COMMISSION STAFF WORKING DOCUMENT 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 (Text with EEA relevance)
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

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.6.2026  SWD(2026) 565 final  COMMISSION STAFF WORKING DOCUMENT  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          (Text with EEA relevance) {COM(2026) 565 final} - {SEC(2026) 565 final} - {SWD(2026) 566 final}  
 
 
1. 
2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ....................................................................... 6 
PROBLEM DEFINITION ............................................................................................................................ 7 

2.1. What is/are the problems and what are the underlying drivers? ................................. 8 
2.2. Who is affected and how........................................................................................... 20 
2.3. How likely is the problem to persist? ....................................................................... 23 
3.  WHY SHOULD THE EU ACT? ................................................................................................................ 24 

3.1 Legal basis ................................................................................................................. 24 
3.2 Subsidiarity: necessity of EU action .......................................................................... 24 
3.3. Subsidiarity: added value of EU action .................................................................... 24 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ....................................................................................... 24 

4.1. General objectives ..................................................................................................... 24 
4.2. Specific objectives .................................................................................................... 24 
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ............................................................................ 25 

5.1. What is the baseline from which options are assessed? ............................................ 25 
5.1. Description of the policy options .............................................................................. 25 
5.2. Measures discarded at an early stage ........................................................................ 28 
6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ................................................................... 30 

6.1. Impact of policy option 1 .......................................................................................... 30 
6.1.1. Economic impacts................................................................................................... 30 

6.1.2.  Social impacts ........................................................................................................ 38 

6.1.3.  Environmental impacts .......................................................................................... 40 

6.2. Impact of policy option 2 .......................................................................................... 41 
6.2.1. Economic impact .................................................................................................... 41 

6.2.2. Social impact .......................................................................................................... 42 

6.2.3.  Environmental impact............................................................................................ 43 
7.  HOW DO THE OPTIONS COMPARE? .................................................................................................... 43 
PREFERRED OPTION .............................................................................................................................. 44 
8. 

8.1. REFIT (simplification and improved efficiency) ..................................................... 44 
8.2. Application of the ‘one in, one out’ approach .......................................................... 44 
9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ......................................... 45 
ANNEX 1:   PROCEDURAL INFORMATION ............................................................................................... 46 
LEAD DG, DECIDE PLANNING/CWP REFERENCES ................................................................................... 46 
ORGANISATION AND TIMING ....................................................................................................................... 46 
CONSULTATION OF THE RSB ........................................................................................................................ 46 
EVIDENCE, SOURCES AND QUALITY .......................................................................................................... 47 
ANNEX 2:   STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................... 48 

 
 
 
2.1. Implementation reports on the ELR and TLR .......................................................... 48 
2.2. IPSOS/Centerdata survey on use and understanding of modernised EU energy 

labels and tyre label ............................................................................................... 49 

Both  surveys  will soon  be published. 2.3.  Implementation Dialogue on  energy-

efficient product legislation on 14 October 2025 .................................................. 50 
ANNEX 3:   WHO IS AFFECTED AND HOW? ............................................................................................. 71 
PRACTICAL IMPLICATIONS OF THE INITIATIVE ...................................................................................... 71 
SUMMARY OF COSTS AND BENEFITS ......................................................................................................... 71 
RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................................................ 72 
ANNEX 4:   COMPETITIVENESS CHECK .................................................................................................... 74 
OVERVIEW OF IMPACTS ON COMPETITIVENESS ..................................................................................... 74 
ANNEX 5:   SME CHECK................................................................................................................................ 75 
ANNEX 6: OVERVIEW OF CURRENT LABELLING PROVISION REQUIREMENTS ............................... 79 

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Glossary 

AdCo 

AI 

API 

Administrative Cooperation Group (for Eco-Design and Energy Labelling 
or Tyre Labelling as indicated)  

Artificial Intelligence 

Application Programming Interface 

APPLiA 

Home Appliance Europe (industry association) 

B2B 

BEUC 

Business-to-Business 

Bureau  Européen  des  Unions  de  Consommateurs  (The  Consumer 
Organisation) 

CCIA 

Computer & Communications Industry Association 

CEFACD 

Comité  Européen  des  Fabricants  d'Appareils  de  Chauffage  et  de  Cuisine 
Domestiques 

CEMEP 

CfE 

CFL 

CLASP 

CMYK 

DIY 

DoC 

DPP 

DSA 

European Committee of Manufacturers of Electrical Machines and Power 
Electronics 

Call for Evidence 

Compact Fluorescent Lamp 

Collaborative Labelling and Appliance Standards Program 

Cyan, Magenta, Yellow, Key (Black) – colour printing model 

Do It Yourself 

Declaration of conformity  

Digital Product Passport 

Digital Services Act (Regulation (EU) 2022/2065) 

EDRA-GHIN 

European  DIY  Retail  Association  (EDRA)  and  the  Global  Home 
Improvement Network (GHIN)  

EEB 

EED 

EEI 

European Environmental Bureau 

Energy Efficiency Directive 

Energy Efficiency Index 

EEPLIANT 

Energy-Efficient Compliant Products (EU-funded Concerted Action) 

EHI 

EHPA 

European Heating Industry (association) 

European Heat Pump Association 

3 

 
e-IDAS 

ELR 

ENEA 

EPBD 

EPEE 

EPREL 

ESPR 

electronic Identification, Authentication and trust Services (EU Regulation) 

Energy Labelling Regulation (Regulation (EU) 2017/1369) 

Italian  National  Agency  for  New  Technologies,  Energy  and  Sustainable 
Economic Development 

Energy Performance of Buildings Directive 

European Partnership for Energy and the Environment 

European Product Registry for Energy Labelling 

Ecodesign 
2024/1781) 

for  Sustainable  Products  Regulation 

(Regulation 

(EU) 

ETRMA 

European Tyre and Rubber Manufacturers' Association (now TyresEurope) 

EU27 

EEA 

F-Gas 

The 27 Member States of the European Union 

European Economic Area 

Fluorinated Greenhouse Gas 

GCP Europe 

European  Association  of  Installers  /  Heating,  Cooling  and  Plumbing 
contractors 

GHG 

GPSR 

GTIN 

HVAC 

IA 

IEA 

IEA 4E 

Greenhouse Gas 

General Product Safety Regulation (Regulation (EU) 2023/988) 

Global Trade Item Number 

Heating, Ventilation and Air Conditioning 

Impact Assessment 

International Energy Agency 

International  Energy  Agency  –  Energy  Efficient  End-use  Equipment 
(Technology Collaboration Programme) 

ICSMS 

Information and Communication System for Market Surveillance 

ITI 

JRC 

kW 

LED 

MS 

MSA 

Information Technology Industry Council 

Joint Research Centre (European Commission) 

Kilowatt 

Light-Emitting Diode 

Member State(s) 

Market Surveillance Authority / Authorities 

4 

 
NACE 

NLF 

OEM 

PFAS 

PIS 

PV 

Nomenclature  statistique  des  activités  économiques  dans  la  Communauté 
européenne (Statistical Classification of Economic Activities in the EU) 

New Legislative Framework 

Original Equipment Manufacturer 

Per- and Polyfluoroalkyl Substances 

Product Information Sheet 

Photo Voltaic 

QR code 

Quick Response code 

RED 

RSB 

RVO 

SBS 

SDG 

SME 

SWD 

TFEU 

TLR 

TSO 

TWh 

Renewable Energy Directive 

Regulatory Scrutiny Board 

Rijksdienst voor Ondernemend Nederland (Netherlands Enterprise Agency) 

Structural Business Statistics (Eurostat) 

Sustainable Development Goal 

Small and Medium-sized Enterprise 

Staff Working Document 

Treaty on the Functioning of the European Union 

Tyre Labelling Regulation (Regulation (EU) 2020/740) 

Transmission System Operator 

Terawatt-hour 

UN ECE 

United Nations Economic Commission for Europe 

ZVEI 

Zentralverband Elektrotechnik- und Elektronikindustrie (German Electrical 
and Electronic Manufacturers' Association) 

5 

 
 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The  European  Commission’s  2024-2029  Political  Guidelines  1  highlight  simplification  and 
better implementation  of EU rules  as being  central  for making business  easier and faster in 
Europe. The Commission has made simplifying legislation a priority for the next five years and 
has  strengthened  targets  to  reduce  administrative  costs  for  business  (together  with  public 
authorities) and small and medium sized enterprises (SMEs) by 25% and 35% respectively. 

The same political guidelines also underline that the EU must and will stay the course on the 
green and digital transition. Energy-efficient product legislation contributes to aspects of this 
transition such as reducing energy import dependency, GHG emissions, energy and material 
use and grid infrastructure build-out needs, while helping to make energy bills and housing 
more affordable. Energy product legislation is a long-standing EU policy framework that has 
been revised regularly since its inception in the wake of the 1973 oil crisis 2. The framework is 
based  on  fully  harmonised  single  market  provisions  and  does  not  contain  any  reporting 
obligations beyond the need to register models in the European Product Registry for Energy 
Labelling  (EPREL)  3  product  database’s  public  and  compliance  parts.  Being  Single  Market 
legislation,  the  EU  measures  are  in  themselves  a  simplification  since  they  ensure  a  single, 
common  set  of  requirements  at  EU  level  for  all  manufacturers  and  avoid  the  cost  and 
complexity  for  market  operators  of  complying  with  different  national  measures  and  for 
Member States to implement national rules.  

The 2024 Draghi report 4 points to insufficient market surveillance and poor enforcement (and 
potentially compliance) as a major shortcoming in the implementation of the EU Ecodesign 
and Energy Labelling frameworks  5. The Action Plan for affordable energy 6 emphasises the 
role of energy efficient products to lower energy bills immediately, an effect that is reduced 
due to non-compliance. The Commission therefore announced a revisiting of energy labelling 
rules.  
In  its  Communication  on  a  Strategy  for  the  Single  Market  7, the  Commission  recognises 
digitalisation as a key driver to enable optimal functioning of the single market, including by 
removing  obligations  to  provide  product  compliance  documentation  in  paper  format. This 
principle is already applied to some extent to the product information sheet under the current 
EU labelling  framework. The present  analysis considers further digitalisation steps, making 
better use of the already existing European Product Registry for Energy Labelling (EPREL) 
product database, including for strengthening compliance. 

1 Political Guidelines EC 2024-2029. 
2 History energy labelling .  
3 EPREL Public website. 
4 The Draghi report on EU competitiveness. 
5 This was already stipulated in the  01/2020 Special Report Court of Auditors and repeated by all stakeholder 
groups  during  the  various  consultations  (implementation  dialogue,  reality  check  and  call  for  evidence,  cf. 
https://energy.ec.europa.eu/news/commission-seeks-views-how-simplify-legislation-energy-efficient-products-
2026-02-16_en). 
6 Affordable energy.  
7 2025 Single Market strategy.  

6 

 
 
 
 
Replacing  a  directive  with  a  regulation  for  energy  labelling  and  adopting  the  tyre  labelling 
regulation  (TLR)  8  aimed  to  harmonise  product  information  requirements.  Prior  to  the  EU 
framework, manufacturers dealt with different label schemes (both voluntary and mandatory) 
and  nationally  diverging  rules  leading  to  a  burden  that  fell  disproportionately  on  smaller 
producers and importers. In earlier versions of the framework, labels were defined in different 
language  versions  complicating  implementation  for  manufacturers.  Full  harmonisation  and 
language  agnostic  labels  (without  text)  as  now  adopted  under  the  current  energy  labelling 
regulation (ELR)9  removed those barriers: now a product registered in EPREL carries a legally 
valid label that is instantly recognisable to consumers in all EU Member States.  

Despite labelling policies being relatively mature and harmonised tools there are still room for 
improvement. This Staff Working Document (SWD) accompanies a simplification  omnibus 
package  10 on energy efficient product legislation and provides a targeted and proportionate 
impact assessment presenting: (1) the input and feedback received from stakeholders during 
the consultation process; (2) the problem statement; (3) policy objectives (4) policy options 
including discarded measures; (5) proportionate assessment and quantification of the expected 
savings of the proposed amendments.  

2.  PROBLEM DEFINITION 

Two main problems and their drivers relevant to this Impact Assessment (IA) and to the sector 
specific rules of the framework were identified:  

8 Regulation (EU) 2020/740 of the European Parliament and of the Council of 25 May 2020 on the labelling of 
tyres with respect to fuel efficiency and other parameters, amending Regulation (EU) 2017/1369 and repealing 
Regulation (EC) No 1222/2009. 
9 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. 
10  COM(2026) 565.  

7 

 
 
2.1. What is/are the problems and what are the underlying drivers? 

Figure 1: The problem tree  

Problem 1: Disproportionate obligations for suppliers and dealers  

Problem driver 1: Cumulative label transmission and registration requirements for suppliers  

The  ELR  obliges  suppliers  (i.e.  manufacturers,  importers  and  authorised  representatives)  to 
transmit labels and product information sheets (PIS) to dealers and register each product model 
in EPREL before placing a product on the market. It is specified that a printed label is to be 
supplied free of charge for each individual unit, typically inside (or on) the product packaging 
11.  In  2023,  this  obligation  concerned  an  estimated  375  million  products  12  sold  in  the  EU. 
Labels usually come in the form of a loose sticker in the box, even though this format is not a 
legal obligation. Suppliers have converged towards using high-quality sticky labels that can be 
removed without residue. Dealers usually open one or some of the boxes in a delivery to use 
the enclosed label for display, or not if the sale happens online. A typical average order of a 
retailer with a wholesaler for store replenishment ranges from a few items to around 50 units 
per model. Since EPREL based on the information provided by the supplier generates the labels 
and PIS, there is to a certain extent a duplication of duties for suppliers who deliver the physicla 
label and the information to generate the electronic label.  

11 The ELR currently requires that a label is printed on the packaging for light sources. For tyres, the TLR requires 
a sticker on the tyre In the case of electronic displays, the ELR requires both a printed label and label printed on 
the packaging. All other products require a printed label to accompany each unit.  
12 Excluding light sources and tyres.  

8 

 
 
Many labels are not seen by a customer until after the purchase decision is taken since they 
remain in the box. No studies could be identified on the behaviour of customers after purchase 
to understand what they do with the energy label. It can be expected that most are thrown away, 
while  some  customers  may  keep  them  with  other  delivered  documents  on  warranty,  user 
manual, etc., or stick them on the back of the appliance.  

Besides the label, suppliers are also obligated to deliver a PIS to dealers. For these, the ELR 
gives flexibility to choose between digital or physical transmission. The Commission has opted 
for electronic PIS for all delegated acts - with an option to obtain a printed version upon request 
through the dealer. Stakeholder responses indicate that such requests are rarely made.  
One  of  the  main  changes  in  the  ELR  from  the  previous  directive  13  was  the  creation  of  a 
centralised product database (now called EPREL, the European Product Registry for Energy 
Labelling) set up and managed by the Commission. Suppliers must register each model of the 
products  covered  by  a    Implementing  Regulation  under  the  ELR  before  placing  it  on  the 
EU/EEA market 14. It is now populated by around two million product models. The purpose of 
the  database,  which  consists  of  a  publicly  accessible  and  a  compliance  part  that  is  only 
accessible to MSAs, was defined in Article 12(2) of the ELR to: 

•  support MSAs in carrying out their tasks under the ELR and the relevant delegated acts, 

including enforcement thereof; 

•  provide  the  public  with  information  about  products  placed  on  the  market  and  their 

energy labels, and product information sheet; 

•  provide the Commission with  up-to-date energy efficiency information for products 

for reviewing energy labels.  

Some of the features of the EPREL database that are now available were not anticipated, nor 
legally required at the time, including: 

•  The QR code on the energy label that links the label to the product page in EPREL15.  

13 Directive 2010/30/EU repealed by Regulation (EU) 2017/1369.  
14 This concerns currently 16 product categories with subcategories: Washing machines/washer-dryers, tumble 
dryers,  dishwashers,  domestic  refrigerating  appliances,  fridges  and  freezers  including  wine  coolers,  domestic 
cooking appliances including, hobs, range hoods, light sources, space  heaters, water heaters, solid fuel boiler, 
local space heaters, air conditioners (residential and commercial), residential ventilation units, displays (TVs and 
signage displays), smart phone and tablets,  commercial refrigerators, professional refrigerated storage cabinets/ 
refrigeration appliances with direct sales function (e.g. open display cases) and tyres.  
15 The QR code is currently in application for 10 out of the 16 product label groups. Some product groups have 
not yet undergone the full review towards the modernised labels and continue using the non-rescaled label layout 
without QR code.  

9 

 
 
 
 
 
Figure 2: The QR code as feature on all modernised/newly introduced labels under the ELR. Scanning 
it leads to the full information registered in EPREL  

•  The EPREL functionality to generate downloadable and printable labels and PIS (in all 

EU languages) based on information entered by suppliers 16. 

•  Open Application Programming Interfaces (APIs) that allow online retailers, suppliers, 
researchers  etc.  to  automatically  access  EPREL  including  for  compliance  with 
requirements for online display of labels and PIS. 

The electronic label was considered an addition, rather than a replacement (cf. recital 13 ELR): 
“Without affecting the obligation of the supplier to provide a printed label together with each 
unit of a product, advances in digital technology could allow for the use of electronic labels in 
addition to the printed energy label. The dealer should also be able to download the product 
information  sheet  from  the  product  database”.  There  is  therefore,  for  certain  elements,  a 
duplication of both electronic information and physical transmission of labels in the current 
framework, and an underutilisation of the EPREL registry.  

Problem  driver  2:  Lack  of  flexibility  in  the  ELR  and  TLR  to  adjust  to  diverse  products, 
distribution chains and technologies (and for tyre label to UNECE updates).  

The current label delivery and display rules appear to be best suited to white goods, which are 
the  products  that  first  had  an  EU  energy  label,  have  best  compliance  with  respect  to  the 
obligations to display them17 and are the products where most customers see and use the labels. 
For  other  product  groups,  such  as  heating  appliances,  the  objective  of  delivering  energy 
efficiency and other environmental information to customers at the point of sale might be better 
or simpler achieved by ensuring the label is part of an offer of an installer rather than a printed 
label in a box which might not get seen by the customer 

The limitations of the current framework and the need for more flexibility were identified as 
one of the main conclusions of the “reality check” meeting in December 2025. It is currently 
not  possible  under  the  ELR  to  require  that  a  product-specific  label  is  directly  affixed  on  a 
product or the QR code of the label is directly marked on a product. Both options could reduce 
the amount of paper waste from labels and become more relevant with the shifting focus on 
post-purchase information on recyclability or reparability.  

16 It is evident that this function was not foreseen since Annex I, point 1(c), of the ELR requires the supplier to 
upload not only technical parameters, but also the label itself in electronic format. 
17 Compliance Services project sweep Jan 2026. 

10 

 
 
 
Article 3 1) of the ELR sets out the basic obligation on suppliers to provide a . printed label for 
each unit and that delegated acts may allow the label to be printed  on the packaging of each 
unit.  However, this may be insufficient given that products and sales channels  vary greatly 
including for:  

Share of online sales for a product 

While online distance sales grew in importance since the ELR was adopted in 2017, there are 
inherent  limits  to  this  sales  channel  due  to  the  size  of  some  products  and  their  need  for 
installation, unlike for other shippable products like clothes. The difference with physical shops 
is that, for this channel, no physical label is needed for display, but that it is processed digitally. 
The role of online sales is very different across the products within scope:  close to 0 % for 
bigger  appliances  necessitating  installation  such  as  hydronic  heat  pumps,  around  25  %  for 
white goods such as washing machines and up to 40 % in the case of lighting products 18.  

Direct imports by customers are at this stage, apart from lighting products, not a generalised 
issue under the ELR and TLR. The only product in scope with a sizeable share of direct online 
purchase  offers  on  platforms  like  TEMU  or  AliExpress  are  lighting  products  and  small 
unregulated energy-related items.   

•  Share of B2B in sales and/or intermediary actors in the distribution chain  

The share of B2B customers and the significance of intermediary actors such as installers, tyre 
fitters or energy service providers who may sell an energy-labelled product as part of a service, 
varies greatly. Under the ELR, where there are intermediaries, the customer may not get to see 
the label at all or only after the purchase. The framework was mainly conceived with a direct 
relationship between supplier and customer or dealer selling to the customer in mind. Some 
products including white goods are sold both via dealers displaying the label in the classic way, 
but also via kitchen fitters or specialised installers, showing the variety of situations that need 
to be catered for by the rules 19. To achieve its objectives the ELR should facilitate customers 
seeing the label in all situations before making their purchase.  
The  TLR  establishes  tasks  for  dealers  regarding  the  tyre  label  when  in  fact  a  customer 
purchasing a car can in most cases not chose the set of tyres that will be mounted, resulting in 
an obligation on car dealers to show a series of labels for potentially to be mounted tyres.20   

•  Share of imports in EU sales  

The share of imports and import channels vary across the products in scope. The EU is a net 
importer of domestic appliances. 15 % of the heating market is supplied from outside the EU 
and heat pumps show a rapidly rising third country share. Here, established brands — such as 
Daikin, Mitsubishi, LG — tend to import through their own authorised EU subsidiaries (and in 
some  cases  even  have  EU-based  manufacturing)  and  register  products  in  EPREL  through 
structured compliance processes, but a growing share of for example the Chinese heat pump 
volume enters through independent importers and distributors who become the supplier. In the 

18  Europe Lighting Market Size, Share and Analysis, 2033. 
19 In the specific case of tyre labels, dealers (who sell around 10-20% of tyres in the EU) have the obligation to 
display the tyre label in offers, but buyers generally do not have a choice as the tyre can be selected from a pool 
of tyre suppliers and the tyre is mounted depending on the time of delivery of the manufacturer. What is typically 
communicated to the customer are the labels for models with which the manufacturer has contracts, and which 
could potentially be mounted. 
20 FAQ - tyre label display obligation for vehicle dealers.   

11 

 
 
 
 
categories with tightly controlled brand channels — smartphones, TVs, large appliances from 
established Asian brands — the supplier is typically a large, well-resourced EU legal entity 
with  the  infrastructure  to  manage  EPREL  registration  and  label  provision  at  scale.  Imports 
account for approximately 40% of the EU LED lighting market by value, with China as the 
dominant source country and a multitude of small actors involved.  

•  Size of the product and its packaging and product type 

The ELR and TLR apply to products with very different packaging (sizes) and display patterns 
in shops. Large items such as TVs or white goods are mostly displayed with one open sample 
and  boxed  stock  behind  or  elsewhere,  while  smaller  products  like  lighting  are  presented 
packaged. Independently from size, a product like an electronic display can also be directly 
displaying  the  label  rather  than  having  it  next  to  the  product.  For  other  products,  the  label 
placement is specified in each product-specific  delegated act 21.  

•  Degree to which customers use the energy label in purchase decisions  

As stated in the energy labelling implementation report 22 and based on a representative survey 
23, buyers of white goods were most likely to have used the energy label when making their 
purchase decision (around 90% of those who saw the label). This compares to 80 % for buyers 
of commercial refrigerators and 70 % of buyers of TVs and monitors. In the latter case it seems 
that other criteria such as screen size or resolution come into play. 

•  Lacking flexibility in the TLR 

The TLR addresses tyres for different vehicles (passenger cars, vans, trucks, buses) and use 
cases (long-haul versus urban) in one common label. It is a self-standing framework in which 
certain technical specifications cannot be reviewed via delegated acts as is done for energy-
related products under the ELR. Since not every technical aspect merits a co-decision review, 
the EU tyre label is no longer aligned with UN ECE requirements - which are used as the basis 
for allowing tyres on the EU market under type approval legislation. Particularly for C1 tyres 
(passenger  cars),  no  models  can  fall  into  the  lowest  classes,  making  the  label  less 
differentiated 24 and consequently less useful and somewhat misleading.  

