Ettepanek - SEC(2026) 565, SWD(2026) 565, SWD(2026) 566, COM(2026) 565

EN EN

EUROPEAN COMMISSION

Brussels, 24.6.2026

COM(2026) 565 final

2026/0169 (COD)

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

{SEC(2026) 565 final} - {SWD(2026) 565 final} - {SWD(2026) 566 final}

(Text with EEA relevance)

EN 1 EN

EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The 2024 Draghi Report1 emphasised that the transition to a low-carbon, resource-efficient,

and circular economy will be essential for securing the EU's long-term economic prosperity,

resilience, and competitiveness. Energy efficient products reduce energy bills for EU

consumers and businesses while also cutting material use, infrastructure needs and

greenhouse gas (GHG) emissions. Energy product legislation is a long-standing policy

framework that originated in the aftermath of the 1973 oil crisis, and which has since been

gradually refined and extended, now covering products representing an estimated annual

turnover of more than EUR 500 billion, and related energy and other operational costs for

users of more than twice that amount2.

In response to the Draghi report, the Competitiveness Compass3 identified the urgent need for

simplification and for deepening the internal market as horizontal enablers for

competitiveness. The Commission has set targets to cut administrative costs by 25 % for all

business and public authorities and by 35 % for small to medium-sized enterprises. The

Draghi report also pointed to insufficient market surveillance, enforcement and compliance as

a major shortcoming in the implementation of the EU ecodesign and energy labelling

frameworks. The affordable energy action plan4 includes action on labelling to contribute to

lower energy bills for households.

As part of its commitment to screen the entire EU acquis, the Commission therefore

announced in its 2026 work programme5 an omnibus initiative on energy-related product

legislation.

This proposal aims to make targeted revisions to the following acts:

• Regulation (EU) 2017/1369 setting a framework for energy labelling (the Energy

Labelling Regulation6); and

• Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency

and other essential parameters (the Tyre Labelling Regulation7);

The proposal builds on the implementation reports adopted in parallel under Article 19 of the

Energy Labelling Regulation and under Article 15 of the Tyre Labelling Regulation8. The

1 Draghi, M. (2024), The future of European competitiveness. 2 Ecodesign Impact Accounting Overview Report 2025, https://energy-efficient-

products.ec.europa.eu/policy-making-0_en#impacts 3 Communication from the Commission to the European Parliament, the European Council, the Council,

the European Economic and Social Committee and the Committee of the Regions of 29 January 2025,

'A competitiveness Compass for the EU', COM(2025) 30 final. 4 Action Plan for Affordable Energy: Unlocking the true value of our Energy Union to secure affordable, efficient

and clean energy for all Europeans - Energy 5 Communication from the Commission to the European Parliament, the Council, the European

Economic and Social Committee and the Committee of the Regions of 21 October 2025, 'Commission

work programme 2026 - Europe's Independence Moment', COM (2025) 870 final. 6 Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for

energy labelling and repealing Directive 2010/30/EU (OJ L 198, 28.7.2017, pp. 1–23ELI:

http://data.europa.eu/eli/reg/2017/1369/oj) 7 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 (OJ L 177 5.6.2020 p 1. ELI:

http://data.europa.eu/eli/reg/2020/740/oj)

EN 2 EN

multi-stage consultation process included an implementation dialogue9, a reality check10 and a

call for evidence11. It is supported by an impact assessment12.

The energy efficiency framework for energy–related products and tyres consists of a

comprehensive set of provisions designed to provide customers and end-users with

harmonised and comparable information on energy and other characteristics of the products

before they make a purchase decision. For energy-related products, suppliers enter into the

European Product Registry for Energy Labelling (EPREL) information on energy efficiency

aspects and on non-energy aspects such as recyclability and noise. Similarly, for tyres,

suppliers enter into EPREL information on tyres’ rolling resistance (relevant to energy

efficiency), wet grip (relevant to safety aspects) and other environmental aspects.

The proposal does not change the scope and objectives of the labelling framework and

preserves the main policy objective of disclosure that enables customers and end-users to

make informed purchasing decisions. However, during the screening of the EU acquis,

simplification options were identified, including by making better use of the digital ecosystem

created by EPREL13.

The proposal introduces targeted changes to:

• simplify rules for suppliers and dealers without compromising the provision of

necessary information to customers and end-users while maximising accessibility to

that information and facilitating comparison of products; and

• improve compliance and enforcement by enhancing the clarity of legal concepts and

a better use of digital options.

These targeted changes will provide the flexibility to adopt more suitable product-specific

requirements in implementing measures for which individual reviews, evaluations and impact

assessments are systematically carried out under the Energy Labelling Regulation.

Further possible modifications of the Energy and Tyre Labelling Regulations are entirely

outside of the scope and aims of the present proposal. The Commission will constructively

engage with the co-legislators, in order to ensure that the legislative process on the present

proposal fully preserves its essential object and does not distort it.

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR)14, which

repealed and replaced the Ecodesign Directive 2009/125/EC15 as from 18 July 2024, subject to

certain transitional measures, is not part of the present omnibus. Implementation of the ESPR

is still in a very early phase. For the purposes of the present initiative, alignment across the

initiatives including on the interaction between the Digital Product Passport (DPP) and

EPREL is sought.

