales, (ii) the EU’s climate change targets, (iii) the global pledge to double energy 
efficiency by 2030 and (iv) the emphasis on competitiveness in the Draghi Report and the 
single  market  strategy  and  more  recently  efforts  around  energy  affordability  and 
independence.  In  this  context,  energy  labels  remain  relevant.  All  relevant  stakeholder 
groups  that  attended  the  implementation  dialogue  on  energy  product  legislation (48)  in 
October  2025  emphasised  the  role  played  by  energy  product  legislation  (including  the 
ELR)  in  promoting  energy  efficiency,  affordability  and  the  competitiveness  of  EU 
industry, but also pointed to non-compliance undermining effectiveness. 

(44)  Anne Kesselring, Energy labels in the European Union: Consumer inattention and producer responses, 
Energy Economics, Volume 144, 2025, ISSN 0140-9883, https://doi.org/10.1016/j.eneco.2025.108275.  

(45)  An evaluation of the delegated regulation on displays is under way. Several complex factors probably 
explain  why  models  remain  in  the  lowest  performing  classes  (including  consumer  and manufacturer 
preference for large screen sizes and high resolutions). 

(46)  GfK 2024 Market Outlook. 

(47)  Corinne Faure, Marie-Charlotte Guetlein, Joachim Schleich, Effects of rescaling the EU energy label on 
household preferences for top-rated appliances, Energy Policy, Volume 156, 2021, ISSN 0301-4215, 
https://doi.org/10.1016/j.enpol.2021.112439.  The  same  study  also  demonstrated  that  showing  both 
labels to consumers (as is the case during the ELR transition phase) does not increase willingness to pay. 

(48)  Implementation dialogue on energy efficient product legislation with Commissioner Dan Jørgensen  – 

Energy.  

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The available evidence on how labels work indicates that the EU Energy Labels decades 
after  their  invention  still  hold  more  potential  for  reducing  energy  use  and  can  also 
contribute to other policy aims. The EPREL product registry for all energy related products 
with an EU Energy Label allows for more market transparency and evidence-based policy 
making. However, EPREL is not yet as widely known or used as the label itself and could 
be used more also to support compliance and market surveillance. The modifications in 
the  Omnibus  proposal  presented  in  parallel  to  this  report  aim  to  better  exploit  these 
opportunities whilst also simplifying where possible for suppliers and retailers. 

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