The Commission is empowered to modify parts of the tyre labelling annexes in the light of 
technical progress, but the limited scope of the empowerment does not allow it to update the 
TLR to reflect new UNECE rules. Moreover, information requested from tyre suppliers does 
not allow for meaningful searches in EPREL by users and procurers (like municipalities for 
bus  or  garbage  trucks)  and  bulk  purchasers  in  general  (like  car  manufacturers  or  fleet 
managers).  
For  other  elements  the  requirements  are  not  clear  enough  for  MSAs  25.  The  information 
requested from suppliers is not always sufficient for customers, to select the right tyre for their 

21 The Eurocommerce contribution to the call for evidence suggests more flexibility for label placement to avoid 
damage from glued label stickers.  
22 COM(2026) 319.    
23 Study on consumer understanding of the EU energy labels applied since 2021.  
24 For C1tyres, almost 60% of tyre types are already in class A, B or C and this share will rapidly increase because 
of UNECE restrictions, banning most of tyres in D and all in E class. 
25 At the reality check meeting, Belgian and German MSAs made the point that enforcement activities for tyres 
are currently hampered by insufficient information on how testing was performed, e.g. which UN ECE Regulation 
is the basis, how test results were extrapolated to prove better performance for certain parameters than indicated 

12 

 
 
 
vehicle and vehicle homologation documents. Differences can be due to use cases, mounting 
or safety aspects, for example, the tread of truck tyres is different depending on the axle where 
the tyre is mounted. These shortcomings complicate a search for the best tyre, in particular for 
non-experts. This makes EPREL, in which tyres constitute the third biggest product group in 
terms of absolute model registrations, less useful than it could be. 

Problem driver 3: Outdated provisions for the transition from non-rescaled to rescaled labels 
for both suppliers and retailers.  

The  ELR  mandates  the  modernisation  of  energy  labels  and  the  return  to  the  A-to-G 
classification, thus implying a change of the label scales in use since 2010 (where A+, A++ 
and A+++ classes were added above A). The ELR contains several provisions detailing how 
the ‘rescaling’ transition from non-scaled to rescaled label is to be managed by suppliers and 
dealers. The aim was to avoid customers seeing parallel labels with different layout or scales, 
obligating suppliers to supply and register double and dealers to manage a strict switch. Linked 
to  the  duty  to  supply  both  labels  in  printed  format  is  the  duty  for  the  supplier  to  have  two 
separate  registrations  in  EPREL  -  even  for  products  that  a  supplier  already  knows  will  be 
discontinued. For the dealer, it means that even if a manufacturer does not intend to continue 
selling a certain model, the dealer is under an obligation to replace the label on display. The 
dealer also must change the label on display within 14 working days after the date specified for 
the product and not use the rescaled label prior to the specified change date.  

This ‘double label provision’ rule of Article 11(13) ELR does not apply if two conditions are 
met: 1) the testing method changed for the rescaled label and 2) no units of the model with the 
non-rescaled label are placed on the market during the 4-month period or thereafter. In such 
cases, suppliers only deliver the rescaled label in printed form during the 4-month period.  The 
dealer may in this case continue selling with the non-rescaled label - until 9 months after the 
date specified for display of the rescaled label. In other cases, old stock cannot be sold after the 
switch-over date. 

Problem driver 4: ‘Once only’ principle not fully applied by Member States for information 
covered by EPREL 

A direct link already exists between EPREL and the Information and Communication System 
for Market Surveillance  (ICSMS)  database  which  are  both  managed  by  the  Commission.  It 
allows MSAs to see in EPREL when another MSA has performed in-depth testing for a certain 
model and consult its results.  

The interaction between EPREL and the future registry for digital product passports (DPPs) 
under  the  Ecodesign  for  Sustainable  Products  Regulation  (EU)  2024/1781  (ESPR)  26  was 
repeatedly  listed  by  manufacturers  during  the  consultation  process  as  a  potential  double 
registration concern  27  or inconvenience28. Several entities with a duty to register called for 

in the type approval test and the fact that significant interlaboratory discrepancies in testing exist e.g. for wet grip 
of tyres. 
26  Regulation  (EU)  2024/781  of  the  European  Parliament  and  of  the  Council  of  13  June  2024  establishing  a 
framework  for  the  setting  of  ecodesign  requirements  for  sustainable  products,  amending  Directive  (EU) 
2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. 
27 When products need to move from EPREL into the new registry without technical facilitation, or suppliers need 
to maintain two registries.  
28 When suppliers of energy-related products might have to register into two different databases - EPREL for those 
with a label under the ELR and other aspects and eco-design in the new registry. 

13 

 
 
clarity to ensure a smooth transition29.  Article 9(4)(b) of the ESPR provides that products that 
are covered by another digital carrier will not be subject to the ESPR’s DPP Recital 34 of the 
ESPR  recommends  a  link  between  the  databases,  where  feasible.  While  this  is  currently  a 
theoretical problem given that DPPs do not yet exist, their advent will need to be factored into 
the way energy labelling works. When DPPs are required under other legislation than ESPR, 
the same principle should apply. The ESPR provides the legal basis for the DPP but does not 
provide  for  a  horizontal  framework  to  make  comprehensive  use  of  the  tool,  including  for 
documenting  compliance.  The  lack  of  such  a  framework  raises  uncertainty  with  industry 
stakeholders. 

Information registered in EPREL is, at least in some instances, requested again at national level 
for  purposes  such  as  financial  incentives  schemes  for  energy-related  products30.  The 
Commission was informed of instances (e.g. in DE, PL) in which documentation in EPREL 
was  not  accepted  for  the  purposes  of  national  incentive  schemes  involving  energy-related 
products, even though the product information sheets are available in all languages. There is 
currently no legal obligation to accept EPREL documents  for such schemes and some Member 
States seem to prefer working with their own databases or want to be fully certain that claimed 
performance values are  certified and therefore require additional  evidence. D  2009/125/ECt . 
However, where the information is uploaded in EPREL by manufacturers and MSAs have no 
reasons to distrust the declared performance and the documentation provided by the supplier 
in  EPREL,  asking  for  further  or  the  same  information  creates  avoidable  burden  and 
administrative costs. 

Problem 2: Persistent non-compliance  

Persistent non-compliant products and insufficient levels of enforcement were highlighted by 
almost  all  stakeholders  at  the  implementation  dialogue  as  an  issue  that  needs  addressing  to 
avoid undermining the policy objectives, and eroding stakeholder support for – and consumer 
trust in – the EU energy and tyre labelling policy. This echoes the findings in the Draghi report 
and the 2020 Court of Auditors special report.  

Evidence,  including  from  a  recent  online  compliance  check  carried  out  on  behalf  of  the 
European  Commission  under  the  EU-funded  Compliance  Services  project  31,  inspection 
outcomes reported by Member States for the implementation report and EU trade associations, 
ICSMS and the findings under the key enabling action for the labelling framework funded by 
the  EU  and  involving  24  MSAs  (Energy  efficiency  compliant  products  =  EEPLIANT 
Concerted Action) 32 back this up.  

29  Comments  along  those  lines  were  made    in  writing  and  the  reality  check  meeting  by  Michelin,  Belino 
Automation, CCIA, Lighting Europe, Digital Europe, EUHA, ITI and CEFACD. Energy product suppliers more 
often express a preference to retain EPREL for energy-related products due to them having registered already, 
actors with a broader portfolio have either no preference as long as no double registration occurs or prefer the 
future DPP to be the centralised registry (eBay, Digital Europe).  
30 Regulation (EU) 2021/2139 (taxonomy criteria) requires tyres that comply with requirements in the highest 
populated class or in the two highest populated classes as set out in Regulation (EU) 2020/740  “ as can be verified 
from the European Product Registry for Energy Labelling (EPREL)” and Article 7 of Regulation (EU) 2017/1369 
that reads “Where Member States provide incentives for a product specified in a delegated act, those incentives 
shall aim at the highest two significantly populated classes of energy efficiency”. 
31 see Compliance Services. 
32 EEPLIANT3. 

14 

 
 
The EEPLIANT 3 non-representative exercise for six product groups 33 found 82% of products 
in stores and 97% in online shops either lacked a label, displayed the incorrect label class, had 
incorrect  or  inconsistent  information  on  label  or  lacked  other  information.  Online  non-
compliance  was  a  particular  issue  for  light  sources  34.  Missing  or  incorrect  data  in  label  or 
database does not always mean that a product is non-compliant, this can only be established by 
in depth or laboratory checking. The above mentioned EEPLIANT 3 exercise tested a selection 
of products that showed document irregularities and were suspected to have compliance issues 
–  43%  of  the  265  laboratory-tested  products  in  the  EEPLIANT  3  exercise  had  energy 
performance issues above the tolerance level after one test (usually three tests are required to 
establish non-conformity). 

Such in depth checks are generally costly to perform, in particular for tyres which also includes 
safety-critical  elements  and  requires  dedicated  test  grounds/tracks  and  the  involvement  of 
several authorities (for type approval, for labelling, for safety). Testing is therefore generally 
less frequent  under this  regulation.  When  tyres are  tested, e.g. as reported by Germany and 
Ireland in ICSMS, the share of non-compliance is consistently above 50%. Ireland has posted 
test results of 36 tyre models in the ICSMS database and found just 33% compliance in 2024 
and 51% in 2025. Germany has posted test results from 60 tyre models subjected to in-depth 
testing and found just 37% compliance in 2023, improving to 58% in 2024.  Data from tests 
performed  by  the  JRC  also  resulted  in  high  non-compliance  figures35.  Even  formal  and 
documental compliance control is more complex for tyres as it interacts with that for vehicles 
and  their  parts  for  which  other  authorities  are  competent.  Unless  type  approval  and  testing 
documentation is uploaded in EPREL, MSAs have no means for checking the plausibility of 
declared  performance  of  tyres  and  can  only  rely  on  inhomogeneous  documentation  or  self-
declarations by tyre suppliers. 

In ICSMS, between 22 July 2021 (the date of entry into application of the market surveillance 
Regulation (EU) 2019/1020) and 17 May 2026, 2 097 energy labelling inspections have been 
encoded as required under Article 34(4) of that Regulation. In principle, this figure does not 
include inspections related to dealers’ obligations (e.g. displaying the label for products sold in 
shops  or  online)  and  cover  only  in-depth  checks,  i.e.  laboratory  tests  or  inspections  of  the 
technical documentation.  The overall percentage of energy-related products that are declared 
as “non-compliant” is 56% in ICSMS. Also tyres are reported in ICSMS, here out of the total 
of 230 in-depth checks reported in ICSMS until end 2025, five products posed a serious risk 
and 16 a high risk. 

The ICSMS system does not provide deeper insight on the nature of these non-compliances. 
These may include significant non-compliances such as incorrect energy class, other incorrect 
data, missing data, but also minor formal non-compliances such as those related to the format 
of the label. A substantial part of non-compliances can be directly corrected by amending the 
label and product information sheet. 

33 Air conditioners, lighting, tumble driers, water heaters, space heaters and ventilators.  
34 Online shopping study - CLASP. 
35 E.g. up to 80% for snow grip. 

15 

 
 
Compliance of online marketplaces is generally worse than in physical shops as seen above for 
EEPLIANT  3.  A  compliance  check  focussing  only  on  online  marketplaces  from  2021  by 
CLASP 36 found that the most frequent non-compliance issues were related to:  

• 
• 
• 
• 

the location of the energy label or “nested display” simplified label; 
format and size of the graphic; 
the availability of the mandatory product information sheet (product fiche); and  
the  absence  of  labelling  information  on  some  page  types  (catalogue  view,  shopping 
basket page, comparator, etc). 

23  %  of  the  72  inspected  online  marketplaces  across  Member  States  in  the  CLASP  report 
showed poor compliance in displaying energy labels (meaning that labels were not shown at 
all or similar facts). The CLASP report does include some online marketplaces in its sample 
but does not provide a differentiation of EU based versus thirdthird country compliance.  

In a mystery shopping exercise of 2025 by the EU trade association Lighting Europe, out of 
442 products offered online across the EU, 76% lacked the necessary information requirements 
(under energy labelling but also other legislation such as WEEE and low voltage Directive).37  

A precise estimate of the overall non-compliance problem both online and in shops is hard to 
establish  as  most  compliance  checks  are  risk-based  and  the  results  cannot  simply  be 
extrapolated. A share of non-compliant products at the higher end of the previous Commission 
estimate  of  10-25  %  of  2016  38  can  be  assumed  given  the  rise  of  online  shopping  and  the 
overwhelming effect of their comprehensive offers on tightly resourced MSAs. In a rare case 
of a random inspection carried out in 2024 by the Slovenian MSA on 15 dishwashers and 15 
refrigerators from Slovenian online marketplaces, 2 refrigerators and 1 dishwasher were found 
non-compliant  and  voluntarily  withdrawn  (=10  %  non-compliance),  this  concerning  white 
goods that generally show best compliance with label provisions. 

The root causes of non-compliance are multi-faceted, with the main drivers being insufficient 
enforcement (resources) for years and, consequently, lack of dissuasive measures against false 
declarations. They also include a lack of knowledge by economic operators (which is being 
addressed  as  part  of  EU  funded  support  action  and  also  Member  State  level  efforts  and 
campaigning), complex legislation, booming online sales etc.  

There is no data that would give insights on whether the non-compliance is intentional or results 
of lack of knowledge or understanding the rules. However, while some economic operators do 
pay attention to the rules and make efforts to ensure compliance, it seems reasonable to assume 
that the low level of enforcement does not provide others with a strong incentive to be attentive 
to  the  rules,  creating  an  unfair  playing  field  and  distorting  the  internal  market.  Unfair 
competition from third-country and EU-based players offering non-compliant products and/or 
misleading consumer information  and with this increasing market shares was highlighted inter 
alia by EuroCommerce39 and EDRA-GHIN during stakeholder consultation, is however in fact 
limited to light sources for products within scope as most energy related products  (e.g white 
goods, heating appliances) and tyres are not offered at scale in online platforms based outside 
the EU such as  TEMU  or Aliexpress.  For light sources, TEMU formally obliges sellers to 
comply with the obligations and has systems for document upload. Whether this also means 

36 Improving Online Labelling Compliance in the European Union - CLASP.  
37 LE_-_OMS_report_2025_-_20260401_.pdf. 
38 COM (2016)773. 
39 #Compliance4All – Retailers call for a level playing field - EuroCommerce. 

16 

 
 
products perform as advertised is less clear, a recent  exercise by the consumer organisation 
BEUC on several product categories (not the ones at stake for this impact assessment) found 
both label related and more substantial safety issues based on risk based sampling.40 .  

Most of the  drivers of  non-compliance  and possible solutions are outside the scope of this 
initiative. The types of action that might be appropriate include:  

•  enhancing the level of national enforcement activities;  
•  complementary EU-level checks; 
• 
•  AI-supported checks; and  
• 

joint enforcement activities between MSAs and operators. 

replicable quick-testing models that allow more tests for the available budget; 41  

While these might be needed to address part of the problem, they are outside the scope of the 
present initiative and might better be dealt with in ongoing parallel legal reviews, for example 
under the forthcoming European Product Act42. Other initiatives such as the recently agreed 
reform of EU customs rules 43 may contribute to improving compliance at the level of border 
control.  

The current initiative addresses aspects with relevance for compliance that are within the remit 
of the ELR and TLR. These mostly relate to unclear legal concepts and responsibilities that 
consequently  result  in  uneven  application  of  the  provisions  and/or  missing  display  of 
information in certain instances. 

Problem driver: Ambiguous legal concepts undermining uniform application and compliance  

Three specific areas have been identified where unclear legal concepts under the ELR and TLR 
may contribute to undermining compliance. They are outlined below. 

• 

Intermediary actors that are not suppliers or dealers  

The ELR and TLR define responsibilities for suppliers and dealers. Unlike the TLR, the ELR 
makes  no  distinction  between  wholesale  distributors  and  dealers  selling  to  customers. 
Moreover,  neither  framework  defines  the  responsibilities  of  intermediary  actors  such  as 
installers/professional  repairers,  tyre  fitters,  kitchen  fitters  or  heat/energy  service  providers. 
While intermediaries can offer or sell a product within scope as part of their service, their role 
is different from a traditional shop owner. 

These ambiguities explain at least partly the lower-than-average compliance for heating and 
cooling appliances for which three-stage distribution channels involving an intermediary are 
dominant in the EU44. The recent online verification exercisein 36 online shops across seven 
Member States carried out by the EPREL Compliance Services project in early 2026 found that 
random verification resulted in a compliance rate of only 43.44 % for heating products versus 
62.61 % for tumble driers and 62.35 % for smart phones45. It also proved necessary to address 

40 BEUC-X-2025-007_Tests_of_Temu_Products_by_Consumer_Groups.pdf. 

41  The budget is often shared with that of other products including products with health and safety concerns.  
42 Commission seeks views on strengthening EU product safety and market rules.  
43 Commission welcomes historic agreement to reform EU Customs Union.  
44 Analysis of the EU heating market. LCP Delta for Agora Energiewende 2025. 
45 Compliance Services. 

17 

 
 
Irish  MSA 

recommended  clarifying 

installer obligations specifically as part of the training activities under the ongoing EU-funded 
project  Compliance  Services.46  The 
installer 
responsibilities: “Legislative text is required in both eco-design and energy labelling defining 
installers and listing their obligations e.g. following manufacturer's instructions” 47. 
For tyre labels, the rules define the role of some intermediaries, but the survey48 supporting the 
implementation report showed that private consumer awareness of the tyre label is significantly 
lower  than  awareness  of  the  energy  label  (40%  for  private  tyre  buyers  versus  65-90%  for 
energy-related  products  49).  Half  of  the  interviewed  tyre  dealers/distributors  reported 
discussing the label only if the customer prompts them while one in six actively discourages 
customers from relying on it. This behaviour can be partly explained by split incentives where 
tyre dealers promote certain brands to maximise margins 50. Finally, the TLR sets requirements 
on tyre distributors, although most of tyre fitters do not fall into this category. 

When it comes to dealers, they are obliged to provide the label of all tyres possibly mounted 
as OEM to all customers of new cars, but customers hardly ever can choose the tyre to be fitted 
on the vehicle that will be delivered to them51. As highlighted by ACEA in the call for evidence, 
customers are predominantly looking to vehicle-related information and a car emission label 
must be displayed in most Member States.    

Diverging obligations for  online marketplaces  and other dealers    and  insufficiently defined 
responsibilities of authorised representatives of third country manufacturers 

As a result of developments since the ELR and TLR were adopted, online marketplaces and 
online  search  engines  have  a  separate  set  of  obligations  around  labelling  as  defined  in  the 
Digital Services Act (DSA) 52. They benefit from being able to offer a wide range of products, 
but are (unless they sell their own products) not liable for the conformity of label display unless 
they become aware of illegal products, A physical shop dealer however has the label display 
responsibility. Both categories of dealers might sell the same products and a lighter regime for 
online marketplaces could result in lower costs for products in such marketplaces and hence a 
competitive advantage. As shown in this report, the separation of label display responsibilities 
between traders selling on an online marketplace on the one hand and online marketplaces on 
the other hand results in structurally higher occurrence of non-compliant labels.  

The DSA includes fully harmonised due diligence obligations including for providers of online 
marketplaces.  These  include  obligations  related  to the traceability  of  traders,  requiring 
platforms to  collect  and  to  make best  efforts to  verify identification data  of traders  (Article 
30), and  that  sellers are  able  to provide  information  on  their  products  sold  online 
via the platform (Article 31 DSA). Online platforms are also required to follow up on orders to 
act against illegal content.  Under the DSA, online platforms have an obligation to put in place 

46 Define your role - Compliance Services 
47 16872-Energy-efficient-product-legislation-Omnibus-simplification/Cfe. 
48 Study on consumer understanding of the EU tyre label applied since 1 May 2021. 
49 Professional tyre buyers show similar awareness levels as for energy related products (80%).  
50 For further detail, see the implementation report on the TLR.  
51 Most cars are equipped with tyres from a few different manufacturers (up to 5 or 6 for the most sold cars): as 
the Report explains, this is mainly for security of tyres supply and to put tyre manufacturers in competition.  
52 Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single 
Market For Digital Services and amending Directive 2000/31/EC. 

18 

 
 
effective notice and action mechanisms for illegal content (Article 16), but there is no general 
monitoring obligation in the DSA.  

Figure 3: Different sales channels and extent to which the entity selling to the end customer is covered by the 
dealer obligations in Regulation (EU) 2017/1369 

Retailers e.g. Eurocommerce, consumer organisations and several MSAs describe a particular 
weakness  around  authorised  representatives  of  third  country  manufacturers.  While  the 
concept was established to have an EU-based entity responsible for registering the models in 
EPREL, it only appears in the definition section of the ELR, in contrast for example  to the 
General Product Safety Regulation (GSPR) 53 that contains a full article on the responsibilities 
of such actors vis-a-vis the third country manufacturers on the one hand and MSAs on the other 
hand.  Since  the  responsibility  in  terms  of  placement  on  the  market  remains  with  the 
manufacturer, enforcement effectively becomes more complicated: MSAs need to identify the 
contact details of the manufacturer and then investigate their relationship. One MSA described 
authorised representatives under the ELR as a “postal forwarding service to a company based 
in a third country”. The representatives’ details are in some cases incorrect, contact details non-
existent or it is not clear which models or duties are covered by the mandate.  While there is no 
quantification of incidents with authorised representatives, EPREL data shows that about 15 % 
of models are registered by an authorised representative, making this more than an occasional 
set-up. 

Tyre label regulation does not specify/facilitate simplified label display  

Unlike the delegated acts adopted under the ELR, the TLR does not specify that a simplified 
class arrow  can be used  when the display of the  label  is  impossible or  impractical, such as 
comprehensive tyre catalogues or for the approximately 29 million tyres sold annually in the 

53 Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product 
safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and Directive 
(EU) 2020/1828 of the European Parliament and the Council, and repealing Directive 2001/95/EC of the European 
Parliament and of the Council and Council Directive 87/357/EEC. 

19 

 
 
EU online 54. Nested labels are also not specified for tyres. The result is unaligned layouts and 
uneven application as can be seen in below where some offers include a simplified class arrow 
for energy efficiency (not for wet grip and rolling noise aspects that are equally part of the tyre 
label) and some have arrows for all label criteria. One offer does not include a simplified arrow 
and just indicates the class 55. A second consequence of not having a simplified format specified 
is that the full-size energy label is used in catalogues resulting in heavy documents of limited 
usefulness for the end customer and car dealers requesting a simpler format56. 

Figure  4:  Tyre  offers  with  variants  of  simplified  label  presentations  (Amazon.de,  https://www.norauto.es/, 
gommadiretto.iteuroimportpneumatici.com/).  

2.2. Who is affected and how  

The problems described affect suppliers and dealers, the main stakeholder groups impacted by 
the ELR and TLR, MSAs and customers.  

Suppliers of energy-related products and tyres  

Suppliers are either manufacturers or in the case of third country manufacturers importers or 
authorised representatives. Suppliers are affected by current obligations to supply printed label 
for each unit and enter product information in EPREL. These come mostly in a box for energy 
labels,  tyre  suppliers  must  ensure  each  tyre  comes  with  a  label  stuck  on  the  tyre.  Annex  6 
provides an overview of the requirements per product.  

54 Online Tire Market Size | Global Analysis [2035].  
55 Only showing the class, but not the full range of the label is contrary to Article 6(1) of the ELR as  both elements 
are to be shown. 
56 cf. the implementation report on the TLR.  

20 

 
 
 
 
When non-compliance is tolerated or widespread, it affects the competitiveness of those who 
respect the rules. Suppliers also need to input data into public and compliance part of EPREL, 
based on which the label and PIS can be generated. 

The share of EU-based manufacturing varies across product categories covered by the ELR. 
The  strongest  domestic  production  position  is  in  boilers  and  heating  equipment  57. 
Approximately 2/3 of heat pumps sold in the EU are assembled in EU MS, though compressors 
— the core mechanical  component  — are predominantly sourced from Japanese and South 
Korean manufacturers. For light sources, EU-based firms such as Signify or ams OSRAM are 
structurally dependent on Asia for LED chips, drivers, and modules. Domestic appliances have 
many established European brands — BSH, Miele, Electrolux, Liebherr who still manufacture 
in  Europe,  but  Asian  and  Turkish  brands  have  growing  shares.    Consumer  electronics  — 
televisions, displays, and smartphones are overwhelmingly imported from China, South Korea 
and Taiwan, with only limited final assembly of televisions by Samsung and LG in Eastern 
Europe and little or no smart phone manufacturing in the EU.  

Dealers 

Dealers are required to display a label at the point of sale, make available the PIS and need to 
manage the switch date when rescaling of the label occurs.  

Dealers basically fall into two categories. The top of the distribution chain is dominated by 
large  wholesale  distributors  and  major  retail  chains  58.  They  operate  sophisticated  product 
management  systems  that  often  interact  systematically  with  EPREL  to  populate  their  e-
commerce and catalogue systems. At the other end of the retail segment are small retailers that 
sell  to  the  end  customer  (e.g.  regional  retail  chains,  independent  electrical  shops,  specialist 
kitchen  dealers,  installers),  often  SMEs.  The  sales  channel  structure  varies  across  product 
categories, and understanding those differences is essential for ensuring a label is transmitted 
through  the  value  chain  and  available  for  display.    .  It  makes  a  difference  whether  a  brand 
controls the value chain (e.g. smart phones) or not for example.  

Product  

Dominant sales channel  

Heating equipment 

Boilers and heat pumps 

Large domestic appliances 

Dominant  sales  channel:  manufacturer→  wholesaler  → 
installer:  ~65–75%  59  Low  single  digit  shares  for  direct 
brand sale and very low for online sale.  

57 Manufacturs  such as  Vaillant, Viessmann, BDR Thermea, Ariston, and Bosch Thermotechnik assemble the 
overwhelming majority of residential boilers sold in Europe  supported by EU-based component suppliers. 
58 E.g. consumer electronics chains such as MediaMarkt, Fnac-Darty and Curry or DIY multiples such as Leroy 
Merlin, Hornbach, and Kingfisher.   
59 Agora Energiewende. Analysis of the EU heating market, 2024.  

21 

 
 
 
Washing machines 

Ovens & cooking appliances 

Electronics and other    

Smartphones 

Light sources    

Leading  retail  channel  is  large  retail  chain:  ~45–50%  60 
Online share with EU wide estimate of 20-30 % 61. Direct 
brand sales in lower single digits.   

Large retail segment 40-50 %.  Share of SME dealers (e.g. 
kitchen  studies/kitchen  fitters)  is  higher  than  for  white 
goods.  Part of sales as B2B to contractors and builders. 

Brand  controlled  channel  dominates  for  new  appliances. 
Other channels are large electronic chains and online shops. 
SME dealer marginal and mainly for e.g. refurbishment or 
secondary /parallel import market. 

The  market  has  two  main  sales  channels.  The  first  is  the 
professional 
trade  channel  dominated  by  electrical 
wholesalers, B2B installers etc. The second is the consumer 
channel  dominated  by  DIY  chains  and  online  shops 
(particularly 
lamps  and  decorative 
luminaires). Online sales are higher than for other energy-
related products and rapidly rising. 

residential 

for 

Tyres  

The tyre market is split between tyres that get sold directly 
to vehicle manufacturers for new vehicles, the replacement 
aftermarket  and  online  sales.  The  aftermarket  is  the  most 
important segment.  

The supply chain length is directly relevant to label provision. When a product passes through 
two or three intermediaries before reaching the point of sale, there are multiple points at which 
the label (both physical and digital) may not be generated, lost, not passed on or mixed up. 

Tyre dealer obligations are specified for distributors, instead of dealers and are not defined for 
tyre fitters and services. The TLR addresses also vehicle dealers who are under a requirement 
to provide the labels for all tyres possibly fitted on the vehicle at the vehicle assembly plant to 
customers  purchasing  a  new  car.  This  concerns  approximately  60.000-100.000  car  dealer 
outlets in the EU. Car dealers are predominantly SMEs.  

End customers  

Customers  require  easy  access  to  appropriate,  accurate  information  prior  to  making  their 
purchase decision. Customers can be professional and private customers. End customers are 
supposed to see a label displayed at the point of sale, but this is not always the case. This means 
they risk making poorer purchasing decisions and miss out on energy bill savings and other 
benefits. Weak application e.g. in the case of tyre or heating labels affects them, in that mainly 
only informed customers might ask for the label if it is not shown before the purchase choice 
and  payment.  Customers  are  offered  energy-related  and  other  information  on  labels  about 

60 APPLiA Statistical Report 2023-2024.  
61 Based on GfK UK figure of 49 % online sales for white goods and knowledge that for the UK online sales are 
generally larger than for the EU MS. 

22 

 
 
 
 
 
products within scope at the point of sale and do not actively have to look for it. Few customers 
request additional information in the product information sheet, mostly ignoring the existence 
of it and of the EPREL database as is evident from the implementation reports.  

MSAs 

MSAs carry duties under both the ELR and the TLR and the overarching market surveillance 
framework established by the Market Surveillance Regulation (MSR) 62 which applies to all 
Union harmonisation legislation. In the specific context of energy and tyre labelling, EPREL’s 
compliance part supports MSAs’ actions. Current legal uncertainties limit the effectiveness by 
which they can enforce the rules, as does the amount/volume of non-compliant products or 
situations.     

SMEs:  As  explained  in  more  detail  in  Annex  V  of  this  impact  assessment,  the  retail  and 
wholesale sectors of energy-related products and tyres are consistently more SME-dominated 
than manufacturing equivalents — both in number and in employment share. Online retail is 
the retail segment most dominated by large enterprises. 

2.3. How likely is the problem to persist? 

Online  sales  can  be  expected  to  continue  expanding,  although  there  is  an  inherent  limit  for 
products that require servicing and installation and barriers to delivering big appliances over 
long  distances. Certain  compliance challenges  e.g. with  online  marketplaces and authorised 
representatives - may also be addressed in related ongoing policy files such as the European 
Product  Act,  the  MSR  or  a  revision  of  the  DSA's  obligations  –  or  under  the  reformed  EU 
customs’  rules  that  will  re-enforce  cooperation  for  enforcement  at  the  border.  Complex 
obligations imposed on suppliers and retailers or ineffective use of the information in EPREL 
are less likely to be addressed through parallel legislative pathways, but the European Business 
Wallet could bring at least once only identification for business.  Non-compliance rooted in 
unclear legal concepts could, in principle, be mitigated over time through guidance, case-law, 
and administrative practice and could also be addressed, to some extent, in individual product-
specific delegated regulations. The lack of clarity for simplified label display for tyres and risk 
of  diverging  layouts  could  be  contained  by  having  downloadable  templates  in  EPREL.  For 
tyres specifically, a full revision through the ordinary legislative procedure is available as an 
alternative  path.  While  the  energy  labelling  regulation  sets  the  basic  principles  for  energy 
labels, there is a limited room to adjust aspects of label supply and display modalities.  e.g.  the 
option  to  print  an  EU  energy  label  on  the  packaging  as  is  already  done  for  light  sources  is 
available. Other variants  such as printing the QR code directly on a product’s nameplate  which 
could offer additional benefits for compliance control and which met with stakeholder support 
during the reality check,  are however today not allowed. 63.  

62  Regulation  (EU)  2019/1020  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on  market 
surveillance and compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 765/2008 
and (EU) No 305/2011. 
63 E.g. a QR code printed on the packaging or the boxes containing batches of the same product model may permit 
to customs authorities to check if the products in scope of energy labelling are duly registered in EPREL. 

23 

 
 
3.  WHY SHOULD THE EU ACT? 

3.1 Legal basis 

The ELR is based on Article 194(2) TFEU. The TLR has a double legal base - Article 114 and 
Article 194(2) TFEU – which reflects the fact that tyre labelling pursues both internal market 
harmonisation objectives and energy objectives. 

3.2 Subsidiarity: necessity of EU action 

Energy  efficiency  product  legislation  —  covering  energy,  tyre  labelling  and  ecodesign 
requirements  —  is  a  fully  harmonised  scheme  meaning  that  Member  States  are  neither 
permitted to maintain diverging national requirements nor to fill regulatory gaps unilaterally 
once EU rules are in place. This reflects the reality that the internal market for energy-related 
products is inherently cross-border: products are manufactured or imported, traded, and sold 
across the EU without regard to national boundaries, and any fragmentation of the regulatory 
framework would directly impede the free movement of goods, distort competition between 
suppliers operating in different Member States, and undermine the level playing field that the 
single  market  is  designed  to  guarantee.  It  is  therefore  also  only  the  EU  legislature  that  can 
modify the obligations flowing from this framework.  Enforcement and surveillance under the 
framework are a national competence.  

3.3. Subsidiarity: added value of EU action 

Intervention  through  the  proposal  delivers  clear  added  value  that  could  not  be  replicated 
through any combination of national or soft-law measures. A coherent, EU-wide simplification 
of administrative obligations such as the responsibilities of suppliers and retailers — produces 
benefits  that  scale  across  the  internal  market.  It  can  reduce  compliance  costs  for  the  many 
businesses that operate in multiple Member States and ensure that MSAs across the EU work 
from  a  consistent  and  predictable  legal  baseline.  Targeted  improvements  such  as  enhanced 
EPREL functionality, clearer definitions, and more proportionate obligations generate systemic 
gains that, by their nature, can only be delivered centrally. Better application of the “once only” 
principle  to  reduce  national  “gold-plating”  and  administrative  procedure  in  relation  to 
eligibility  for  public  incentives  for  energy  efficient  appliances,  such  as  heat  pumps,  could 
significantly decrease market fragmentation and reduce costs for end consumers.  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1. General objectives 

The  general  objective  is  to  simplify  the  ELR  and  TLR  whilst  preserving  the  objective  to 
provide relevant  information to  allow  customers to  make an informed  purchase  choice  (on) 
energy use, environmental impacts and other relevant aspects of the product. 

4.2. Specific objectives 

The proposal has the specific objectives of: 

1)  Simplifying rules for suppliers and retailers; and 
2)  Improving compliance through more clarity and use of digital options.  

24 

 
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1. What is the baseline from which options are assessed? 

The  baseline  is  the  current  ELR  and  TLR,  in  which  soft  measures  such  as  continued 
improvements  of  the  EPREL  database  (for  which  no  change  of  the  legal  provisions  is 
necessary) are, and will continue to be, implemented for all policy options. This is for example 
the case for a wider use of plausibility checks for the data entered in EPREL to avoid incorrect 
information or better usefulness of the registry e.g. by adding brand names or images of the 
product models or explaining better what the QR code is about in labels. Incorrect entries in 
EPREL can also be targeted by non-legal measures and enforcement.  

 Current  EU-funded  supporting  actions  for  implementation  and  surveillance  such  as  under 
EEPLIANT4 (see Annex 7) and other EU projects would deliver in a no change scenario.  

Action to deal with incorrect information in EPREL  

There is no comprehensive estimate on the number of incorrect EPREL entries. An ongoing 
project under EEPLIANT 4 (report not yet published) investigated the EPREL information 
registered for 25.637 oven models and found that 204 (=0,8 %) of them declared an incorrect 
Energy Efficiency Index (EEI), the key compliance indicator 64. There have been occasional 
examples of fake labels and PIS, including for products that currently are not even in scope   
where manufacturers mimicked the energy label, but the full extent of this issue is not known. 
Incorrect  information  presents  a  problem  for  customers,  MSAs  and  a  disadvantage  for 
competing and compliant companies. The Commission continuously addresses this issue as 
part  of  its  responsibilities  of  managing  products  database  and  has  introduced  plausibility 
checks for the first product (lighting) that for example prevent the registration of unlikely or 
impossible pairs of parameters for a label 65. It can be expected that the recent removal from 
the  public  interface  of  products  registered  by  unverified  suppliers  (i.e.  registrations  pre-
dating the introduction of mandatory verification by the means of e-IDAS signatures and 
seals since October 2024 66 in accordance with Commission Implementing Regulation (EU) 
2024/994) already contributed to removing certain incorrect entries, in particular for lighting 
products that had the highest share of non-verified suppliers.  

5.1. Description of the policy options 

Two sets of policy options were assessed for this impact assessment which are identical for the 
measures  under  the  ELR.  When  it  comes  to  the  TLR,  policy  option  1  contains  a  revised 
empowerment  for  the  Commission  to  amend  the  technical  annexes  in  more  cases  than  is 
currently  possible  and  mainly  in  order  to  integrate  UN  ECE  regulations  more  rapidly.  Test 
protocols for tyres which are currently required to be supplied by tyre suppliers are replaced 
by a duty to upload the full testing reports in the restricted compliance part in EPREL. Policy 
option 2 includes all measures of policy option 1 and in addition suggests the opening up of 
the TLR for directly amending of all of  Tthe technical annexes. . The updating of annexes 

64 The analysis of this result is ongoing. https://www.eepliant.eu/. 
65 The industry association Lighting Europe endorsed plausibility checks and recommends expanding it to other 
products. 
66 https://energy-efficient-products.ec.europa.eu/suppliers_en#verification-of-suppliers-main-deadlines. 

25 

 
 
 
concerns two aspects: The lacking  technical specifications for  simplified label  display  for 
tyres and addition of a limited set of technical parameters currently not recorded in EPREL but 
necessary  to  correctly  identify  the  right  tyre  for  a  vehicle.  Policy  option  1:  Simplified 
obligations for suppliers and retailers, and improved compliance and limited changes to 
the TLR 

This  policy option contains  13  measures addressing both  policy objectives.  For the TLR, it 
includes  a  modified  empowerment  to  amend  label  aspects,  but  it  does  not  include  the  full 
technical specifications for simplified online and catalogue label display.  

Any changes to the TLR's technical specifications and annexes will materialise once the revised 
empowerment is  used in a delegated act procedure. Hence these impacts occur later and in 
subsequent  revision  rounds.  For  the  ELR,  principles  that  change  the  regulation  such  as  the 
clarified  responsibilities  and  legal  concepts  become  directly  applicable  once  the  Regulation 
enters  into  force,  however  the  effect  of  policy  measure  1  materialises  only  once  the 
Commission amended the product-specific delegated acts.  

Policy  option  2:  Simplified  obligations  for  suppliers  and  retailers  and  improved 
compliance.  Amendment  of  the  annexes  to  the  TLR  for  simplified  label  display  and 
parameters to be introduced in EPREL 

This policy option comprises all measures in policy option 1 plus two additional ones, namely 
1) amendments of the annexes to the TLR directly providing the technicalities of simplified 
label display for tyres for direct effect; and  

2) updated information requirements in TLR to make the tyre label and the EPREL registrations 
more effective and usable. 

The advantage of this option is that the effects from the additional measures  will be delivered 
after successful revision and do not depend on a subsequent delegated act procedure to use the 
new empowerment.  

Overview of measures contained in option 1 and 2:  

Measures  

M1  Removal  of  printed  label  by  default  in  the  ELR  regulation. 
Flexibility  for  the  Commission  to  determine  label  delivery  and 
display  in  delegated  acts  based  on  product  specific  review  study, 
reflecting  product  specifications  and  sales  channels.  The 
requirement for suppliers to upload an electronic image of a label 
into the product database is removed as redundant.  

The measure also contains a generalised right for dealers to request 
printed label from the supplier.  

M2 PIS fully electronic. Printed PIS no longer available on request.  

M3 Right for dealers to display labels on electronic shelf displays, 
a technical option which currently does not yet allow displaying of 
energy  labels  in  correct  size  and  resolution  but  is  expected  to  be 
available in the near future.  

Option 1  Option 2  

x 

x 

x 

x 

x 

x 

26 

 
M4 Suppliers to deliver either non-rescaled or rescaled label during 
4-month transition according to modalities in delegated acts. This 
measure  simplifies  the  current  duty  to  provide  two  printed  labels 
and gives manufacturers flexibility on their product model policy. 

M5 Retailers can phase-in rescaled label in display as part of stock 
management (no longer within 14 working days). This generalises 
a current exemption and allows selling under the non-rescaled label 
for all products. The period during which units with non-rescaled 
labels can be sold is extended from 9 to 12 months.   

M6 Responsibilities of authorised representatives are clarified and 
strengthened, and information an authorised representative needs to 
upload  in  EPREL  to  describe  the  mandate  received  from  the 
manufacturer. The measure also clarifies that installers who, as part 
of  their  activity  offer  for  sale,  hire  or  purchase  a  product  shall 
comply with the relevant obligations of dealers.  

M7 Obligation for online marketplaces to verify the registration in 
EPREL  before  offering  a  product  for  sale.  This  would  create  a 
sector-specific deviation from the principles in the DSA but provide 
a layer of protection against unverified third country suppliers and 
non-compliant products  

M8 DPP and EPREL to  be linked so  that information  in  EPREL 
does not need to be re-entered in DPP and suppliers need to become 
‘verified’ once. 

M9 Obligation for Member States to accept information in EPREL 
for  national  purposes 
if  suppliers  voluntarily  add  relevant 
documents such as such as Declaration of Conformity (DoC), third 
party certification or testing reports.  

M10  This measure introduces a new benchmarking and reporting 
exercise  and  publishes  the  information  registered  by  MSAs  into 
ICSMS,  aggregated  information  on  non-compliance  and  imposed 
penalties and indicatively benchmarks the frequency of and severity 
of  penalties  imposed.  Additionally,  it  is  clarified  that  MSAs  can 
reduce  the  public  visibility  of  the  product  in  EPREL  and  display 
appropriate warnings until the non-compliance ceases. 

M11 Modified empowerment for Commission to amend the TLR 
through delegated acts for improved regulatory alignment/technical 
details. This  measure widens  the current empowerment  to  amend 
for fuel efficiency, wet grip and noise and also in the light of market 
developments. 

M12Obligation  to  upload  actual  test  reports  for  tyres  in  the 
compliance  part  for  more  effective  market  surveillance  for  tyres. 
This  replaces  the  current  obligation  to  provide  protocols  of  the 
testing,  grading  and  measurement  as  per  TLR  Annex  VII  2  c.  is 
removed. 

27 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

 
M13 Addition of parameters in the public part of EPREL that are 
critical for correct assessment and choice including category of use, 
information on extended mobility, axle position, mission profile and 
tread depth, depending on the tyre category.  

M14  Inclusion  of  fully  harmonised  specifications  of  simplified 
label  display/nested  display  in  Annex  to  the  TLR.  This  measure 
directly  amends  the  current  Annex  IV  and  sets  out  the  technical 
details of the simplified label that can be used online and also for 
catalogues which list several labels. 

M 15 Removal of tyre labelling obligations for vehicle dealers. This 
implies that vehicle dealers are no longer obligated to show to end 
users the tyre label of tyres offered or fitted to the vehicle or any 
relevant technical material.   

x 

x 

x 

x 

5.2. Measures discarded at an early stage 

Several measures have been discarded at an early stage. 

Amendment of product-specific delegated acts 

The  possibility  to  not  only  amend  the  ELR  and  TLR,  but  to  also  directly  amend  some/all 
existing product-specific delegated acts  under the ELR to reflect the removal of the printed 
label default was considered and discarded. This would have made the effects of measure 1 
immediate  rather  than  sequenced.  However,  this  was  not  retained  as  it  was  not  considered 
feasible to comprehensively assess product specificities within the available time, in particular 
as there are . 

While removing the default rule in the ELR to have a printed label accompanying each unit  is 
rather straightforward, it would then also be necessary to determine for each possible supplier-
dealer-customer interaction and each product whether the transmission through the chain is still 
complete even if intermediary actors are involved. It would also have to be analysed to what 
extent the removal of the printed label obligation for suppliers results in an actual reduction in 
compliance cost rather than a mere shift of the burden to dealers.   Furthermore, Article 11(7) 
of the ELR requires the Commission to undertake a review study to support a product review 
or newly introduced product label. This seems to be the appropriate place to investigate also 
on the best interplay between suppliers and dealers and the best balance between digital and 
printed label provision. Any shift to digital label delivery and or display would also have to be 
submitted  to  consumer  tests  to  ensure  that  the  effectiveness  is  not  reduced.  No  stakeholder 
requested  direct  amending  of  the  product  specific  delegated  measures  for  simplification 
purposes  since  the  savings  effect  from  an  earlier  application  of  measure  1  was  considered 
relatively small compared to the risk of a regime resulting in less visibility and effectiveness 
of the label.  

Establish “digital only” labels for delivery by suppliers (while maintaining duty to display 
labels at the point of sale)  

28 

 
 
 
 
This  measure  was  put  forward by manufacturer associations  67. The printed label  would  no 
longer be transmitted by suppliers, and it would be the responsibility of retailers to ensure that 
labels are available to be displayed at the point of sale. No flexibility was envisaged to define 
the best interaction sharing between suppliers and dealers for label delivery and display. A right 
for  dealers  to  request  printed  labels  from  suppliers  would  be  ensured  so  as  to  cushion  the 
shifting burden in particular for smaller dealers  The printed energy label would possibly  be 
replaced by QR codes leading to EPREL at the point of sale, although it could not be estimated 
for how many displayed models this would be the case. This would oblige customers to seek 
out the information while shopping rather than being exposed to it automatically.  Most non 
manufacturer stakeholders voiced concerns as to how a digital by default regime for the energy 
label would affect the visibility and use of label. Denmark and Germany, in their responses 
provided  after  the  reality  check  meeting  made  the  point  that  shifting  the  responsibility  for 
printing to retailers will result in higher compliance cost due to the fact that a larger number of 
retailers with lower economics of scale would be in charge of printing labels.  The retail sector 
is  more dominated by SMEs who are not generally equipped to  automatise or integrate the 
printing process and do also not have the same economies of scale for printing labels.  It was 
considered by some stakeholders that this is somewhat contradictory to the simplification focus 
on SMEs. Several MSAs voiced concerns that in the absence of printed labels in boxes, the 
already high non-compliant incidents 

such   as missing energy labels, non-compliant misprints (e.g. incorrect formats, monochrome 
printing)  or  incorrectly  assigned  energy  labels  in  physical  shops  could  increase  further.  
Therefore, both the visibility of the energy label and its utility for consumers would suffer.  

Digital-only labels for HVAC appliances were supported by the HVAC industry and for tyres 
by Tyre Europe, but opposed in those cases and in general by the Italian MSA and consumer 
organisations. Several MSAs could consider wider digitalisation of HVAC labels where the 
customer cannot be expected to see the product and its packaging ( e.g. when sold as part of a 
service by an installer).  

There  is  no  regulatory  precedent  68  or  behavioural  evidence  on  how  consumers  react  in 
situations where a printed label is replaced by electronic version for energy-related products.  

A JRC study of 2022 69 performed behavioural tests with consumers with both physical food 
labels and labels for which part of the mandatory information had to be visited via scanning. 
While a certain discouraging effect on customers from needing to actively look for product 
information seems plausible to apply also for energy-related products, shopping for many 
food items in a supermarket with little time cannot be compared to taking a decision on an 
energy-related  product  worth  hundreds  of  euros.  The  methodological  set  up  of  the 
experiment also ‘hid’ one element of food information behind the scannable code (e.g. the 
best before date) whereas the other information was still on the label so the marginal effort 
to  scan  for  one  piece  of  information  might  not  have  been  worth  the  effort  rather  than 
signalling a more structural consumer issue with scannable labels.  

67 APPliA, supported by EHPA, Digital Europe, ZVEI.  
68 No major jurisdiction outside the EU has moved to replace mandatory printed energy labels with QR codes  – 
even though product registries exist in, for example, the United States and Australia. 
69 JRC Publications Repository - Using QR codes to access food information: a behavioural study with European 
consumers. 

29 

 
 
Full digitalisation  would  result  in  a  substantial  shift  of  compliance costs  to  the retail  sector 
since all stakeholders agreed that the objective of the ELR to display at point of sale is to be 
upheld. The physical cost of a printed label of lower double-digit cents when done at scale is 
only  a  small  share  of  the  total  product  cost,  well  under  0.1%  for  most  covered  appliances. 
Digital  only  is  also  not  cost-free.  There  is  a  cost  increase  for  regulators  (MSAs  for 
compensating campaigns and enforcement). Fully digitalising the EU energy label was rejected 
unequivocally by retailers, MSAs  70 and NGOs/consumer organisations. These contradictory 
views could not be resolved during the comprehensive stakeholder consultation process. The 
European  Parliament  has  also  in  the  past  attached  importance  on  disclosure  policies  being 
inclusive. Although an estimated 94% of EU households have internet access as of 2024, some 
still lack access to smartphones or have limited digital literacy.  

Re-enforced responsibilities  for online marketplaces  

Throughout  the  stakeholder  consultation,  retailers,  manufactures  and  MSAs  called  on  the 
Commission  to  make  online  marketplaces  the  responsible  economic  actor  where  product 
information or the label is not correctly presented and/or for third country products that are 
non-compliant and for which no responsible economic actor can be identified by MSAs. This 
would  deviate  for  products  in  scope  from  the  general  rules  under  the  DSA  and  creating  a 
separate regime for energy-related products. Actors with a broad product portfolio would have 
to  follow  different  rules  across  their  product  portfolio.  In  addition,  several  other  relevant 
legislative files are either in preparation or being reviewed (notably the MSR in view of the 
European Product Act), which might be more suited for such deliberations.  

Repeal the TLR and merge it with a possible future ESPR measure on tyres  

Since the Commission, in the context of the working plan under the ESPR, has included the 
consideration of possible requirements for tyres among the priorities, and since the ESPR in 
principle  allows  for  product  specific  measures/delegated  acts  to  include  ‘ESPR  labels’,  an 
option could be to merge the tyre label with an ESPR measure. However, this is at present a 
purely theoretical option as the latter is still at an early stage of assessment and development, 
and experience shows that product specific measures generally take at least 4 years to develop. 
This option has therefore been discarded for the purpose of this proposal. The TLR is, with the 
caveats  discussed  in  this  Impact  Assessment  and  the  TLR  implementation  report,  overall 
working well and tyres are already registered in EPREL, which stakeholders are used to work 
with. Any decision to merge or change the ELR and TLR (which have different legal bases) 
would need to be carefully considered once the case of specific ESPR-based measures for tyres 
has been fully assessed, in particular for safety aspects that are also covered by the tyre label. 
Major changes in the legal architecture at this stage would risk causing legal uncertainty and 
unpredictability for little practical gain. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

6.1. Impact of policy option 1  

6.1.1. Economic impacts 

The  main  type  of  cost  assessed  for  this  proposal  are  changes  to  administrative  costs.  The 
relevant stakeholders concerned by changes are suppliers, retailers and MSAs. The current and 

70 Belgium was the only MSA open to implement digital only. 

30 

 
 
proposed requirements apply equally to EU-based and third country manufacturers and hence 
do not affect relative competitiveness. The following details the economic impact per measure. 

Economic impact of M1:  

The obligation to have by default a printed label  accompanying each product unit currently 
results  in  an  estimated  EUR  83  million  per  year  in  costs  for  suppliers  for  347  million 
products 71 with energy labels sold on average in a year and assuming an average of EUR 0,24 
per printed sticker label 72.  Policy measure 1 proposes to remove the printed by default rule 
and provide the flexibility to specify the best regime for label delivery and  display for each 
product-specific  delegated  act.  There  is  therefore  a  clear  sequencing  and  the  extent  of  the 
savings depends on the details adopted when the currently 16 product specific delegated acts 
are reviewed.  

Labels would as a rule only be printed by the dealer at the point of sale to the extent needed for 
display. For products for which the review  shows that printed labels accompanying each unit 
are  no  longer  necessary  (e.g.  several  MSAs  indicated  that  they  could  accept  digital  label 
transmission  from  supplier  for  situations  in  which  the  label  will  mostly  not  be  seen  by  the 
consumer before the purchase such as for large HVAC that needs installation), savings will 
occur when only the labels needed for display get printed. No label printing would occur at the 
wholesale dealer level - instead the EPREL registration number/link or QR code would need 
to be transmitted - and no printed label would be involved in online sales. These savings are 
recurrent savings.  

Removal of the printed label default and flexibility for product-specific delegated acts would 
most  likely  not  fully  remove  physical  delivery  by  suppliers  and  hence  would  not  reach  the 
maximum estimate of EUR 83 million p.a.  This is because it can be expected that for some 
products it is more appropriate to keep supplying physical labels (at least in some instances) or 
some manufacturers might decide to include the printed label voluntarily in each box.  

Future rules could establish that it is sufficient to display the label on the product and/or the 
packaging – in such a case there is no saved printed label. For a manufacturer running large 
volumes, printing energy label  information  directly  onto  packaging  is  probably  cheaper per 
unit than sourcing, storing, and applying a separate sticker, but the change in compliance cost 
when moving to a printed label on packaging needs to be determined.  Other options such as 
the adding the EPREL identification number/QR code directly on the nameplate of the product 
could be envisaged for some products. This could to some extent replace the printed label, at 
least as far as its role as a reference for end customers (and recyclers) in the “post-sale” phases 
of the product lifecycle. 

Part of the compliance cost for displaying label in physical shops will be shifted to retailers 
who  sell  to  the  end  customer,  depending  on  the  product-specific  rules.  Order  sizes  vary 
depending on the size of the dealer at the point of sale and the product  – from as little as 5 
HVAC units per order for small specialist distributors for several months to 100 for white good 

71 This figure excludes tyres and lighting products that have separate regimes. Source. EIA Overview Report 2023 
VHK for European Commission DG Energy.  
72  An  estimate  of  on  average  EUR  0,24  (range  EUR  0,20-0.29)  as  costs  associated  with  supplying  a  physical 
energy label is given in a not yet published interim report for technical assistance on the setting up of labels under 
the ESPR and on preparation of an implementing act on their layout.  

31 

 
 
 
 
 
 
orders for large retail  chains  per months  to  1000 units per month for  consumer electronics. 
Assuming conservatively an order size per model of 20 on average across products would mean 
that instead of now 20 labels, only 1 would need to be printed at the point of sale (however 
possibly with a higher cost per printed label as scales are much smaller). Printed label cost in 
such a case would represent EUR 7 million (at a price per label of EUR 0.40) for retailers in 
contact with end customers. The effect can be contained through the option to request printed 
labels which is included in both options although this would itself involve cost due to the time 
needed to approach suppliers. In that case the costs go back to the supplier. The removal of the 
obligation to provide separate images of the label for tyres and under ELR also reduces the 
administrative  burden  for  suppliers,  albeit  it  minimally  as  many  already  rely  on  the  label 
generator feature in EPREL.  

In summary, net overall administrative cost recurrent savings of up to EUR 76 million can 
be expected across all affected actors If the removal of physical labels were to negatively affect 
consumer choice, there could be a trade-off between the specific objectives 1 and 2, hence the 
need for product specific assessments and delivery and display modalities.   

Economic impact of M2: PIS fully electronic. No more printed PIS upon request 

Since  electronic  PIS  transmission  was  already  adopted  for  all  products  and  printed  PIS  are 
hardly requested from suppliers, there is no direct reduction in administrative cost.  

Economic impact of M3: Right for dealers to display label on electronic shelf labels 

The significant upfront costs for electronic self-label systems make probably only sense for 
dealers managing many model variants with many units per model, there are advantages from 
integrating  label  display  into  the  wider  automated  price  and  stock  management,  connecting 
directly into the EPREL database, and with this not only saving costs but also minimising the 
risk of  erroneous  label display.  Dealers would make their own  judgment  on the cost of the 
infrastructure versus the time and cost avoided and thus can be expected to only use the option 
when  it  is  economically  advantageous.  No  economic  impact  from  this  measure  is  therefore 
quantified.  

Economic impact of M4: Simplified transition for suppliers  

Over the past few years, the Commission adopted on average one product review   per year  
under the  energy labelling framework.   Excluding lighting and tyres  from  annual  sales that 
have separate regimes for label delivery and do not use sticker labels in boxes gives an average 
of 24.7 million products in scope sold in a year, which for the 4 months transition period (1/3 
of the year) would need to deliver one printed label less and deliver the other label according 
to the modalities of the delegated act under this measure. This saves at least around EUR 2 
million  administrative  label  cost  per  product  group/year.  The  measure  was  broadly 
supported at the reality check.  

Economic impact of M 5: Simplified transition for retailers  

Removing the obligation for dealers to change the label on display within 14 working days and 
allowing them to  continue selling  stock with  non-rescaled labels  for all  products - not  only 
those covered by the exemptions in the current rules bring savings for dealers. The period for 
selling old stock is expanded from 9 months to 12 months. It is mainly smaller importers and 

32 

 
specialist retailers who cannot absorb large write-downs of unsold seasonal stock, hence this 
benefits those in particular. Longer sell-through periods can be expected to bring cost savings 
for retailers in particular for high volume items such as lighting products where relabelling or 
repackaging for each unit would become costly. MSA views on grandfatherering of stock with 
non-rescaled label differed as to whether it should be allowed and for how long. ￼The removal 
of the 14 working days for display effectively converts a recurring unplanned compliance cost 
for dealers into a planned stock management activity, which is inherently less burdensome. An 
average across all product groups of 24.7 million sold units are affected per year by a label 
transition, for which a display ratio of 1:20 is assumed (1.235 million),  5 minutes on average 
for changing the label(s) on display at the EU average wage of EUR 33.5 per hour in 2024 73, 
delivering EUR 3 million savings for retailers one-off when a label transition occurs.  

Economic impact of M6: Authorised representatives' responsibilities clarified 

This change affects 301.474 models registered by authorised representatives of third country 
manufacturers under the ELR and TLR who will need to upload a copy of the mandate from 
the manufacturer established outside the Union providing contact details of both manufacturer 
and the authorised representative and information on the duration of the mandate, and indicate 
for all registered models covered by the mandate. A mandate could cover more than one model 
number (i.e. be common for several or all models).   This results in one-off costs to gather 
document and upload in EPREL estimated at up to EUR 10 million.  

Direct cost benefits result from this measure mainly with the MSAs that will in the future save 
time and resources to follow up with authorised representatives. If one assumes each of the 129 
MSAs  jdeals  with  just  5  %  of  authorised  representatives  in  its  jurisdiction  (assumed  to  be 
allocated evenly for simplification), this results in 117 interactions per MSA per year or 15.000 
in the EU overall. If one assumes identification and location of the authorised representative 
and follow up take 8 hours without mandate rather than 30 minutes if the mandate is readily 
available in EPREL, staff cost savings for MSAs of EUR 3 million annually occur. This time 
saved can be used for additional enforcement activity. In addition to the time saved, there is 
also a non-quantifiable structural enforcement improvement when verification lags disappear. 
There will also be a more limited time and cost saving for authorised representatives not having 
to respond to as many inquiries. Indirect benefits occur with manufacturers and retailers in the 
EU subject to unfair competition when rules are poorly enforced.  

Additional duties upon authorised representatives which cannot be quantified stem from the 
added  obligations  to  provide  a  MSA,  upon  a  reasoned  request,  with  all  information  and 
documentation necessary to verify compliance in an official language which can be understood 
by  that  MSA  and  to  notify  MSAs  of  any  changes  in  the  tasks  performed  by  the  authorised 
representative on behalf of the manufacturer and in particular the finalisation of the mandate. 
These  occur  only  in  limited  occasions  of  either  suspected  nonconformity  and  or  end  of 
mandate. 

Economic  impact  of  M7:  Online  marketplaces  to  verify  in  EPREL  before  offering  a 
product for sale  

73 Eurostat. 

33 

 
 
 
The  measure  applies  to  EU-based  and  third  country  online  marketplaces  equally.  This 
compliance burden is concentrated on big online marketplaces (Amazon, eBay) who can work 
with APIs in which case marginal costs for checking are close to zero for products that are duly 
registered  in  EPREL  and  where  the  supplier  has  communicated  the  EPREL  identifier. 
However, this might not be the case for smaller local online marketplaces.  

If an online marketplace needs to verify manually, one can assume 10 minutes checking time 
per model on average. It is difficult to establish how many units are offered by retailers without 
API, but  conservatively  assuming  20 % of  currently listed items  in  EPREL would  result in 
EUR  2  million  in  annual  labour  cost  for  manual  EPREL  verification  across  online 
marketplaces, close to zero cost for non-manual. 

The most important non-quantifiable benefit from a mandatory pre-listing EPREL check is the 
changed incentive structure for third-country sellers. If a product cannot be listed without an 
EPREL registration number, non-registration is no longer a viable compliance strategy. This 
eases MSAs; workload.   

Economic impact of M8: Information in EPREL does not need to be re-entered in DPP/ 
both databases linked  

Suppliers are required to enter the parameters and technical information in EPREL for every 
model under the ERL and TRL.  A similar requirement will become applicable for the future 
registry under the DPP. Whether or not products subject to DPP requirements are required to 
have unit-level DPPs (a DPP for each individual product, rather than one per model-type), the 
model level information should be provided in accordance with the “once only” principle. This 
makes it necessary to ensure a link between the two central registries/databases, avoiding the 
need for suppliers to re-enter the information registered in EPREL for all registered models.  

One hour per registration is assumed for the purposesfor the future DPP registration. At average 
EU wage of EUR 33.5 per hour in 2024, the measure saves one-off administrative costs for 
suppliers of up to EUR 66 million for the 2 million models product models currently in EPREL 
that would not need to be spent to enter the same data again in the new DPP registry (depending 
on the degree of overlap of information requirements). Savings will continue to accumulate for 
future registrations if suppliers need to only register once and not twice.  

Economic impact of M 9: Member States to accept information in EPREL  

Since  the  number  of  incidents  in  which  information  is  requested  again  is  not  known,  it  is 
difficult to quantify the effect of this measure. However, at least for some product categories, 
this  can  be  consequential.  Especially  heating  appliances  where  many  Member  States  or 
subnational  public  authorities  operate  public  incentives  programmes  based  on  national 
“eligibility lists” (e.g. like the German BAFA lists 74), the effort to apply for being accepted on 
such lists and provide documentation to that effect can be substantial. The cost is both direct in 
terms of the administrative effort required, but also indirect in terms of the negative impact it 
has on effective competition in the Member States where such processes risk causing de-facto 
barriers for entry.  These savings will arise for suppliers, but they will also face one-off costs 
for voluntarily uploading certification or test reports in EPREL (as MSAs sometimes ask to 

74 
https://www.bafa.de/DE/Energie/Effiziente_Gebaeude/Waermeerzeuger_Portal/waermeerzeuger_portal_node.ht
ml . 

34 

 
 
have reassurances that the information in EPREL is correct/reliable). Under the “once only” 
principle, this would however be more attractive than providing such information to several 
Member States  bilaterally. The  economic impacts  are not  possible to  quantify but  the main 
impact would likely be the positive effect of stronger competition in the internal market that 
would be more material than any changes in administrative costs. 

Economic  impact  of  M10:  Commission  to  provide  benchmarking  report  on  MSA 
enforcement as reported in ICSMS every 4 years and MSAs can request Commission to 
hide model entries in EPREL until compliance ensured 

The measure results in direct costs with the Commission.  

Since MSAs are already under obligation to report results of in-depth checks under the market 
surveillance regulation the costs of performing and reporting in-depth checks are not accounted 
here again.   

Economic impact of M11: Modified empowerment for Commission to amend the TLR 
through delegated acts for regulatory alignment/technical details  

The shift from co-decision to delegated acts for technical details for label review and display 
produces  net  positive  economic  impacts  for  all  stakeholders  through  faster  regulatory 
adaptation,  reduced  compliance  planning  uncertainty  and  reduced  regulatory  uncertainty. 
However, the actual changes to fuel efficiency, wet grip and noise requirements would only 
occur once the delegated acts based on the new empowerment enter into force. In the meantime, 
as e.g. stated by BMW group in their contribution to the call for evidence,  E manufacturers of 
high performaning tyres have no means of showing this to customers as the tyre label is  and 
offerslittle  differentiation  and  therefore  little  incentives  to  manufacturers  to  improve 
performance.   

Economic impact of M12: Once only addition of test reports in compliance part for tyre 
labelling 

The proposed obligation for tyre suppliers to upload test reports or an explanation of the value 
extrapolation in the (non-public) compliance part of EPREL generates a one-off administrative 
cost per relevant registered tyre model 75. 

For new registrations, it is assumed that the cost will be partially compensated by the removal 
of the current obligation to provide protocols of the testing, grading and measurement pursuant 
to Annex VII, point 2 c, of the TLR. For existing entries, an update is necessary.  Parameter 
values reported in EPREL are assumed to be mostly exported from a supplier’s internal data 
system in a single operation covering tens or even hundreds of tyre types (models). Thus, the 
incremental  cost  of  this  measure,  with  a  duly  managed  internal  data  system,  should  be 
negligible. Furthermore, the supplier’s internal systems enables much lower costs than manual 
management,  should  a  MSA  ask  a  supplier  to  provide  documentation.  Assuming 
conservatively  that,  for  a  third  of  tyre  models  in  EPREL  (95.000),  upload  would  not  be 

75 If for a specific tyre size, performance is better than the “worst case” for the entire family featuring on the type 
approval documents, this must be the result of a test or the application of an extrapolation rule applied by the 
manufacturer. 

35 

 
 
automated but manual, with an average of 2 hours per model 76, the one-off administrative cost 
is estimated at approximately EUR 6 million. Currently, when an MSA wants to verify a tyre 
model, it must formally request the test report from the supplier, wait for a response and then 
assess  whether  what  was  provided  is  complete  and  authentic.  This  process  can  take  weeks, 
particularly if the supplier is a third-country manufacturer or an authorised representative. A 
reasonable assumption for the administrative handling time saved per compliance check if the 
testing report is available in EPREL is about 4 hours.  Assuming 1000 document checks per 
year, this results in EUR 134.000 saving recurring annually. Often it is not possible to establish 
compliance as key elements are missing from the information supplied which might lead MSAs 
to not undertake verification at all since in the absence of the information in test reports or on 
extrapolation only in-depth checks can determine that claims made for registered tyre model 
are correct. A laboratory test for tyres costs in the range of EUR 5.000–10.000 depending on 
the parameters tested. If access to the uploaded report avoids even 50–100 lab tests per year 
across the EU, the saving is EUR 150.000–EUR 1.000.000 annually (midpoint EUR 575.000) 
on avoided testing costs, before counting staff time. There is also a cross-benefit from EPREL 
holding test reports for the distinct safety enforcement communities, and an indirect positive 
impact on compliance when a supplier who has not conducted the required standardised testing 
is prevented from uploading 77.  

Four MSAs and the AdCO Tyre labelling chair that provided input on this issue during the 
consultation supported this addition. By allowing a summary of test reports the confidentiality 
concerns  expressed  by  Tyres  Europe  are  addressed  (noting  that  anyhow  the  documents  can 
only be accessed by MSAs in the restricted, non-public compliance part of EPREL). It can be 
expected  that  the  obligation  impacts  to  a  larger  extent  suppliers  of  low-cost  brands,  often 
imported  hence  also  benefiting  compliant  EU  manufacturers.  The  reason  why  adding  this 
administrative  cost  was  considered  appropriate  for  both  policy  options  (unlike  for  energy 
related products), is significant non-compliance and associated safety risks.  

Economic impact of M 15: Removal of label display obligations for vehicle dealers  

This measure removes the obligation to display the tyre label for car dealers in approximately 
10.8 million instances in which new passenger cars were sold (in 2025) in the EU 78 and also 
for sales of light and heavy-duty vehicles. Most car manufactures rely on the supply of tyres of 
the same size from different tyre manufacturers 79.  Displaying all the labels (up to 6 for the 
most sold models) in a vehicle offer places a burden on car dealers that brings no benefit for 
customers as they cannot chose the tyre to be mounted. Even if one can assume that most car 
dealers will work with EPREL in an automated manner, it saves car dealers in the future the 

76 The cost per model depends on three variables: whether the report can be uploaded as is, whether it requires 
confidentiality screening and whether the supplier must instead produce a structured summary (for instance where 
the original report is held by a third-party laboratory and cannot be shared in full). For suppliers that do not hold 
the test report directly — in particular importers and authorised representatives of third-country manufacturers — 
an additional coordination cost arises from having to request the document from the original manufacturer. 
77 Out of the total of 230 in-depth checks reported in ICSMS until end 2025, 5 products posed a serious risk and 
16 a high risk. Compliance was reported to be low in Member States. Ireland has posted test results of 36 tyre 
models in the ICSMS database and found just 33% compliance in 2024 and 51% in 2025. Germany has posted 
test results from 60 tyre models subjected to in-depth testing and found just 37% compliance in 2023, improving 
to 58% in 2024. 
78  European  Automobile  Manufacturers’  Association  (ACEA),  27  January  2026.  https://www.acea.auto/pc-
registrations/new-car-registrations-1-8-in-2025-battery-electric-17-4-market-share/ . 
79 For security of supply and to put tyre manufacturers in competition. 

36 

 
 
software interlink with EPREL to retrieve labels for display in offers as well as the printing of 
labels for display. For an estimated 35.000 car dealers in EU, this saves an estimated EUR 10 
million  EUR  annually  in  IT  maintenance.  One  can  assume  conservatively  marginal  zero 
printing costs when including it in offer documents, but with staff cost of 5 minutes to include 
the label into such documents still obtains savings of EUR 30 million annually.  

 Summary of administrative cost impact for all measures under policy Option 1  

One-off 
savings 
(EURm) 

Recurrent 
savings  (EURm, 
annually) 

One-off costs  

(EURm) 

Recurrent  costs 
(EURm) 
annually) 

M1 

M2 

M3 

M4 

M5 

M6 

M7 

- 

- 

- 

- 

to  83 

Up 
supplier ELR  

for 

7 for retailers 

- 

- 

for  suppliers 

2 
ELR  

3 for retailers  

3 for MSAs 

- 

- 

- 

- 

10  for  authorised 
representatives 

- 

- 

- 

- 

- 

Up to 2 for online 
marketplaces  

M8  

Up  to  66  for 
suppliers  

Yes 

M9 

Yes 

Yes 

M 10  

M11 

M 12  

- 

- 

- 

M15 

TOTAL  Up to 66 

- 

- 

0.7 for MSAs 

- 

- 

- 

- 

- 

6 for tyre suppliers 
who 
to 
need 
demonstrate  better 
performance  

car 

for 

40 
manufacturers 
and dealers  

to 

Up 
131.7 
including  public 
authorites  (up  to 

16 

37 

Up to 9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
128 
companies)  

only 

Most  of  the  quantified  savings  occur  with  suppliers  mainly  in  M1  and  M8.  The  effect  on 
retailers is a net cost of EUR 4 million annually from M1 and M5, contained by the addition to 
be able to request printed labels with suppliers under M1 included due to the higher share of 
SMEs  in  retail.  Part  of  retailers  will  benefit  from  better  enforcement  around  online  market 
marketplaces and authorised representatives. M 15 saves for car dealers due to the large number 
of new car sales in the EU. MSA benefits are recurrent and can contribute to better enforcement 
under  limited  financial  resources.  Customers  would  likely  benefit  from  other  but  non-
quantified benefits from stronger competition from strengthened application of the “once only 
principle” related to more consistent use of EPREL for national incentive programmes. 

6.1.2.  Social impacts  

The main direct social impacts of the measures contained in policy option 1 would arise from 
any impact on customers from amending the label provision scheme. Other indirect impacts 
would come from better compliance for energy-related products and tyres and more effective 
enforcement activities, for more compliant products and ultimately more energy savings.  

Social impact of M 1:  

The measure removes the rule to have a printed label in each box as a default. Since modalities 
for delivery and display of labels can be adjusted per product, end customers should benefit 
from tailored rules that ensure that, for heating appliances, an installer includes the energy label 
in its offer and in its advertisement as that is the moment at which a purchase decision is taken. 
Customers should not be affected negatively by the removal of printed labels accompanying 
each unit, since the obligation that a label is displayed at the point of sale is maintained. Dealers 
can still request a printed label from suppliers to contain the risk of missing labels in display. 
However, several MSAs warned of a negative effect of no longer having a printed label coming 
with each unit, even if most labels were not used for display. Any shift to digital label provision 
by suppliers and/or for display by retailers would have to be preceded by a consumer testing 
as part of the review study to see how consumers react to the fact that they need to actively 
look for the information rather to be exposed to it.  

Social impact of M 2: no more printed PIS 

Customers and retailers will in the future need to digitally access additional information in the 
PIS via the QR code as those will no longe be supplied printed upon request. However, it seems 
that such requests were rarely made in the past, hence this should not have a significant social 
impact.  

Social impact of M 3: Electronic label shelf display (once technologically mature enough 
to respect label display provisions)  

This measure is expected to not be applied immediately since the technology of electronic price 
displays is not yet sufficiently developed to allow for the electronic display of the energy label. 
Once the technology allows for the use of electronic shelf labels, the customer should not be 

38 

 
 
affected negatively as the label is placed in vicinity of products on display at points of close to 
the product or on it in a way that they are unequivocally associated to the specific model. In 
addition, the label and its information will be made visible for potential customers without any 
further  necessary  manipulation.  It  will  only  become  reality  once  the  label  can  be  properly 
displayed in correct size and resolution.  

Social impact of M 4 and 5: Simplified transition for suppliers and retailers 

The transition from a non-rescaled  to a rescaled label inevitably results in a certain degree of 
confusion for the consumer as, in the overwhelming number of cases, the ambition increases, 
and  the  scales  of  the  label  are  not  comparable  due  to  changed  testing  methods  and  higher 
ambition.  

Under the current rules, there is a confusion of the customer linked to the fact that suppliers are 
required to register a model for a short period of time to be able to comply with the requirement 
to deliver a rescaled label, even when the unit will be non-compliant after the rescaling. There 
is also a confusion because the customer will find two printed labels in the box with different 
scales such as the A+++ to D scale and the other one the A-to-G scale.  

Under  the  proposed  measure,  the  transition  period  allows  for  parallel  presence  of  the  non-
rescaled label and the rescaled one  in shops and online for up to 12 months. Consumers who 
do not  understand the rescaling  will for this period  be directed towards the appliances with 
non-rescaled labels which look better for the class in display rather than the rescaled ones and 
might be buying less efficient products with this– unless the transition is explained in shops by 
information in store or by shop assistants.  Article 7(3) of the ELR already requires Member 
States to accompany the introduction of rescaled labels with information campaigns and the 
Commission to support such activities and this article remains unchanged.  

A  solution  with  parallel  labels  for  12  months  with  simpler  transitional  arrangements  for 
economic  actors  and  reduced  waste  is  considered  preferable  over  a  variant  with  4  months 
confusion and complex obligations.  Grandfathering of stock commissioned before the switch 
date with the non-rescaled label is already practice in other jurisdictions e.g. Australia and it 
can therefore be assumed that the existing parallel labels have a limited confusing effect and 
the co-existing models with the different labels are similar to product variants (such as models 
in different colours) .  

Social impact of M 6: authorised representatives  

This measure is expected to improve the situation for customers since the changes are intended 
to allow MSAs to more effectively verify and ensure compliance for products registered by 
authorised  representatives.  This  in  return  should  ensure  that  products  from  third  country 
manufacturers  supplied  through  authorised  representatives  more  likely  comply  with  the 
declared label information. This is an indirect effect and will depend on actual enforcement 
activities at national level.  

Social impact of M 7: Online marketplaces  

The measure adds clarity to the responsibility of online market places, including the new task 
that an online marketplace should only offer products that have a corresponding registration in 

39 

 
EPREL. This limits cases of mimicked energy labels that are not covered by the ELR and also 
limits offers from non-verified suppliers.  

Social impact of M 8: DPP and EPREL once only  

No impact expected.  

Social impact of M 9: EPREL once only for national financial support schemes  

This  measure  contributes  to  more  effective  financial  incentive  schemes  with  cross-border 
competition  as  complying  with  EPREL  identity  verification  and  information  requirement 
should be acceptable for participating in financial support schemes.  

Social impact of M 10: Commission benchmarking report ICSMS  

Indirectly  contributes  to  a  conversion  of  enforcement  efforts  across  Member  States  and  a 
convergence of enforcement levels across Member States.  

Social impact of M 11: modified empowerment under the TLR  

This should ensure more effective tyre labelling as updating the label via delegated actsto cope 
with technological evolution and more stringent requirements set under UNECE or, in future 
ecodesign  requirements on tyres. As observed in the implementation report, effectiveness of 
the tyre label is increasintly limited as the vast majority of tyres are crowded in the two or three 
top classes80.  A more timely update of the annexes to the TLR is paramount to ensure that the 
tyre  label  offers  sufficient  differentiation  for  consumers  and  thus  interest  in  the  label  and 
searching in EPREL.  

Social impact of M 12: Testing report  

More  effective  compliance  control,  facilitated  by  uploading  in  EPREL  the  necessary 
documentation to mitigate the need of expensive testing, should increase consumer trust in the 
parameter values displayed in the label.  

Social impact of M 15 for vehicle dealers  

Tyre customers will no longer receive car configuration offers or invoices with labels for all 
tyres possibly to be mounted at the factory as, apart from premium or diplomatic sales, they 
are not given any possibility to choose one. Their choice is therefore not restricted compared 
to today. There will also be no confusion or partial duplication with the CO2 label for cars.  

6.1.3.  Environmental impacts  

The simpler transition  from  one label  to  another and extended period for  selling  stock with 
non-rescaled labels reduces waste from products that can generally be sold and marketed until 
12 months after the date of the label change. However, the effect cannot be quantified as it is 
not clear how many units are destroyed and what dealers do with unsold models.  

80 E.g. 87% of car tyres are in A, B or C for wet grip, and 100% in A or B for noise emissions. 

40 

 
 
 
In  terms  of  environmental  impact  for  347  million  EU  energy  labels  and  standard  label 
dimensions of 110x220 mm in the baseline, the printed label obligation results in 419 tonnes 
of backing liner81 (the discarded backside of the label which usually is silicone coated and not 
recyclable) plus avoided material for the label and 1.5 tonnes of Cyan, Magenta, Yellow, Key 
(CMYK)82 ink.  In policy option 1, this is reduced proportionally to the degree to which printed 
label  for  display  are  reduced.  The  environmental  footprint  of  the  energy  label  (change)  is 
negligible compared to  the environmental gains  in  terms  of CO2 and  energy savings of the 
policies  and  would  quickly  be  undone  when  insufficient  printed  labels  result  in  consumers 
buying  less  efficient  appliances.  Therefore,  the  product-specific  delegated  acts  will  need  to 
ensure that any changes to the current way in which labels are delivered does not result in lower 
effectiveness of label-related information. There is a small positive environmental impact when 
the obligation to add two printed labels during a rescaling period is removed. However, there 
is a reverse negative environmental impact from the temporary disclosure for consumers when 
the rescaled label coexists with the non-rescaled label when this results in consumers deciding 
against better performing appliances and products with a more ambitious label scale.  

6.2. Impact of policy option 2  

6.2.1. Economic impact  

Economic impact of M13: Addition of critical information requirements for public part 
of EPREL for tyre suppliers 

If all tyre registrations are used for the calculation and non-automated entry is assumed for all, 
EUR 6 million occur as a one-off cost for updating the information in EPREL. This is a 
conservative assumption. As noted for M12, tyre suppliers maintain internal product databases 
with all these tested / calculated parameters requested for the EPREL database. The incremental 
cost of the five new parameters along with the other required fields is virtually zero. When 
preparing  an  internal  database  extract  to  upload  through  EPREL’s  API,  it  would  involve 
selecting  five  additional  columns  which  are  then  automatically  uploaded  into  EPREL  and 
processed  for  use.  This  would  add  virtually  no  cost  for  future  tyre  model  registrations  in 
EPREL as exporting for uploading through the API is automatic and does not require manual 
intervention.  Some tyre manufacturers already provide this information voluntarily in EPREL 
and they would not have to adjust further.  

Detailed  data  in  the  central  registry  may  also  reduce  burden  on  tyre  manufacturers  and  on 
vehicle manufacturers when having to comply with other legislation such as Euro VI 83.  

Economic impact of M 14: Inclusion of fully harmonised specification of simplified label 
display/nested display in Annex of the TLR 

This  measure  is  the  immediate  result  of  including  clarifications  of  technical  requirements 
directly into the annexes, saving  time that would be required to revise them based on the wider 
empowerment. This means that earlier than in option 1 MSAs can enforce simplified labels for 

81 This is based on 50 g/m² which is a commonly cited industry parameter for standard silicone-coated glassine 
liner used in self-adhesive label stock. Cf e.g. AR160 TT BG40 BROWN FSC S692N SGP-BG40WH FSC_EN. 
82 Assuming 15% coverage at ~1 g/m² per colour pass. 
83 Currently all truck manufacturers have to request this data from all tyre suppliers providing OEM tyres: a query 
to EPREL may avoid these requests. 

41 

 
 
 
online display and ensure the diverging formats disappear and labels become harmonised and 
comparable for customers.  The measure is supported by tyre manufacturers.   

Summary of additional cost impacts for measures under Policy Option 2  

# 

M13 

M14 

One-off 
savings 
(EURm) 

Recurrent savings  
(EURm, 
annually) 

- 

- 

- 

- 

One-off  
costs 
(EURm) 

9.5 for tyre 
suppliers 

- 

Recurrent costs 
(EURm, 
annually) 

Yes 

- 

Total administrative costs and savings under option 2:  

One-off 
savings 
(EURm) 

TOTAL 

Up to 66  

Recurrent 
savings  
(EURm, 
annually) 

Up to 131,7 
including public 
authorities  
(Up to 128 only 
companies) 

One-off  
costs 
(EURm) 

Recurrent costs 
(EURm, 
annually) 

Up to 25,5 

Up to 9  

The  difference  with  policy  option  1  is  the  higher  one  off  costs  for  tyre  suppliers  (here 
represented with conservative assumptions on the extent to which manual data entry occurs).  

6.2.2. Social impact  

Social impact of measure 13:  

The  additional  information  will  allow  customers,  in  particular  public  procurers  and  fleet 
managers, and more generally users needing replacement tyres, to make better use of the entire 
information registered in EPREL. Moreover, if this measure increases the fuel efficiency for 
tyres  in  the  EU,  this  can  contribute  to  energy  savings  in  road  transport  which  can  help  to 
containing energy price issues in the current crisis (for those customers who use EPREL).  

Social impact of measure 14:  

It can be expected that simplified labels in e-commerce for tyres become more harmonised an 
once it is clarified how this has to be implemented and allowing customers to compare which 
is currently not possible in many instances. The more immediate clarity and enforceability for 
tyre labels delivers indirect benefit to customers (which in the case of tyres also relate to safety 
aspects) and a more uniform appearance for tyres sold online can contribute to better familiarity 
and use of the tyre label.  

42 

 
 
 
 
6.2.3.  Environmental impact  

There are very minor environmental impacts from reduced printing needs when simple labels 
can be used which is so far not possible. There can also be potential energy use savings when 
customers make better use of EPREL to find fue- saving tyres. 

7. 

 HOW DO THE OPTIONS COMPARE? 

1)    

Effectiveness, efficiency and coherence are the criteria that are used to compare the two policy 
options, with each given the same weight. Also, the delivery towards both policy objectives is 
given equal weight.  

Effectiveness 

Both policy options’ effectiveness is similar as they are the same for amending the ELR for 
both specific policy objectives and some elements for TLR.  

The  difference  lies  in  how  fast  and  effectively  the  ELR  and  TLR  are  simplified  for  tyre 
suppliers and retailers and to what extent tyre label compliance is improved. In policy option 
2,  the  full  technical  specifications  on  how  to  apply  a  uniform  and  simplified  label  become 
applicable and available once the measures enter into force. This means the details are available 
sooner for market actors and MSAs, which is both a simplification for tyre suppliers and also 
an improvement for compliance when full details are available.  

Early availability was considered important since in 2025, 1.660.783 visits for tyres in EPREL 
were recorded – resulting in more than twice the ratio of visits over energy-related products 
registered in EPREL84. This means that tyres are more visited for EPREL than energy-related 
products  and  a  quick  update  of  the  new  information  requirements  can  improve  the  user 
experience earlier.  

For an estimated 20-30 million tyres per year sold online in the EU, MSAs would be better 
equipped to check label compliance. In policy option 1, the possibility to use the simplified 
display  is  offered  immediately,  but  no  specifications  on  how  to  show  the  label  with  three 
categories properly, including for nested display. This will effectively mean that MSAs might 
not be able to enforce this provision.  

Efficiency:  

Efficiency  compares  benefits  and  costs  which  could  be  monetised  for  administrative  cost 
savings and cost additions relatively consistently for this IA, however other economic impacts 
around  indirect  effects  on  competition  or  better  compliance  etc.  could  not  be  quantified  or 
monetised.  

Policy options 1 and 2 differ in administrative costs by the quantified 9.5 million EUR one off 
for tyre suppliers. This will be applicable to both EU-based and non EU-based manufacturers, 
creating no competitive disadvantage for EU-based tyre manufacturers. This can be compared 
against less useful already registered information in EPREL when key parameters are missing 
and compromise the use of the entire set of information registered.  

84 In 2025, 1.660.783 visits in EPREL were recorded for tyres and 4.977.310 for all energy related products. Tyres 
had 245.167 registered models in August 2025 and energy related products 4.977.310. Putting registrations and 
visits for each group in relation results in 2.9 visits per registration for energy-related products versus 6.7 for tyres.  

43 

 
 
Coherence:  

Internal coherence is improved similarly in both policy options when the wider empowerment 
to revisit the label is aligned for the TLR with the procedures applied under the ELR. There is 
more coherence with the upcoming CO2 label for cars when car dealers do no longer have to 
display  also  the  tyre  label.  In  policy  option  2,  the  additional  full  inclusion  of  technical 
specifications for how the tyre label is to be shown in simplified class arrow mode and nested 
display improves internal coherence as such annexes exist for every product-specific delegated 
act under the ELR. In policy option 1, the technical specifications would only be added after 
the measures enter into force and the subsequent delegated act procedure amends the TLR for 
the specifications, hence possibly a few years later than for policy option 1. Internal coherence 
is  also  better  achieved  in  policy  option  2  for  the  additional  information  parameters  for  the 
public part of EPREL, since for other energy-related products no comparable usability gap for 
searches and comparisons exists.  

External coherence:  

Both policy options are similar for most parts since measures that would have created sector-
specific  deviations  from  general  rules  under  the  DSA  or  the  MSR  were  discarded  upfront. 
Policy option 2 can be considered more externally coherent when the TLR is directly amended 
now, rather than in a few years via delegated acts, possibly interfering with the planned tyre-
specific provisions under the ESPR.  

Policy option 

Effectiveness 

Efficiency 

Coherence 

Policy option 1  

Policy option 2  

+ 

++ 

++ 

+/++ 

+ 

++ 

8.  PREFERRED OPTION 

Based on the analysis above, the preferred option is policy option 2 which uses the occasion of 
the simplification to update the TLR for technical details for immediately improved compliance 
and enforcement and better use of EPREL for the product. It also makes the TLR more aligned 
with the ELR. Policy option 2 still brings substantial net administrative cost savings of up to 
123 million EUR p.a. annualised over a 10 year period. 

8.1. REFIT (simplification and improved efficiency) 

The proposed policy option is in line with the REFIT objectives of simplification and reduction 
of red tape as it explores means to reduce compliance costs for suppliers and retailers and also 
increases the benefits from the EPREL database and improves effectiveness of MSAs.  

8.2. Application of the ‘one in, one out’ approach 

The intervention amends the ELR and TLR. In accordance with the 'one in, one out' principle, 
this proposal generates up to EUR 123 million net annualised savings over a period of ten years 
for  companies.  The  generated  positive  impact  for  consumers,  procurers  and  MSAs  is  not 
included  in  this  monetisation.    While  test  reports  for  tyres  are  added  as  information  to  be 

44 

 
 
 
registered in the compliance part, the current obligation to supply test protocols of the testing, 
grading and measurement is removed.   

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

One reference point for monitoring the impact for policy objective 2 is the EPREL database 
that hosts all products with energy and tyre label and that can be used for analysis such as the 
evolvement of label class populations over time. It will also be possible to monitor whether the 
number of users for tyre labels goes up because of the additional information requirements that 
allow customers to  better find the right tyre for their vehicle. The  ICSMS database and the 
proposed benchmarking report every four years allows to monitor the results of in-depth checks 
for  all  products  within  scope  as  well  as  the  level  of  compliance  efforts  in  Member  States. 
Changes in compliance (including a decrease of display of labels in shops) can be detected by 
national MSA s compliance checking.  

For policy objective 1, the databases will not allow for monitoring and evaluating the effect of 
the  proposal  as  it  is  not  possible  in  EPREL  to  monitor  for  example  the  time  needed  for 
registration by suppliers.  Instead, surveys could  be undertaken either commissioned by the 
Commission  or undertaken as part of the EEPLIANT 4  (see  Annex  7) project  running until 
April  2029  to  understand  better  to  what  extent  rules  for  retailers  and  suppliers  could  be 
simplified and enforcement by MSAs could be improved. This was the approach taken also for 
the  implementation  reports  under  the  ELR  and  TLR  and  the  supporting  IPSOS/Centerdata 
surveys  of  suppliers.  Also  the  questions  received  in  helpdesks  (EPREL  helpdesk  and  the 
Compliance Service Desk - Compliance Services Compliance can be monitored. The following 
indictors could be used to monitor progress towards the specific objectives:  

1)  Simplifying rules for suppliers and retailers 

Proportion  of  interviewed  suppliers  reporting  a  reduction  of  administrative  costs  for  label 
provision (survey). 

Proportion  of  retailers  reporting  a  change  in  administrative  costs  around  the  obligation  to 
display a label at the point of sale (survey). 

2)  Improving compliance through providing clarifications 

Number of questions addressed to the Commission concerning ambiguous provisions in the 
ELR and TLR 

Evolution of questions received e.g. at Compliance Service Helpdesk.  

Number of ICSMS entries per Member State (ICSMS database). 

Proportion of MSAs that report a reduction in administrative costs around verifying compliance 
for the tyre label, compliance for products involving authorised representatives (surveys).  

Repetition of EU sweep exercise to monitor the improvement of compliance in online shops.  

45 

 
 
 
ANNEX 1:   PROCEDURAL INFORMATION 

LEAD DG, DECIDE PLANNING/CWP REFERENCES 

DG ENER PLAN/2025/2742  

CWP 2026 Reference: Annex I (New initiatives) Energy: Omnibus to simplify energy product 
legislation 

ORGANISATION AND TIMING 

The  Inter  Service  Steering  Group  (ISSG)  on  energy  labelling  and  ecodesign  (involving  the 
following DGs SG, AGRI, CLIMA, CNECT, COMM, COMP, DEFIS, EAC, ECFIN, EMPL, 
ENV,  ESTAT,  FISMA,  GROW,  JRC,  JUST,  IDEA,  MOVE,  REFORM,  REGIO,  RTD, 
SANTE, SJ, TAXUD, TRADE) was consulted in writing on 27th March 2026 and had until 8th 
April 2026 to comment on a draft impact assessment with problem statement, policy objectives, 
policy options and explanation on how the options will be assessed and quantified. 

In response to the comments received, the IA clarifies better the DPP-EPREL interaction as 
well  as  the  interaction  of  ESPR  with  the  tyre  label.  The  explanation  of  issues  related  to 
enforcement  for  products  offered  on  the  EU  market  through  authorised  representatives  was 
strengthened. EU customs rules were added to the policy context and the baseline.  

CONSULTATION OF THE RSB 

An upstream meeting took place on 11 March 2026. The RSB comments highlighted the need 
to  show  trade-offs  and  distributional  effects,  transparency  around  new  administrative 
obligations, clarify the continued validity of the policy objectives of the current framework and 
the need for evidence to substantiate the outcome of stakeholder input.  

The draft impact assessment was submitted to the RSB on 22 April 2026 for a scrutiny meeting 
with  the  RSB   on  20  May  2026.  The  non-qualified  opinion  provided  by  the  RSB  after  this 
meeting suggested the following improvements:  

1)  To improve the analysis of non-compliance 
2)  Better  differentiation  of  the  two  policy  options  and  improved  assessment  of 

social/consumer impacts  

DG  ENER  amended  the  problem  statement  for  non-compliance  by  integrating  evidence  on 
non-compliance  gathered  in  the  two  implementation  reports  and  other  exercises  since.  It  is 
explained better how evidence of actual non-compliance in markets is difficult to obtain given 
the risk-based approach generally used for verification of non-compliance. The analysis of non-
compliance  has  been  strengthened  and,  in  that  context,  it  is  made  clear  that  compliance 
checking  rarely  ever  reports  the  cause  of  a  non-compliance  e.g.  whether  it  is  intentional  or 
rooted in lacking awareness.  

The revised impact assessment report contains a more detailed description of the content of 
each  policy  measure  and  an  assessment  of  the  social  impact  for  each  measure  was  added. 

46 

 
Comments regarding the economic assessment of single measures in the checklist of the RSB 
were also addressed. The cost assessment for tyre suppliers in option 2 is expanded.  

Finally, the rationale, presentation and comparison of the two policy options was strengthened 
so that it is clearer for the reader that the proposed policy measures under the ELR are mostly 
regrets and therefore identical for both policy options. Rather than artificially creating policy 
options  with  only  a  subset  of  measures,  the  description  of  discarded  measures  shows  that 
alternatives  were  considered.    Total  cost  figures  for  each  policy  option  help  the  reader  to 
understand the differences better. The additional content of policy option 2 is the immediate 
integration of clarifications around the tyre label and the addition of an updated list of technical 
parameters necessary to identify the right tyre e.g. in EPREL. In option 1 this impact would be 
delayed since the changes would have to be integrated once the omnibus proposal is finalised, 
the empowerment widened and then used for a review.  

EVIDENCE, SOURCES AND QUALITY 

Evidence gathering for this impact assessment was carried out in-house at the Commission  

The IA builds in large part on:   

•  The Commission’s implementation reports on the ELR 7 and ELR 8 which are adopted 

alongside this impact assessment and the proposal.   

• 

Insights gathered from  market  surveillance, complaints  received by the Commission 
and the ICSMS database, reports of compliance activities carried out in 2024 and results 
thereof  provided  by  Member  States  representatives  in  the  Consultation  Forum  and 
Adco sectoral formation for energy labelling and eco design.   

•  Analysis of EPREL statistics 

•  Two representative IPSOS/Centerdata surveys on the use and understanding of the tyre 
label and modernised energy labels under the ELR and EPREL, carried out in 202585 

•  Reports  and  analysis  undertaken  as  part  of  EU-funded  projects  supporting  the 
implementation of the energy and tyre labelling frameworks in particular EPPLIANT 
Concerted Action (see Annex 7) and Compliance Services. 

•  Freely accessible commercial data and industry reports. Sales data was taken from the 
Ecodesign  Impact  Accounting  (EIA)  Overview  Report  2023,  VHK  for  European 
Commission DG Energy (October 2023, revised March 2024). All figures are EU27. 
2020 is the EIA's most recent historical reference year.     

•  Feedback  from  stakeholders  during  the  preparation  of  the  proposal  (including  the 
implementation  dialogue  on  14  October  2025,  input  provided  during  and  after  the 
reality check on 8 December 2025 and the call for evidence in early 2026. See Annex 2 

85  Study  on  consumer  understanding  of  the  EU  tyre  label  applied  since  1  May  2021  and  Study  on  consumer 
understanding of the EU energy labels applied since 2021.  

47 

 
 
48 

 
 
 
ANNEX 2:   STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

Stakeholder  input  has  been  gathered  at  various  steps  using  also  existing  expert  committees 
supporting  the  preparation  of  product-specific  delegated  regulations  under  the  ELR  and 
supporting MSAs for both the ELR and TLR. This was combined with input occasions open to 
the wider public (reality check and Call for Evidence (CfE)).  

2.1. Implementation reports on the ELR and TLR 

The  delivery  of  implementation  reports  to  the  European  Parliament  and  the  Council  is  an 
obligation under both the ELR and TLR. It was decided to not adopt them separately by their 
deadlines  (summer  2025)  but  instead  include  them  in  the  simplification  initiative.  The 
Consultation  Forum  on  Energy  Labelling  and  Ecodesign86  a  formal  stakeholder  body 
established  under  EU  law  that  brings  together  57  representatives  from  MS/EEA,  industry, 
manufacturers, retailers, importers, consumer organisations, environmental groups, and other 
interested  parties,  and  the  ADCO  sectoral  formations  for  energy  labelling  and  tyre 
labelling87 under the MSR were both invited to provide input into the implementation reports.  

The focus of the questions was on:  

−  The experience with the shift to modernised labels and the establishment of the product 

registry  
level of market surveillance activities and results of compliance checks  
the benefits of EPREL for compliance activities by MSAs  

− 
− 

While no specific questions on simplification were asked, the experience with implementation 
still provided insights into aspects that could be simplified.  

14  MS/EEA  members  (AT,  BG,  DE,  DK,  EE,  IE,  IT,  LT,  LV,  NL,  PT,  SI,  NO,  IS)  
represented in the Consultation Forum and/or the Adco energy labelling group and  7 non-MS 
members  of  the  Consultation  Forum  (APPLIA,  Digital  Europe,  EHI,  EHPA,  EPEE, 
EuroCommerce, Lighting Europe) provided  input during April-June 2025.  

Responses from MSAs showed a vastly different level of activities across Member States, with 
some of them also indicating there is in certain years no activity for products within the scope 
as the surveillance budget is shared with other policies. 2 Member States have an earmarked 
surveillance budget for energy-related products.  The importance of EU-funding for national 
enforcement  activities  was  evident,  in  particular  for  smaller  Member  States  and/or  costly 
laboratory  testing.  Member  State  contributions  collectively  suggest  EPREL  is  valued  as 
supporting tool for market surveillance tool, but also pointed to issues such as low consumer 
and retailer awareness of the database, early phase problems with unverified suppliers (issue 
which is solved since such entries are blocked now) and data quality issues such as duplicated 

86 Register of Commission expert groups and other similar entities. 
87 Adco sectoral formations. 

49 

 
 
entries  or  incorrect  data.  Several  MSAs  are  not  yet  using  more  advanced  features  like  the 
ICSMS cross-link. 

Responses  from  non-MS  members  came  exclusively  from  business  members  of  the 
Consultation Forum and overwhelmingly from manufacturers (6 out of 7). Data quality issues 
in EPREL were raised and insufficient market surveillance activity listed in all contributions. 
EPREL’s usefulness was assessed in a very different manner - Lighting Europe promoting 
EPREL as the repository for all information, to replace documents on manufacturer websites, 
EHPA  arguing  the  contrary.  DigitalEurope  promoted  the  future  DPP  registry  as  central 
registry. Several positions called for improving EPREL filter functions.  The proposal to move 
to digital-only labels was already raised by several manufacturer associations and the EHPA 
contribution  mentioned an estimate of EUR 400 per printed energy label  without providing 
details and which possibly includes mainly overhead costs.  Eurocommerce is positive about 
EPREL’s usefulness, but calls for more interoperability in legal provisions. APPLiA praised 
EPREL as helping against non-compliant products and producers but warned of overreliance 
on light document checks that can be done with EPREL/AI support at the expense of in-depth 
compliance checks.  

2.2. IPSOS/Centerdata survey on use and understanding of modernised EU energy labels 
and tyre label  

A representative survey across 10 EU Member States88 conducted by Ipsos and Centerdata in 
early 2025 on behalf of the European Commission  aimed to understand better the usefulness 
and understanding of selected modernised EU energy labels and EPREL. The survey included 
around 20.000 consumers (online survey via IPSOS panel), 125, professional buyers, 200 
suppliers,  200  retailers  of  energy-labelled  products  (all  per  telephone  interviews).  Main 
findings reveal that consumers highly value energy efficiency information and often use it in 
conjunction with factors such as price and brand during their decision-making process. This is 
particular the case for white goods. Understanding of the label and its components seems high. 
The upper part of the label showing energy related performance is used more by consumers 
than the icons on non-energy aspects in the lower part. EPREL seems well known to retailers, 
but less used by and known to consumers. Suppliers reported mixed experiences with EPREL 
registration, retailers report higher levels of satisfaction and relatively few problems managing 
the change from the non-rescaled to the rescaled label. Overall, the research offers significant 
insights into consumer behaviour concerning energy-related product information and identifies 
opportunities for enhancing energy labelling systems and EPREL functionalities.  

A separate representative survey89 to inform the implementation report on the TLR across ten 
EU Member States90 interviewed 4.590 private consumers (online survey via Ipsos panels), 
100  professional  buyers  (such  as  fleet  managers  and  procurement  specialists),  40  tyre 

88 Belgium, Croatia, France, Germany, Hungary, the Netherlands, Poland, Portugal, Romania and Sweden. 
89 Study on consumer understanding of the EU tyre label applied since 1 May 2021 .  
90 Belgium, Croatia, France, Germany, Hungary, the Netherlands, Poland, Portugal, Romania and Sweden. 

50 

 
 
suppliers, 200 tyre dealers and distributors, and 150 vehicle dealers and distributors (all 
via telephone interviews).  

The revised EU tyre label (in force since May 2021) is used by 40% of private and 80% of 
professional buyers. Tyre dealers are broadly familiar with the label, but tend to discuss it only 
when customers ask, which is rare. Tyre suppliers generally understand their legal obligations, 
but report challenges around space constraints in promotional materials and confusion over the 
"nested display" rule for online labelling.  

Both  surveys  will  soon be  published.  2.3.  Implementation  Dialogue  on  energy-efficient 
product legislation on 14 October 2025 

Documents and minutes 

Link  to  website:  Implementation  dialogue  on  energy  efficient  product  legislation  with 
Commissioner Dan Jørgensen - Energy 

Link to the Summary Report: Conclusion ID  

The Implementation Dialogue on energy efficient product legislation was held on 14 October 
2025  in  Brussels  with  23  organisations  representing  manufacturers,  retailers,  installers, 
consumers, online marketplaces, NGOs and market surveillance experts.  
The dialogue addressed implementation issues, options for simplification and the role of market 
surveillance  to  ensure  energy  savings,  compliance  and  a  level-playing  field.  A  balanced 
participation across value chain actors and products was ensured.  

List of participants 

•  Administrative Cooperation (AdCo) group for Eco-Design and Energy Labelling 
•  APPLiA – Home Appliance Europe  
•  BEUC – The Consumer Organisation  
•  CEFACD – Comité Européen des Fabricants d’Appareils de Chauffage et de Cuisine 

Domestiques 

•  CEMEP – European Committee of Manufacturers of Electrical Machines and Power 

Electronics 

•  CLASP  
•  Digital Europe 
•  Ebay 
•  ECOS 
•  EDRA-GHIN 
•  EEB 
•  EHI 
•  EHPA 
•  ETRMA 
•  EuroCommerce 
•  Eurovent 
•  GCP Europe 
• 
• 
•  Lighting Europe 

Independent Retail Europe 
Independent market surveillance expert (DK) 

51 

 
•  PROSAFE 
•  RVO (NL) 
•  SME United 

Main issues discussed/main outcomes 
The discussion consisted of two parts:   

•  Key  challenges  faced  in  implementing  the  energy  efficient  products  legislation  and 

ways to improve and simplify legislation; and 

•  The role of market surveillance for implementation, challenges of MSAs and proposals 

for more effective surveillance. 

Main outcome 

Almost  all  stakeholders  expressed  support  for  energy  efficient  product  legislation.  Where 
adequately  enforced,  it  contributes  to  competitiveness  of  industry,  a  strong  single  market, 
innovation, consumer information and affordability. There is a need for clarification of certain 
concepts, better communication to citizens, more digitalisation, need for faster adoption of the 
rules  and  longer  implementation  periods.  Market  surveillance  requires  more  effort  and 
resources, as well as increased EU coordination and competence in this area. The rapid rise of 
online  shopping  and  direct  imports  by  consumers  pose  challenges  for  consumer  trust  and 
market surveillance.  The participants praised the collaborative and transparent processes for 
the energy efficient product legislation. 

Overall implementation progress and assessment 

•  Independent  Retail  Europe  recalled  that  customers  chose  price  over  label, 
EUROCOMMERCE shared the observation that a good energy label is regarded as a 
quality mark, but that in some cases and without financial incentives this might not be 
enough to stimulate a change in purchase.  

•  Some labels for heating, cooling ventilation appliances and tyres label are in practice 

not used to their full extent for informing consumers.  

•  ETRMA (now TyresEurope) pointed to the specificities of the tyre label with market 
average performance for energy efficiency still only D and the persistent launches of 
inefficient models since the final consumer often does not get to see the label of the 
tyre.  As  a  solution  ETRMA  proposed  (financial)  incentives  for  purchasing  more 
efficient tyres. 

•  BEUC  called  for  online  market  spaces  to  be  held  accountable  for  third  country 

producers  

•  CLASP added that enforcement is inconsistent across Member States.  
•  Hans-Paul Siderius (academic and RVO/NL) cautioned about having too much hope 
and emphasis on simplification of EE with product legislation becoming increasingly 
complex, interoperable, digitalised etc.  

•  CEMEP and Lighting Europe pointed to the fact that the savings potential at product 
level for their applications is becoming increasingly small and that a move to a systems 
level approach is desirable to bring more benefit.  

52 

 
 
 
 
 
•  DigitalEurope was the only stakeholder to caution against horizontal e.g. repairability 
and  standby  requirements,  suggesting  closer  involvement  of  the  industry  to  create 
guidelines.  

•  GCP  Europe  (Installers)  suggested  a  broader  application  of  interoperability  as  was 

done for the common charger standard.  

•  SME United mentioned the problem  of additional  administrative burden at  national 

level (e.g. DK national rules adding to solid fuel heater EU rules).  

On the process of developing the rules 

•  Delayed product reviews by the Commission are a problem. ECOS, EEB and CLASP 

called for more resources at the European Commission. 

•  Many interventions called on the European Commission to share again, as was done in 

the past, the full legislative draft texts for feedback prior to adoption.  

•  CEFACD and DigitalEurope highlighted the need to have synchronised requirements 

across legislations 

On EPREL 

•  Most interventions considered the EPREL product registry to be a beneficial, practical 
tool  and  a  good  example  for  the  future  digital  product  passport  (DPP),  with  some 
pointing  to  possible  improvements  for  labels,  including  digital-only  energy  label, 
visibility and user-friendliness.  

•  Many  participants  mentioned  that  EPREL  has  the  potential  to  be  a  tool  for  regular 

(automated) checks on compliance of the registered products.  

•  EHI  pointed  to  persistent  incorrect  entries  undermining  EPREL’s  potential  and 
recommended  flagging  non-compliant  products  in  EPREL  (this  idea  supported  by 
EuroCommerce).    

•  Retailers report more benefits from EPREL, while manufacturers are more critical.  
•  CLASP called for giving EPREL more visibility with consumers, GCP Europe more 

user-friendliness for installers.  

On ESPR/ DPP:  

•  When  interventions  referred  to  the  ESPR  and  the  digital  product  passport  (DPP) 
envisaged in  it, different  views were expressed:  Ebay and  CEMEP  said  DPP could 
become the one-stop shop for all information and also the chair of the Adco group saw 
opportunities  for  MSAs,  whilst  others  (EUROCOMMERCE,  Independent  Retail 
Europe, APPLiA etc.) warned of too big ambition and felt the current EPREL system 
works well.  

•  GCP Europe and DigitalEurope warned of overlaps between EPREL and DPP.  
•  Prosafe made the point that enforcement will also be crucial for DPP and the ESPR’s 

success.  

On policy stability:  

53 

 
  
 
  
  
  
  
  
  
  
•  A  considerable  number  of  speakers  (e.g.  Eurovent,  Eurocommerce,  CLASP, 
Lighting  Europe,  SME  United)  emphasised  the  value  of  policy  stability  and 
predictability for investment certainty, including for related legislation under EU Green 
Deal such as the EPBD, EED and RED, circularity, but also customs regime.  

•  One intervention (EPHA) pointed to the difficulty for manufacturers to take investment 
decisions in an ever-evolving policy context with different changing rules on F-Gases, 
PFAS and product regulation and suggested a regulatory freeze to allow manufacturers 
to adapt. EEB took the opposite view and said EU own manufacturers are often better 
on regulated aspects.  

•  One  intervention  criticised  overlapping  regulation  of  products  and  components 

(APPLIA).  

•  Several interventions emphasised the importance of giving industry sufficient time to 
implement the product regulation requirements, but for Commission to speed up the 
review process. 

On the simplification idea to remove obligation to deliver a paper label in each box:  

•  The  ADCO  chair  expressed  support  for  simplification  but  emphasised  that 

enforceability must be ensured.  

•  “Digital  by  default”  for  the  EU  energy  label  supported  by  several  manufacturers 
associations. Other stakeholder groups insisted on the need for a proper assessment of 
impacts from no longer delivering printed labels.   

•  Eurocommerce insisted it should not be the retailers’ obligation to print, consumer and 
market surveillance representatives insisted that the change should not result in lower 
compliance.  

•  Simplification needs to respect the main objective ensuring the customer has a label 
displayed to inform them before the purchase and does not need to e.g. scan the QR 
code to obtain more info BEUC.  

•  ECOS: Paper labels are vital for the effectiveness of the label. 
•  EHI  and  GCP  Europe  both  supported  digitalised  labels  as  heating  and  cooling 

appliances are bought by an intermediary  

•  Independent  Retail  Europe  highlighted  that  digital  access  to  the  label  data  is  very 
useful but that essential and safety information needs to physically be with the product. 
•  EDRA-GHIN and SME United mentioning the 2-week transition time from  the non-
rescaled to the rescaled label during which dealers need to change the label in display 
as a challenge.  

On harmonisation 

•  The merits  of harmonisation  and standards were  emphasised e.g.  by  EUROVENT, 
Lighting  Europe,  CEFACD,  Digital  Europe,  ERTMA,  Independent  Retail 
Europe, Adco group Chair 

•  CLASP also mentioned the slow progress on standards and processes dominated by 

industry voices (suggestion for Commission to take more ownership of this).  

•  EHI: Harmonised standards improve competitiveness. 
•  Two  interventions  (EEB  and  Adco  chair)  mentioned  the  need  to  have  harmonised 

methodologies to represent real life conditions (better).  

54 

 
  
  
  
  
  
  
On online shopping and imports from third country manufacturers:   

•  The exponential increase of online shopping and direct imports from outside the EU 
threaten  the  level-playing  field  for  compliant  suppliers/retailers  and  undermine 
consumer protection.  

•  Legal  gap  around  online  marketplaces  underlined  by  many  (several  manufacturers, 
MSAs, Prosafe and SME United), many supported making online marketplaces (EU 
based  and  third  country  based)  legally  responsible:  several  manufacturers,  several 
retailers, some MSA experts, ECOS and BEUC.   

On market surveillance:  

•  There was a call (e.g. from Adco chair, EHPA, and Prosafe) to further address non-
compliance,  particularly  but  not  solely  for  online  sales.  APPLiA,  ECOS  and  EEB 
called for an EU entity for market surveillance. Both manufacturers and retailers offered 
to  cooperate  in  efforts  to  improve  compliance  e.g.  Joint  Actions  under  the  MSR. 
Participants referred to the lack of testing capabilities, high costs of in-depth testing. 
•  ETRMA (now TyresEurope) added to this that claims on the tyre label often are not 
met in real life which is why more physical testing and coordination between member 
states is necessary. 

•  RVO/NL pointed to the conceptual weakness of national enforcement for an EU wide 

single market and called for more cooperation  

•  The independent market surveillance expert suggested AI crawlers for compliance 

checking and replicable testing elements. 

•  EEB pointed to disinformation campaigns steered from outside on some of the products 

within scope.  

•  EUROCOMMERCE highlighted that products  that are taken to  be tested are often 

held by MSAs for lengthy times before they return to shops.  

•  CEMEP  made  the  point  that  enforcement  is  less  of  a  crucial  factor  with  B-to-B 
products, here programmes to accelerate replacement of old stock are more important.  
•  Independent Retail Europe called for better coverage of low-value products in market 
surveillance. Lighting Europe referred to India as best practice for enforcing rules in 
online shops.  

•  ECOS highlighted that the Commission estimate of 10% non-compliance is from 2019 
and that they expect the number to be higher now. This is why they also support EU-
wide coordination. 

•  Other suggestions for more effective enforcement included:  

·  Better cross DG cooperation on enforcement aspects (Digital Europe) 
·  Improve circularity by recycling e.g. copper from old products, and improve 
the second-hand market, also for products coming from outside of the EU 
(Ebay) 

·  Improve the quality of the data in the ICSMS database (Prosafe)  
·  Involve private certification bodies (EUROVENT)  
·  Work with guidance to ensure unform implementation and help installers and 

SMEs. (ADCO chair, SME United)  

55 

 
  
  
  
  
  
  
  
·  Some concepts used in legal texts need clarification such as “professional 

repairer” or “installer”. (SME United)  

Reality check meeting on 8th December 2025 

The Reality Check meeting on energy efficient product legislation took place on 8 December 
2025 in Brussels and via Webex. The meeting was announced on DG ENER’s website and was 
open  to  all.  In  addition,  invitations  were  sent  to  the  Consultation  Forum  and  the  two  Adco 
groups.  

It united around 160 participants, 139 organisations of which 15 entities were already at the 
table of the implementation dialogue. Companies and associations representing manufacturers 
were  clearly  the  most  represented  group,  the  category  of  others  include  energy  companies, 
chambers of commerce,  consultancies etc.  

Event  announcement:  Reality  Check  on  energy  product  legislation  -  Energy  -  European 
Commission  

The agenda of the meeting:   

•  Experiences, obstacles, good practices, better implementation/compliance: 

Improving usefulness of labels, notably for heating and cooling  

 
  Clarification  of  modalities  to  display  the  EU  tyre  label  in  advertisement  and 

technical documentation  

  Clarification  of  MSA  duties  and  rights  and  other  elements  to  improve 

compliance  

•  Possible simplification ideas:             

  Suppliers’ obligation in  the Energy  Labelling  Regulation  to  accompany each 
product with a printed label and obligation to provide printed labels and PIS on 
dealers’ request  

  Obligation  to  include  both  existing  and  upcoming  rescaled  label  during  4 
months  /obligation  to  replace  existing  labels  on  product  display  by  rescaled 
label in 2 weeks under the Energy Labelling Regulation (in shops and online)  

  Simplification of registrations in EPREL  
  Possibility of revisiting aspects of the EU tyre label via delegated acts  

56 

 
  
 
Figure 5: Breakdown per stakeholder group for the reality check meeting  

List of participants  

•  A.I.S.E.  
•  AKS Envirotech Inc 
•  Alstom 
•  AMD 
•  AMDEA 
•  ANEC 
•  ASERCOM 
•  APPLiA 
•  Assotermica - ANIMA Confindustria 
•  ATIEL 
•  Austrian Federal Economic Chamber (WKO) 
•  Bavarian State Ministry of the Environment and Consumer Protection 
•  Belgian Federal Ministry of Public Health and Environment 
•  Belgian Federal Public Service Health, Food Chain Safety and Environment 
•  BEUC 
•  Bosch Home Comfort 
•  Bosch, Worcester 
•  Bridgestone Europe NV/SA 
•  Brother International Europe 
•  BSH Home Appliances S.A. 
•  BTTA GmbH 
•  Bulgarian Commission for Consumer Protection 
•  Bulgarian Ministry of Economy and Industry 
•  Bulgarian State Agency for Metrological and Technical Surveillance 
•  Bureau Veritas 
•  Canon Europe  
•  CEFACD 
•  CEMEP 

57 

 
 
•  CEN 
•  CEPE Aisbl 
•  CINEA 
•  CLASP 
•  Computer & Communications Industry Association (CCIA) 
•  Consumer Protection and Technical Regulatory Authority of Estonia 
•  Czech Ministry of Industry and Trade 
•  Daikin Europe 
•  Danish Energy Agency  
•  Danish Environmental Protection Agency 
•  Danish Safety Technology Authority 
•  Department of Energy Security and Net-Zero, UK 
•  Digital Europe 
•  DLA Piper 
•  Dutch Ministry of Infrastructure and Water management 
•  ECOS 
•  EEB 
•  EHPA 
•  Enterprise Ireland 
•  EPEE 
•  EPTA 
•  Estonian Ministry of Climate 
•  ETRMA 
•  Eurochambres 
•  European Biogas Association 
•  European Vending & Coffee Service Association 
•  Eurovent Association 
•  FEICA - Association of the European Adhesive & Sealant Industry 
•  Finnish Energy Authority 
•  Finnish Ministry of Economic Affairs and Employment 
•  Finnish Ministry of the Environment 
•  Finnish safety and chemicals agency 
•  Finnish Transport and Communications Agency Traficom 
•  Flint Global  
•  FONDITAL SpA 
•  FPS Economy 
•  Free ICT Europe Foundation 
•  French Ministry for ecological transition 
•  French Ministry of Energy 
•  FuelsEurope 
•  GCP Europe 
•  Geological Survey of Sweden 
•  German Chamber of Commerce and Industry 
•  German Environment Agency (UBA) 
•  German Federal Ministry for Economic Affairs and Energy 
•  German Ministry of Environment, Climate Protection and the Energy Sector 

58 

 
•  Groupe Atlantic 
•  GS1 
•  HKI Industrieverband e. V. 
•  HP Inc. 
•  Hungarian Ministry of Energy 
• 
• 
• 
• 
• 
• 

I&P Europe 
Independent Retail Europe 
Indorama Ventures Mobility Obernburg GmbH 
Irish Department of Enterprise, Tourism and Employment 
Italian Ministry for the environment and energy security 
Italian National Agency for New Technologies, Energy and Sustainable Economic 
Development (ENEA) 
ITI 

• 
•  Korea International Trade Association (KITA) 
•  Latvian Consumer Rights Protection Centre 
•  LGE 
•  Lighting Europe 
•  Miele & Cie. KG 
•  nec Europe 
•  Nordic Ecolabelling 
•  Norwegian Water Resources and Energy Directorate 
•  NoW Partners 
•  Orgalim 
•  PANASONIC 
•  Permanent Representation of Greece to the EU  
•  Plastics Recyclers Europe 
•  Polish Ministry of Economic Development and Technology 
•  Portuguese Agency for Competitiveness and Innovation  
•  Portuguese Directorate-General for Energy and Geology 
•  Region of Crete 
•  Ricoh Europe 
•  Risk Miner GmbH 
•  RREUSE - Reuse and Recycling European Union Social Enterprises 
•  RTE France 
•  Rud Pedersen Public Affairs  
•  RVO (Netherlands Enterprise Agency) 
•  Samsung Electronics 
•  SECIMAVI 
•  Shimano Europe 
•  Signify Netherlands B.V. 
•  Slovak Ministry of Economy 
•  SolarPower Europe 
•  Spanish Ministry of Industry  
•  Stadtwerke München 
•  Sustainable Energy Authority of Ireland 
•  Swedish Chemicals Agency 

59 

 
•  Swedish Energy Agency 
•  Swiss Federal Office of Energy 
•  TenneT Holding BV 
•  The Japan Electrical Manufacturers' Association (JEMA) 
•  Topten Switzerland and Europe 
•  TUV Rheinland 
•  Tyres Europe 
•  UNIFE - The European Rail Supply Industry Association 
•  UNITI 
•  Utopia 
•  Vivo 
•  Westdeutscher Handwerkskammertag 
•  WKB Lawyers 
•  Wuppertal Institute for Climate, Environment and Energy  
•  Yamaha Motor eBike Systems (YMESG) 
•  ZVEI 

The discussion was already entering technicalities on certain measures that could be envisaged 
for simpler and more effective rules under the ELR and TLR. It notably included a more in-
depth exchange on the manufacturer suggestion to move to digital by default for the EU energy 
label. One of the main outcomes of the discussion was strong agreement for an approach that 
gives flexibility in the framework to determine the product specific best way to deliver and 
display the label.  

On improving usefulness of labels, notably for heating and cooling  

•  GCP  Europe,  EPEE  and  EHI  emphasised  the  role  of  installers  including  for 
combining appliances and that individual product labels cannot reflect the reality of the 
combinations installed.  

•  Also  building  environment  matters  for  heating  products.  (WHKT  (German  regional 

chamber, EPEE). 

•  EHI  cautioned  against  future  merged  heating  technology  label  under  the  ELR, 

RVO/NL supported it.  

•  Italy strongly advised keeping printed labels. Italy supports installers having to show 

the full label to their clients, but wonders how this can be verified by MSAs.  

•  The EEB also supported the proposal of consumers being shown the label and receiving 
information, especially before the purchase. They added that consumer awareness for 
heating  and  cooling  label’s  existence  must  improve;  adding  a  QR  code  leading  to 
EPREL in the offers could help. 

•  BEUC also expressed support saying that the usefulness of the label is linked to how 
visible it is to the consumer. In shops the labels and best products can easily be spotted. 
They further highlighted that the label needs to be displayed in online shops as well, 
also  in  the  case  of  heating  and  cooling  products,  because  many  consumers  research 
products there first before reaching out to an installer or energy service provider.   

60 

 
  
  
 
On clarification of modalities to display the EU tyre label in advertisement and technical 
documentation  

•  TyresEurope stated that the label led to more quality tyres being put on the market 
(supply side) and improvements for wet grip and noise, but that this is not reflected in 
the purchase choices which remain based on price (demand side). They called for the 
improvement of the visibility of the tyre label  

•  The  tyre  labelling  AdCo  chair  called  for  more  clarity  in  the  TLR  on  technical 

documentation that has to be uploaded  

•  The BE MSA called of better technical information removing the unnecessary parts, 
but adding other elements. They argued in favour of making the upload of test reports 
mandatory, instead of the protocols, explaining that measured values are necessary for 
market  surveillance  purposes.  They  called  also  for  more  clarity  in  EPREL  on  the 
relevant version of the  UN ECE standards that were used for testing. 

•  Tyres Europe opposed test reports obligation for reasons of confidentiality 

On clarification of MSA duties and rights and other elements to improve compliance  

•  IT  underlined  that  more  funding  is  needed  to  improve  market  surveillance.  Italy 
suggested  allowing  MSAs  to  recover  testing  costs  also  when  products  are  found 
compliant. 

•  NL proposed introducing EU-level testing to complement tests conducted by Member 

States.  

•  To improve compliance, Lighting Europe suggested introducing a button in EPREL 
to  directly  report  products.  The  Commission  explained  that  this  would  signify  a 
restructuring  of  EPREL  and  while  it  is  being  considered  it  can  currently  not  be 
developed further due to lack of resources. 

•  EHI  pointed to  the problem of companies making false claims in  EPREL and these 

false claims staying in the data base.  

•  APPLiA  praised  EPREL  and  highlighted  that  not  registering  is  illegal  and  that  not 

having a label or QR code is dissuasion.  

On ESPR, DPP and the link with EPREL 

•  The German MSA expressed support for EPREL and added that EPREL can facilitate 

the rollout of the DPP. 

•  DigitalEurope, IT and CCIA asked for clarification on whether EPREL and DPP will 
exist in parallel. The Commission explained that the DPP database being built is using 
EPREL as a foundation, but will be wider and more complex and thus take time to be 
set up. An integration in the future is not excluded.  

On possible simplification ideas regarding the printed label  

•  EEB cautioned of “digital only” label display as disadvantageous to certain customer 
groups, or to many retailers who are often SMEs. But full support for digitalisation of 
the PIS. 

•  APPLiA  offered  that  retailers  should  have  the  right  to  ask  for  printed  labels  from 

manufacturers.  

•  NL  expressed  concern  about  a  responsibility  “ping-pong”  between  suppliers  and 
dealers. While they do support the full digitalisation of the PIS, they are unsure about 

61 

 
 
  
 
a digitalisation of the label. They see this as a shift in responsibility to the dealer not a 
simplification. NL suggests allowing dealers to use electronic shelf displays if the EU 
energy label can be corrected displayed.  

•  IT  insists  on  printed  labels  per  unit  to  make  sure  they  are  always  and  correctly 
displayed. But it was supportive of a simpler transition phase from the non-rescaled to 
the rescaled label, or for air conditioners where more combinations are possible than a 
physical label can show.  

•  Eurocommerce underlined that retailers need to be supplied with a printed label for 

display and should not be the ones to have to print it.   

•  APPLiA  responded  by  suggesting  a  solution  be  found  that  would  guarantee  printed 
labels for SME retailers. They added that they expect few retailers to need this service.  
•  Belgium stated that an ideal solution for every single situation does not exist and hence 
supported the digital label because that would work well for the majority of situations.  
•  The EEB wondered how many people can access QR codes and thus EPREL on their 
phone. They added that only knowledgeable consumers would go on EPREL to look 
for  a  model.  Digitalisation  is  helpful,  but  a  label  is  needed,  e.g.  for  second  hand 
purchases where the box no longer exists.  

•  APPLiA mentioned that their dealers ask for the EPREL number because it simplifies 
processes for them. They acknowledged that the EPREL app is not used much but argue 
that the website is.  

•  BRV/BIPAVER (DE retread industry) explained that in the case of tyres, most labels 
are thrown away, creating unnecessary waste. They pointed to the fact that 40 million 
tyres were sold in Germany alone in 2024 and support digitalisation of labels.  

•  Tyres Europe agreed that a digital tyres label is attractive, but stated that enforcement 
in small tyres shops is difficult. The usefulness of the tyre label is limited due to lack 
of awareness of consumers  

•  BEUC reiterated that the label needs to be visible at the point of sale. Small retail shops 
tend to not fully comply with the rules, and obligating dealers to actively look for the 
label for display might worsen this    

•  Lighting  Europe  mentioned  the  special  regime  for  light  source  where  the  label  is 
printed on the packaging and said they could accept digital label in addition. In their 
view the modalities for label delivery are best  addressed in delegated acts for every 
product, not generally.  

•  Denmark  supported  this  proposal,  adding  that  white  goods  in  stores  should  always 

have a printed label while other products might not need one.  

•  Solar Europe confirmed this explaining that solar PV are not typically shopped for in 
a store which is why a printed label might not be needed. They added that putting a 
label directly on the panel could impact its energy production which is why they also 
advocated for product-specific considerations.  

•  NL agreed that providing a label on the box on a case-by-case basis seems promising. 
It  needs  to  be  clear  who  is  responsible  for  the  label  being  shown  whenever  the 
regulation asks for a label. Sweden also supportive.  

•  APPLiA agreed that a product-specific approach is useful, but added that the channel 
through  which  a  product  is  being  sold  could  additionally  be  considered,  e.g.  if  100 
washing machines are being sold in one store, one printed label could suffice. 

•  CCIA suggested that second-hand sales be considered where a digital label could be 
useful since many products that are refurbished need a rescaled label and energy class 

62 

 
afterwards. This could become feasible with a digital label. Miele clarified that in the 
case of second-hand sales, labels can always be found in EPREL via the model number. 
•  The Commission asked about the idea of putting a QR code or an EPREL number on a 
product  directly  to  be  able  to  recover  information  years  later.  There  was  agreement  
from several stakeholders that this could be a useful option.  

•  The UK inquired about a new feature in EPREL that excluded uses for the UK  

On possible simplification ideas regarding the double label 

•  APPLiA explained that the 4-month transition period with double label might not be 

needed in case of digitalisation   

•  Italy supported the idea of removing one of the printed label in every box for the 4 
months  transition.  They also  proposed keeping  the four-month period to  allow for a 
voluntary anticipated labelling and ecodesign. They further suggested getting rid of the 
obligation  to  sell  products  with  the  non-rescaled  label  before  a  certain  number  of 
months due to enforceability issues. Products put on the market before a rescaling are 
usually sold until the very last unit, regardless of an expiration date.  

•  NL agreed that more leniency with the four-month period is possible, but argued that a 

limit is needed, suggesting nine months.  

•  Denmark highlighted the experienced usefulness of a case-by-case approach as done 
for lighting (9 months) and tumble dryers (18 months) and suggested 12 months for 
sale of old stock. 

On components and double regulation 

•  APPLiA raised the issue of components of regulated products being also regulated at 

product level.  

•  Italy expressed support for this suggestion as it is the final product’s energy-efficiency 
that  matters,  not  the  components.  They  pointed  to  the  fact  that  manufacturers  often 
produce their own components and are thus interested in them being compliant.  

•  NL argued that this would create a loophole for components manufacturers who could 
then put their products on the market declaring that they are intended for that use only 
and thus avoid complying with the labelling regulation. They explained that such an 
exemption could only be supported if there was a technical specification that would for 
instance guarantee that a specific motor or fan can only be used in a specific kind of 
product.  

•  EPEE  also  supported  APPLiA’s  suggestion,  explaining  that  that  would  simplify 
compliance, reduce manufacturing costs and emphasise the energy performance of the 
final product.  

•  Miele pointed to the difficulty that if older models have to be repaired, if there are no 
exceptions for components, newer and more efficient motors would have to be used in 
the repair. This could require a new wiring to make the motor and product compatible 
making the repair less affordable. 

The  written  contributions  submitted  after  the  reality  check  meeting  of  8th  December 
2025: 

After the Reality Check, the following 10 entities submitted written contributions:  

63 

 
  
  
  
APPLiA 

BE 

APPLiA calls for digital energy labels as an alternative to printed ones, 24–36 
month 
implementation  periods,  elimination  of  double  regulation  for 
components,  product-specific  ESPR  label  layouts,  reinstatement  of  early 
document  sharing  before  Forum  meetings,  and  removal  of  Substances  of 
Concern from the ESPR scope. The technical annex includes specific proposed 
changes to the lighting and cooking appliance ecodesign regulations. 

Belgium  expressed  support  for  simplified  display  options  of  tyre  labels  in 
catalogues,  offers  and  online  sales.  Belgium  also  called  for  clarifications  on 
versions  of  UN  ECE  regulations.  Further,  they  suggested  clarifying  whether 
simulations and extrapolations are acceptable replace for tests in determining 
the classes for the label. Belgium stressed the importance of EPREL for market 
surveillance  and  supported  requiring  test  reports  to  be  uploaded  in  the 
compliance part for tyres of EPREL. 

CCIA 
Europe 
(Computer  & 
Communications 
Industry 
Association 

Strongly  pro-digitalisation,  supporting  replacement  of  printed  labels  with  e-
labels, citing potential savings of €120 million annually in compliance costs. 
Flags  that  ESPR  does  not  explicitly  allow  digital  labelling.  Supports 
postponement of Ecodesign sunset clause from 2026 to 2028 in ESPR. Cautions 
against  changing  market  surveillance  rules  prematurely  given  recent  new 
frameworks (GPSR, DSA, PLD) not yet evaluated. 

DE  

DK 

Rejects the manufacturer proposal to remove the printed label obligation, calling 
it  a  burden-shifting  exercise  that  would  harm  SME  retailers,  increase  non-
compliance, and undermine label visibility. Can support digitalisation of label 
for products not typically displayed in shops. Call to correct current deviation 
in some delegated acts that exempts installers from showing the full label of 
heating products in offers. DE supports extending the relabelling deadline from 
14  days  to  one  month,  keeping  9  months  to  sell  with  old  label,  potentially 
abolishing the on-request printed PIS option. Germany proposed a mandatory 
display of the entire energy label in online retail e.g. in the image carousel so 
that not only energy efficiency is visible. Additionally, they welcomed the idea 
of requiring either the EPREL number of QR code on the packaging or product 
to  allow  for  long-term  access  to  the  relevant  information.  They  expressed 
support for a non-exhaustive list of options in the framework regulation so that 
delegated acts can identify appropriate regime. 

tyres,  DE  supports  wider  empowerment  for 

On 
label  review.  They 
acknowledged the value of the proposed additional mandatory parameters and 
documents in EPREL for market surveillance, supported allowing a simplified 
display option of the label in catalogues, offers and online sales as well as the 
option  to  revisit  technical  aspects  of  the  TLR  in  delegated  acts  if  MSAs  are 
being taken into consideration 

Denmark expressed support for digitalising the label for products that are not 
typically displayed in shops and was supportive of requiring installers to show 
the label to consumers in offers. They recommended complementing this with 
the promotion of EU-funded comparison tools for these products and targeted 
guidance  for  installers.  Denmark  emphasised  the  importance  of  labels  being 
physically displayed in shops and expressed concern about shifting burden to 
retailers,  citing  the  risk  of  lower  compliance.  They  suggested  a  product-by-
product approach in delegated acts.  

64 

 
  
  
  
  
  
  
EHPA 

Additionally,  Denmark  expressed  support  for  improving  the  effectiveness  of 
EPREL for market surveillance. They explained that the current model where 
test reports and other technical documentation is only delivered on request is 
insufficient and causes delays. Expand compliance part of EPREL.  

Denmark recognised the double labelling as a significant burden and support 
longer period for selling stock with old label (12 months).  

Place  requirements  at  the  finished  product  level  rather  than  on  individual 
components, avoid duplicated reporting across EPREL and the Digital Product 
Passport,  synchronise  revision  timelines  across  different  legislative  files 
affecting heat pumps (Ecodesign, F-Gas, EPBD etc.), and stick to announced 
timelines.  Allow  digital  energy  labels  as  an  alternative  to  printed  ones 
(estimating €20 million in avoidable annual costs to the sector); simplify the 
double-labelling  obligation  during  the  4-month  rescaling  transition  period; 
improve  EPREL  so  manufacturers  can  update  performance  data  without 
changing the model identifier. On refrigerants, it flags the unresolved overlap 
between the F-Gas Regulation and the upcoming PFAS restriction, urging the 
Commission to clarify how the two frameworks will interact. On digitalisation, 
it warns against product-level obligations being introduced through non-product 
legislation (such as the Network Code on Demand Connection), arguing grid 
flexibility  requirements  are  better  handled  through  smart  meters  and  home 
energy  management  systems  rather  than  through  mandatory  heat  pump 
hardware changes. 

EuroCommerce 
(Retail 
Wholesale) 

& 

Calls  for  a  Commission  Task  Force  against  unfair  competition  from  third-
country  operators  expanded  Commission  investigative  powers,  reform  of  the 
Customs  Code,  a  digital  one-stop  shop  and  a  certified  Authorised 
Representatives  system.  Supports  the  Digital  Product  Passport  for  all 
compliance purposes. 

Italy (ENEA)  

NL (RVO) 

Firmly against replacing printed labels with EPREL references as the default, 
arguing the visual impact of physical labels in shops is irreplaceable. Supports 
indefinite  sell-through  of  stock  with  old  labels.  Recommends  simplifying 
Article 11(13) on rescaling transitions.  

Removing the printed label obligation shifts burden unfairly to dealers and risks 
wrong labels being applied. Proposes a targeted exemption only for products 
rarely  displayed  in  shops.  Supports  adding  commercial  names  and  product 
images to EPREL. Wants QR codes provided through multiple channels and the 
9-month sell-off period retained. 

(German 
ZVEI 
Electrical 
& 
Digital  Industry 
Association)  

Supports  moving  to  digital  energy  labels  since  retailers  can  download  from 
EPREL. Wants EPREL strengthened and made more user-friendly (trade name 
search, product images). Also calls for longer implementation periods (24–36 
months) and more planning certainty for companies 

The contributions show a clear devide between manufacturers and tech industry on the one 
side, who want to move to digital labels and MSAs and retailers who are sceptical or opposed, 
fearing burden-shifting to (SME sized) retailers and reduced compliance.  

65 

 
  
  
  
11) Call for evidence February-March 2026  

A Call for Evidence was published and feedback was sought from 12 February until 12 March 
2026 and obtained 58 responses from:  

•  ACEA (European Automobile Manufacturers' Association)  
•  AdCo Tyres Chair (Administrative Cooperation Group)  
•  AIEL (Italian Wood Energy Association)  
•  AIM, European Brands Association  
•  Amazon  
•  Anonymous EU citizen (Germany)  
•  Anonymous EU citizen (Poland)  
•  APPLiA (Home Appliance Europe)  
•  Bavarian State Ministry for the Environment (StMUV)  
•  Belimo Automation AG  
•  BEUC, the European Consumer Organisation  
•  Bioenergy Europe  
•  BMW Group  
    CEFACD 
•  CCIA Europe (Computer & Communications Industry Assoc.)  
•  Dagmar Mištinová (EU citizen, Slovakia)  
•  Dansk Erhverv (Danish Chamber of Commerce)  
•  Deutsche Umwelthilfe (DUH)  
•  DIGITALEUROPE  
•  EDF S.A. (Électricité de France)  
•  EFA e.V. (European Fireplace Association)  
•  EHI (European Heating Industry Association)  
•  EHPA (European Heat Pump Association)  
•  EIHA (European Infrared Heating Alliance)  
•  ECOS (Environmental Coalition on Standards)  
•  Energinet (Danish TSO)  
•  EPEE (European Partnership for Energy & Environment)  
•  Eurofuel (European Liquid Heating Fuels Assoc.)  
•  Eurogas  
•  EuroCommerce (Retailers & Wholesalers European Association)  
•  Eurovent (European HVACR Industry Association)  
•  EUHA (European Underfloor Heating Alliance)  
•  EVIA (European Ventilation Industry Association)  
•  HKI (Industrieverband Haus-, Heiz- und Küchentechnik)  
•  IDEE ECONOMICHE  
•  Independent Retail Europe  
•  ITI – Information Technology Industry Council  
•  Ivan Petrov (EU citizen, Bulgaria)  
•  Joint Industry Statement – Article 16(5) ESPR (multi-association)  
•  LightingEurope  
•  Michelin  

66 

 
  
•  Netherlands Enterprise Agency (RVO)  
•  NIBE AB  
•  nucleareurope  
•  NVE – Norwegian Water Resources & Energy Directorate  
•  Orgalim (European Technology Industries)  
•  SEAI (Sustainable Energy Authority of Ireland)  
•  SER (Société d'Energie Renouvelable / French Renewables)  
•  Solar Heat Europe  
•  Stanislav Baran (EU citizen, Slovakia)  
•  Svenska kraftnät / Nordic TSOs (joint position)  
•  SYNERGI (Danish Energy Industry)  
•  Tyres Europe (European Tyre Industry)  
•  U.Di.Con. APS (Italian Consumer Union)  
•  Verbraucherzentrale Bundesverband (vzbv)  
•  WKÖ – Austrian Federal Economic Chamber  
•  ZVEI (German Electrical & Electronic Manufacturers' Assoc.) 

There was one joint stakeholder submission and two identical ones (EDF/nucleareurope).  

74% of the respondents to the CfE also participated in the reality check meeting.  

74 % of feedback dealt with the ELR, 10 % with TLR and the remainder with both regulations.  
56 % were submitted by Brussels/Belgium based entities and two submissions came from US 
companies/associations. Business associations and companies together accounted for 68% of 
contributions.  

Figure 6: Have your say statistics of respondents to the call for evidence, European Commission.  

Manufacturers’ views constituted half of all responses to the call for evidence as shown below.   

67 

 
 
Figure 7: Shares of manufacturer versus retailer views expressed in the Call for evidence.  

On changing the printed label by default requirement 

Among  the  30  manufacturer-group  submissions,  15  unambiguously  support  removal,  4  are 
conditionally  or  supportive  for  certain  product  groups  (heating  appliances),  and  11  give  no 
position.  No  manufacturer  organisation  explicitly  opposes  removal.  ZVEI  supports  that 
manufacturers  supply  some  printed  labels  per  delivery  batch  rather  than  one  per  unit,  with 
retailers able to request more. EVIA supports digital provision via EPREL registration number 
and/or QR code as part of the sales process. 

The two retailer umbrella organisations oppose this change, Amazon did not respond to this 
particular issue.  

Independent 
Europe 

Retail 

Supports  simplifying  delivery  of  printed  labels  but  insists 
retailers should not be responsible for verifying or producing 
labels. Supports labels on packaging as a simpler alternative 
to separate attached labels. 

68 

 
 
  
 
EuroCommerce 

Supports  allowing 
labels  printed  directly  on  product 
packaging; need to carefully assess impact before any change 
to delivery system. Clarify that labelling the  display unit is 
sufficient.  Any  change  must  include  transition  periods  and 
sell-through  provisions.  Supports  mandatory  GTIN  in 
EPREL for automated compliance. 

All  four  consumer  organisations  oppose  removing  the  printed  label  and  no  MSA  supports 
unconditional  removal  of  the  printed  label  either.  Several  submissions  argue  that  finding  a 
solution that works for all products might not be possible. A notable aspect of the debate is the 
limited  empirical  evidence.  DUH  and  BEUC  both  call  explicitly  for  consumer  behaviour 
studies  before  any  changes,  citing  JRC  evidence  from  food  labelling91  that  QR  codes  are 
scanned only 24% of the time and that digital labels do not replicate the nudging effect of a 
physical label at the point of sale (this point supported by the Irish MSA SEAI).  

On the transition from non-rescaled to rescaled label 

There  is  more  agreement  on  simplifying  this  part  of  the  legislation,  with  notably  MSAsnot 
objecting to such endeavour.  After IT had already proposed the idea at the reality check to 
turn the 4-month transition period from a double regime to a gradual phase in depending on 
suppliers  model  policy,  the  Irish  MSA  proposed  in  its  CfE  contribution  to  turn  the  current 
binary (non-rescaled label → switch date → rescaled label) into a period of double display to 
ease the changing for retailers at a specific date. They also suggest EPREL could play a role in 
managing  this  process.  Consumer  organisation  however  are  opposed  to  consumers    two 
different  labels    visible  in  parallel  for  one  model.  Eurocommerce  calls  explicitly  for  sell-
through periods for existing stock bearing the non-rescaled label to be allowed in general, and 
particularly for high-volume products such as lamps — including for an indefinite period where 
necessary. Independent Retail Europe rejects any duty for retailers to having to retroactively 
relabel stock as that would imply assuming manufacturer product responsibility and suggest 
this to be done via digital solutions supplied by manufacturers. Several suppliers called for 
longer implementation periods for updated requirements (2 years) and consumer organisation 
urged the Commission to rapidly finalise the outstanding revisions of non-rescaled labels.  

On the interaction with the ESPR, including the future registry for the digital 
product passport  

The relationship between EPREL and the forthcoming Digital Product Passport (DPP)  was 
raised by many contributors to the CfE, the central concern being double registration without 

91 JRC Publications Repository - Using QR codes to access food information: a behavioural study with European 
consumers.  

69 

 
 
 
 
 
 
additional  benefit.  The  “once  only”  principle  is  emphasised  by  e.g.  EHPA,  ITI,  Michelin, 
DigitalEurope, CCIA, EUHA, CEFACD, Applia, AIEL, Dansk Erhverv, Eurocommerce, 
Tyres Europe, Irish MSA and a German citizen. ECOS suggested that EPREL becomes the 
DPP for energy-related products and warns that this cannot happen automatically due to the 
absence of a legal obligation to transfer data and this establishing a link between databases. For 
BEUC, digital databases are only a complementary way of transmitting information alongside 
labels.  Independent  Retail  Europe  insists  retailers  should  not  be  obligated  to  verify  if 
information is correctly transmitted. Vzbv proposes that dealers should be obliged to provide 
a DPP access terminal for access to the future DPP for the 5 % of the population that are never 
online.  A  specific  issue  raised  in  this  context  was  whether  the  Global  Trade  Item  number 
(GTIN) should be made mandatory in EPREL for automatic linkage. Digital Europe opposes 
this while Amazon, Eurocommerce and Lighting Europe support it.  

A  common  submission  of  several  manufacturers  of  which  some  also  submitted  individual 
responses  called  for  a  suspension  of  work  on  a  harmonized  label  layout  under  the  ESPR, 
preferring this to be done product-specifically.  

17 submissions raise and support the issue of prolonging the longer transition period for energy 
related  products  under  Article  79  (1)  of  the  ESPR  in  order  to  be  able  to  finalise  advanced 
product reviews under the the previous ecodesign rules rather than starting reviews again.92 

On market surveillance and addressing non-compliant products  

Approximately 35 submissions express support for improved market surveillance, though with 
different  emphases  and  priorities.  The  single  most  frequently  raised  market  surveillance 
concern is the systematic level-playing-field disadvantage with third-country sellers on online 
marketplaces who are not subject to equivalent duties and enforcement. This point is raised by 
manufacturers, retailers, consumer organisations and MSAs alike.  

The AdCo Tyre Chair and the Irish and Romanian MSA explicitly support mandatory test 
report upload to EPREL/Annex VII. Tyres Europe expresses the opposite view saying lacking 
enforcement not lacking information or regulatory detail is the issue.  

Several submissions address the adequacy of MSA resources as a structural issue that cannot 
be solved through simplification including BEUC, ECOS, APPLiA and Tyres Europe.  

Interestingly, there are opposing views expressed on whether there could be a tension between 
simplifying label transmission through digitalisation and compliance. DUH, Irish MSA and 
BEUC warn of a negative effect on MSAs and compliance in shops. (Irish MSA: 'Were the 
mandatory  display  of  a  printed  label  be  reduced/removed,  then  the  benefit  to  consumers 
accruing  from  the  visibility  of  the  label  would  be  likely  significantly  reduced').  The  digital 
sector  and  manufacturers  emphasises  the  potential  of  particularly  EPREL  with  GTIN 
integration and API access to strengthen rather than weaken market surveillance.   

92 The prolongation of the transition period for energy-related products in advanced preparatory stage listed in 
Article  79  (1)  a)  i)  of  Regulation  2024/1781  is  currently  being  discussed  as  part  of  omnibus  IV  on  common 
specifications (COM 2025 (503). 

70 

 
 
On unclear legal concepts 

Some submissions flag a legal gap around the obligations of installers or other intermediaries 
that are neither defined in the Ecodesign Directive nor the Energy Labelling Regulation (Irish 
MSA, Tyres Europe, EPEE). Eurofuel insists simplification should not result in transfer of 
compliance responsibility or costs to installers.  

71 

 
 
 
 
 
ANNEX 3:   WHO IS AFFECTED AND HOW? 

PRACTICAL IMPLICATIONS OF THE INITIATIVE 

Please see main part of the IA for more details.   

SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount 

Direct benefits 

Comments 

Compliance cost reductions  Up to 66 million EUR for suppliers one-off and 

up to EUR 85 million annually.  

EUR 2 million annually for retailers p.a. 
EUR 40 million car dealers p.a. 

Both suppliers and retailers under ELR have 
benefits. 
Non  quantified/monetised  benefits 
for 
retailers through longer period for selling old 
stock etc. 

EUR 3.7 million  annually 

For both ELR and TLR  

Indirect benefits 

Clarification 
responsibilities 

of 

intermediary 

More  effective  use  of  MSA 
resources 
for  compliance 
checking  

Fairer  competition  among 
retailers  

More  compliance  and  in  a 
second  step  more  energy 
savings  

EPREL 
information more useful  

database 

II. Overview of costs – Preferred option 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct adjustment 
costs 

- 

Adjusting 
to 
product-specific 
delivery  mode 
for label  

Action (a)   

Direct 
administrative 
costs 

15.5 
tyre 

EUR 
million 
suppliers 
EUR 10 million 
AR  

EUR  7  million 
for retailers and 
EUR  2  million 
for 
online 
marketplaces   

Not 
qualifiable 
for 
Commissio
n  EPREL 
hosting 
costs 

Not 
quantifiable 
for 
Commission 
EPREL 
hosting costs 

Direct regulatory 
fees and charges 

Direct 
enforcement costs 

- 

- 

- 

- 

- 

- 

72 

- 

- 

- 

- 

- 

- 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Indirect costs 

- 

- 

- 

- 

- 

- 

III. Application of the ‘one in, one out’ approach – Preferred option(s) 

One-off 

Recurrent 

Total 

[M€] 

(annualised total net present 
value over 10 years) 

(nominal values per year) 

11.99 

135,74 

-123.75 

- 

3.7 

- 

- 

- 

- 

-127.45 

Businesses 

New administrative burdens 
(INs) 

Removed administrative burdens 
(OUTs) 

Net administrative burdens* 

2.99 

7.74 

Adjustment costs** 

Public authorities 

Removed administrative 
burdens (OUTs) 

Citizens 

New administrative burdens 
(INs) 

Removed administrative burdens 
(OUTs) 

Net administrative burdens* 

- 

- 

- 

9 

UP TO 128  

UP TO -119 

-4.75 

- 

3.7  

- 

- 

- 

Adjustment costs** 

Total administrative burdens*** 

- 

-4.75 

- 

-122.7 

(*) Net administrative burdens = INs – OUTs;  
(**) Adjustment costs falling under the scope of the OIOO approach are the same as reported in Table 2 above. Non-
annualised values;  
(***) Total administrative burdens = Net administrative burdens for businesses + net administrative burdens for citizens. 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option 
Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG no. 7 - affordable 
and clean energy 

SDG no 8 - Promote 
sustained, inclusive and 
sustainable economic 
growth, full and 

through 

Increased  compliance 
legal  clarifications.  And 
eventually  more  energy  savings  due  to  better  compliance.  
Better  use  of  EPREL  by  complementing  public  parameters 
allowing for better search and comparison  

Reduction of compliance costs for suppliers and retailers.  
Better  use  of  scarce  resources  in  MSAs  which  can  then  be 
deployed for more targeted compliance checking.  

73 

 
 
 
 
  
  
productive employment 
and decent work for all 

SDG no. 13 – Climate 
action 

Expected increase in energy savings with more compliance  

74 

 
 
ANNEX 4:  COMPETITIVENESS CHECK 

OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Current  and  proposed  obligations  under  the  tyre  and  energy  labelling  framework  apply 
equally to EU based and third country suppliers and retailers, hence do not affect relative 
competitiveness.  

Dimensions of 
Competitiveness 

Impact of the 
initiative 
(++ / + / 0 / - / -- / n.a.) 

Cost 
competitiveness 

and 

price 

+ 

International 
competitiveness  

+ 

References to sub-sections of the 
main report or annexes 

Reduction  of  compliance  costs  for 
retailers and suppliers  

Authorised 
representatives’ 
clarifications  improve  situation  for 
EU  based  suppliers  and  retailers. 
for  more 
Additional 
action 
is 
label 
compliance  under 
expected  to  affect  more  low-cost 
brand 
than  EU  based 
imports 
manufacturers.  
All  provisions apply  equally to  EU 
based and outside EU enterprises.  

tyre 

Capacity to innovate 

0 

0 

SME competitiveness 

0 

Benefits  from  simpler  compliance 
applies to both large companies and 
SMEs. Retailers can request printed 
labels from suppliers, this expected 
to be relevant mostly for SME.  On 
the  other  hand,  SMEs  less  used  to 
integrating  EPREL 
stock 
management systems. 

into 

75 

 
 
ANNEX 5:   SME CHECK  

OVERVIEW OF IMPACTS ON SMES 

The role of SMEs in manufacturing of energy-related products  

SMEs are not common at the level of finished products for household appliances but are 
present  at  components  suppliers'  level  for  Original  Equipment  Manufacturers  (OEMs).  
The latter probably do not have an independent consumer interface and are therefore not 
assumed  to  be  affected  parties  of  label  delivery  obligations.  The  heat  pumps  and  air 
conditioners sector is dominated by large enterprises such as Viessmann, Stiebel Eltron, 
Daikin, Bosch/Vaillant. Manufacturing of local space heaters and solid fuel boilers counts 
a higher share of SMEs than other energy-related products. Here 78% of the companies 
are SMEs, to a large extent in the 200+ employees' category and for at least 14 % of the 
SME  enterprise  share  belonging  to  larger  holdings  (and  therefore  not  considered 
autonomous for the purposes of the labelling framework). It is not possible to provide a 
quantified  estimate  for  the  share  of  SME  companies/employees  for  manufacturing  of 
energy-related  products.  While  Eurostat  Structural  Business  Statistics  (SBS)  give  SME 
shares  at  NACE  code  double  digit  level,  these  figures  have  limited  utility  for  product-
specific  policy  analysis  for  several  reasons:  the  relevant  NACE  categories  aggregate 
manufacturers  of  products  with  substantially  different  characteristics  and  market 
structures93; it cannot be determined where within a broad category SME employment is 
concentrated, whether those jobs are EU-based or the SME part of a larger corporate group. 

The role of SMEs in retail of energy-related products  

Also here, NACE classification codes  at  2-digit-level  for wholesale and retail  activities 
covering HVAC, white goods, light sources electronics are distributed across broad and 
overlapping categories that contain unrelated product lines, however to a lesser extent than 
for manufacturing.  SMEs account for slightly less than 2/third of employment in retail 
sector of NACE code 47 and 75 % in wholesale (NACE code 46). Small retailers are in 
many  instances  not  in  direct  contact  with  the  manufacturer  and  do  often  not  integrate 
systematically with EPREL. Installers are also predominantly SMEs. SME jobs in retail 
are assumed to be EU-based. 

Relevance for SMEs: YES  

(Based on SME filter and the ISG discussion, this initiative is relevant/highly relevant 
for SMEs94)   

93 One category is for example C26.3 manufacturing of communication including smart phones. The overall 
SME share of employees for that category is above 90 %, which is however not reflective of the structure of 
the smart phone market with only large players.  
94 https://ec.europa.eu/docsroom/documents/63274. 

76 

 
 
 
 
(1) IDENTIFICATION OF AFFECTED BUSINESSES AND ASSESSMENT OF RELEVANCE 

Are SMEs directly affected? Yes  

In which sectors? Manufacturing of energy-related products and retail of energy 
related products and tyres.  

The retail and  wholesale sectors of  energy-related products and tyres are consistently 
more SME-dominated than manufacturing equivalents — both in enterprise count and in 
employment share. The gap between enterprise share and employment/value-added share 
is  smaller  than  in  manufacturing,  because  retail  has  less  capital  intensity  and  fewer 
economies of scale than industrial production. Online retail is the retail segment most 
dominated  by  large  enterprises.  It  is  not  possible  to  provide  SME  numbers  for 
manufacturers but SME share not assumed significant for the purposes of label delivery 
as often not with direct customer contact. In retail, SMEs account for slightly less than 
2/third of employment in retail sector of NACE code 47 and 75 % in wholesale (NACE 
code 46) which can be taken as a proxy for the products in scope.  

Are SMEs indirectly affected? In which sectors? What is the estimated number of 
indirectly affected SMEs and employees? 
n/a. 

(2) CONSULTATION OF SME STAKEHOLDERS 

How has the input from the SME community been taken into consideration? 

-A high level representative of SME United was present at the implementation dialogue 
as one out of 23 participants.  
-Inclusion of the SME dimension into the assessment of distributional effects of proposed 
amendments of this IA and decision on discarded measures.  

Are SMEs’ views different from those of large businesses? 

It is not a case in which SMEs have different views from large enterprises, however the 
larger  proportion  of  SMEs  in  the  retail  sector  than  in  the  manufacturing  sector  was  a 
relevant issue in the discussions to remove the obligation for manufacturers to deliver 
printed labels. It is also less common for SME sized actors to work with APIS to directly 
integrate their own software applications with EPREL.   

(3) ASSESSMENT OF IMPACTS ON SMES95 

What are the estimated direct costs for SMEs of the preferred policy option? (Fill 
in only if step 1 flags direct impacts) 

Quantitative assessment 

95 The costs and benefits data in this annex are consistent with the data in annex 3. The preferred option 
includes the mitigating measures listed in section 4.  

77 

 
 
 
 
 
This cannot be detailed for suppliers as exact share of SMEs not known. For retailers 
2/thirds of annual  recurrent  EUR 7 million  which can be mitigated by the request  of 
printed labels from suppliers 

Qualitative assessment  

- 

What  are  the  estimated  direct  benefits/cost  savings  for  SMEs  of  the  preferred 
policy option96? 

Qualitative assessment  

Simplification of label delivery and display. Simplification when dealing with national 
authorities during compliance verification and for other national purposes when EPREL 
data can be used.  Better level  playing  field  in  retail  for small  retailers  against online 
marketplaces.  

Quantitative assessment 

Not possible  

What are the indirect impacts of this initiative on SMEs?  

n/a 

(4) MINIMISING NEGATIVE IMPACTS ON SMES 

Are SMEs disproportionately affected compared to large companies? (Yes) 

SMEs are more affected by the delivering and the handling/display of EU energy labels 
and registration into EPREL due to lower economics of scale and less sophisticated IT 
systems.  

If yes, are there any specific subgroups of SMEs more exposed than others? 

no 

Have mitigating measures been included in the preferred option/proposal?  

Considering the higher share of SMEs in the retail sector (compared to the manufacturing 
sector) for products within scope, the digital by default option that would have meant for 
all retailers  to  print all EU energy labels  needed  for display, was discarded.  Retailers 
preserve a right to request printed labels from suppliers, assuming that this option will 
mainly be made use of by the small retailers in contact with end customers, not large 
retail and distributors.  

CONTRIBUTION TO THE 35% BURDEN REDUCTION TARGET FOR SMES 

96 The direct benefits for SMEs can also be cost savings. 

78 

 
 
 
 
Are there any administrative cost savings relevant for the 35% burden reduction 
target for SMEs? 

The share of SMEs in the overall identified savings  

79 

 
ANNEX  6:  OVERVIEW  OF  CURRENT  LABELLING  PROVISION 

REQUIREMENTS  

Delegated Acts under Regulation (EU) 2017/1369 — Energy Labelling 

#  Regulation 

Product 
Group 

Label Supply -
physical 

Label Supply — 
Distance / Internet 
Selling 

1 

EU 
2019/2017  

Household 
dishwashers 

Printed label for each 
unit  
electronic  label  and 
product 
electronic 
information 
sheet 
available  to  dealers 
each  model. 
for 
entered into EPREL. 

in 
label 
Nested 
price. 
proximity 
to 
must 
Telemarketing: 
inform 
of 
energy  class,  range,  and 
how  to  access  the  full 
label or request a printed 
copy. 

customer 

2 

EU 
2019/2016 

Household 
refrigerating 
appliances 
(fridges, 
freezers, wine 
coolers) 

Printed label for each 
unit 
electronic  label  and 
electronic 
product 
sheet 
information 
available  to  dealers 
for 
each  model. 
entered into EPREL. 

full 

customer 

in 
label 
Nested 
price 
proximity 
to 
must 
Telemarketing: 
inform 
of 
energy  class,  range,  and 
label 
that 
and 
product 
information 
sheet  are  accessible  via 
free-access  website  or 
printed copy on request. 
Hosting  platforms  must 
enable  electronic  label 
display. 

3 

EU 
2019/2018  

4 

EU 
2019/2014  

Refrigerating 
appliances 
with  a  direct 
sales  function 
(display 
cabinets, 
vending 
machines, 
beverage 
coolers) 

Household 
washing 
machines  & 

Printed label for each 
unit  
electronic  label  and 
product 
electronic 
information 
sheet 
available  to  dealers 
for 
each  model. 
Entered into EPREL. 

Hosting  platforms  must 
enable  the  showing  of 
the  electronic  label  and 
electronic  product  fiche 
on 
display 
mechanism  and  inform 
the 
the 
dealer 
obligation.  

the 

of 

Printed label for each 
unit  
electronic  label  and 
product 
electronic 

Nested  label  display  in 
. 
proximity 
Internet 
hosting 
platforms  must  ensure 

to  price 

80 

 
 
  
  
  
5 

EU 
2019/2013  

washer-
dryers 

Electronic 
displays 
(TVs, 
monitors, 
digital 
signage) 

6 

EU 
2019/2015  

Light  sources 
(LED, 
fluorescent, 
etc.) 
those 
containing 
products 

incl. 
in 

7 

EU 
2023/2534  

Household 
tumble dryers 

8 

EU 
2023/1669  

Smartphones 
& 
slate 
tablets 

81 

information 
sheet 
available  to  dealers 
for 
each  model. 
Entered into EPREL. 

Printed label for each 
unit  and  in  addition 
label  printed  on  the 
packaging  or  stuck 
on it 
electronic  label  and 
product 
electronic 
information 
sheet 
available  to  dealers 
for 
each  model. 
entered into EPREL. 

label  printed  on  or 
affixed  to  the  outer 
packaging 
electronic  label  and 
electronic 
product 
sheet 
information 
available  to  dealers 
for 
each  model. 
entered into EPREL. 

label 
and 
electronic 
information 
product 
sheet 
clearly 
are 
displayed  according  to 
Annex VIII. 

Hosting  platforms  must 
enable  the  showing  of 
the  electronic  label  and 
product 
electronic 
information sheet on the 
display  mechanism  and 
inform  the  dealer  of  the 
obligation. 

full 

customer 

Telemarketing: 
must 
of 
inform 
energy  class,  range,  and 
label 
that 
and 
product 
information 
sheet  are  accessible  via 
free-access  website  or 
printed copy on request. 

Printed label for each 
unit  
electronic  label  and 
product 
electronic 
information 
sheet 
available  to  dealers 
for 
each  model. 
entered into EPREL. 

label 
and 
Electronic 
information 
product 
sheet displayed in online 
mechanism 
display 
label). 
(nested 
must 
Telemarketing 
communicate 
energy 
class and range. 

Printed label for each 
unit  
electronic  label  and 
product 
electronic 
information 
sheet 
available  to  dealers 
each  model. 
for 
entered into EPREL. 

of 

Providers 
online 
platforms  must  enable 
provide 
to 
traders 
information 
labelling 
label 
(energy 
and 
information 
product 
in  compliance 
sheet) 
with Article 31(2) of the 
Digital Services Act (EU 
Visual 
2022/2065). 
must 
advertisements 

 
  
  
  
  
  
Printed label for each 
unit  
makes 
Supplier 
electronic 
label 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites. 

Printed label for each 
unit. 
makes 
Supplier 
electronic 
label 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites. 

Printed label for each 
unit  
makes 
Supplier 
electronic 
label 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites. 

Printed label for each 
unit  
makes 
Supplier 
electronic 
label 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites. 

Printed label for each 
unit.  
Supplier 
makes 
label 
electronic 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites. 

Printed label for each 
unit.  

show  the  energy  class 
and range. 

No  full 
to  be 
label 
provided in  cases  where 
cannot  be 
end-users 
expected 
the 
see 
to 
product  displayed  (only 
energy  class  and  key 
parameters)  

No  full 
to  be 
label 
provided in  cases  where 
cannot  be 
end-users 
expected 
the 
see 
to 
product  displayed  (only 
energy  class  and  key 
parameters) 

No  full 
to  be 
label 
provided in  cases  where 
cannot  be 
end-users 
expected 
the 
see 
to 
product  displayed  (only 
energy  class  and  key 
parameters) 

to  be 
label 
No  full 
provided in  cases  where 
cannot  be 
end-users 
expected 
the 
see 
to 
product  displayed  (only 
energy  class  and  key 
parameters) 

No  full 
to  be 
label 
provided in  cases  where 
cannot  be 
end-users 
the 
see 
to 
expected 
product  displayed  (only 
energy  class  and  key 
parameters) 

No  full 
to  be 
label 
provided in  cases  where 
cannot  be 
end-users 

9 

EU 
626/2011 (in 
force; 
originally 
under 
2010/30/EU) 

10  EU 

811/2013 (in 
force; 
originally 
under 
2010/30/EU) 

kW 

Air 
conditioners 
≤12 
(single-split, 
multi-split, 
single 
double duct) 

duct, 

Space 
heaters, 
combination 
heaters,  and 
packages 
(heater 
temperature 
control 
solar device) 

+ 

+ 

11  EU 

812/2013 (in 
force; 
originally 
under 
2010/30/EU) 

12  EU  65/2014 
force; 

(in 
originally 
under 
2010/30/EU) 

Water 
heaters,  hot 
water  storage 
tanks, 
and 
packages 
(water  heater 
solar 
+ 
device) 

Domestic 
ovens 
range hoods 

and 

Residential 
ventilation 
units 

13  EU 

force; 

1254/2014 
(in 
originally 
under 
2010/30/EU) 

14  EU 

2015/1186 
(in 

force; 

space 

Local 
heaters 
(electric,  gas, 

82 

 
originally 
under 
2010/30/EU) 

liquid 
etc.) 

fuel, 

Solid 
boilers 
packages 

fuel 
and 

15  EU 

force; 

2015/1187 
(in 
originally 
under 
2010/30/EU) 

makes 
Supplier 
label 
electronic 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites.. 

Printed label for each 
unit.  
makes 
Supplier 
electronic 
label 
available  to  dealers. 
Electronic 
product 
fiche  on  free-access 
websites. 

see 

expected 
the 
to 
product  displayed  (only 
energy  class  and  key 
parameters) 

No  full 
to  be 
label 
provided in  cases  where 
cannot  be 
end-users 
expected 
the 
see 
to 
product  displayed  (only 
energy  class  and  key 
parameters) 

Regulation (EU) 2020/740 - Tyre Labelling 

# 

Regulation 

Product Group 

Label Supply -physical 

Tyres 

Printed Sticker label to be 
provided on tyre 

Label Supply — Distance / 
Internet Selling 

Nested display mentioned 
without explanation. No 
possibility and no 
technical details for 
simplified label display 
with class arrows.  

83