8 COM(2026) 319 and COM(2026) 326. 9 https://energy.ec.europa.eu/events/implementation-dialogue-energy-efficient-product-legislation-

commissioner-dan-jorgensen-2025-10-14_en. 10 https://energy.ec.europa.eu/events/reality-check-energy-product-legislation-2025-12-08_en. 11 The Commission seeks views on how to simplify legislation on energy efficient products. 12 SWD(2026) 565. 13 EPREL Public website. 14 Regulation (EU) 2024/1781 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 (OJ L,

2024/1781, 28.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1781/oj). 15 Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing

a framework for the setting of ecodesign requirements for energy-related products (OJ L 285,

31.10.2009, pp. 10–35, ELI: http://data.europa.eu/eli/dir/2009/125/oj).

EN 3 EN

Finally, the proposal repeals Regulation (EC) No 106/200816 and Regulation (EU) No

174/201317, which implemented the US-EU Energy Star agreement and have become obsolete

when the latter elapsed.

The proposal contains the following key measures:

Flexibility as regards the format for energy labels accompanying products while maintaining

the possibility to obtain printed labels on request

The Energy Labelling Regulation requires that each unit of a product placed on the market is

accompanied by a printed label. The label is, for most products, found inside the box. For

lighting and electronic displays, printing on the packaging is required. Additionally, in case of

rescaling, both the label under the old regulation (the non-rescaled label) and the label under

the reviewed regulation (the rescaled label) are to be delivered in printed format with each

unit of product for a period of four months before the rescaled label is to be shown to

potential customers (thereafter referred to as “the transition period”).

The impact assessment supporting this proposal has assessed alternative options for how the

label should be provided - while maintaining the key requirement that a label must be

displayed to customers or end users at the points of sale. The proposal seeks to reduce the

number of labels inside boxes and/or printed on the packaging that are not used for display

and that the customer or end user gets with the purchased product and may simply discard as

the purchasing decision has been taken. The proposal removes the default rule in the energy

labelling framework to have a printed label accompanying each unit but it does not introduce

a ‘digital only’ system for label, given the impact this would have on the more SME-

dominated retail sector and the lack of sector specific behavioural studies on the effect of

moving fully to digital labels.

The proposal also removes the obligation for suppliers of tyres and energy-related products to

enter a separate label image in EPREL since the product database automatically generates

these labels. In addition, the proposal ensures that the QR code that is compulsory on revised

labels and the EPREL registration number are transmitted along the supply chain.

The proposal retains the possibility for dealers to request printed labels from suppliers, an

option that is expected to be used by smaller dealers who may face higher per unit printing

costs than suppliers, which generally are bigger manufacturers. The proposal also gives

dealers the possibility to display the label in shops on digital screens, considering

technological developments that enable such screens to display energy labels in the

appropriate resolution, colour and size.

Fully electronic product information sheets

Product information sheets (PIS) provide dealers with additional technical information useful

for marketing and sales. They can be accessed by anyone through EPREL where they are

automatically available in all official languages of the Union. Article 3(1) of the Energy

Labelling Regulation offers the option to not require the delivery of printed PIS for each unit

of product which was effectively retained by the delegated acts adopted so far. Even if dealers

currently have a right to request printed product information sheets, this right is rarely

16 Regulation (EC) No 106/2008 of the European Parliament and of the Council of 15 January 2008 on a

Community energy-efficiency labelling programme for office equipment (OJ L 39, 13.2.2008, pp. 1–7,

ELI: http://data.europa.eu/eli/reg/2008/106/oj). 17 Regulation (EU) No 174/2013 of the European Parliament and of the Council of 5 February 2013

amending Regulation (EC) No 106/2008 on a Community energy-efficiency labelling programme for

office equipment (OJ L 63, 6.3.2013, pp. 1–4, ELI: http://data.europa.eu/eli/reg/2013/174/oj).

EN 4 EN

exercised. PIS should therefore become fully digital completing the digitalisation of this part

of the obligations.

Stronger accountability for non-EU manufacturers and their authorised representatives

Article 2(11) of the Energy Labelling Regulation defines ‘authorised representative’ (AR) as

“a natural or legal person established in the Union who has received a written mandate from

the manufacturer to act on its behalf in relation to specified tasks”. That definition was

established to have an EU-based entity responsible for registering the models in EPREL on

behalf of third country manufacturers. However, the notion of AR does not appear in any

further provision of the Energy Labelling Regulation, which creates a lack of clarity on the

role of the AR, in particular, since the responsibility for placing products on the market

remains with the manufacturer. The proposal therefore establishes a duty for ARs to cooperate

with MSAs and requires that a signed copy of the AR’s mandate is to be added to EPREL as a

condition for registering products and that any changes in the scope of that mandate are

notified to MSAs.

Simplifying the transition to rescaled labels for suppliers and dealers

The Energy Labelling Regulation currently requires suppliers to deliver both non-rescaled and

rescaled labels in printed form for each unit of product during a 4-month transition period

preceding the date where the rescaled labels are introduced. Dealers must obtain rescaled

labels to continue selling their existing stocks and need to change the label on display within

14 working days from the official rescaling date. They can continue selling units with the

non-rescaled label beyond that only in exceptional cases.

The proposal introduces greater flexibility during the transition period to allow suppliers to

deliver labels in line with their product-to-market processes during this time and dealers to

change the label on display as a more natural part of their stock management. Products

bearing the non-rescaled label may be marketed and sold, in shops and online, for an extended

period of 12 months from the official rescaling date (the date from which suppliers can only

place units on the market accompanied with the rescaled label).

Once-only principle for EPREL

The proposal clarifies that products for which EPREL offers equivalent information to that set

in a delegated act adopted under the ESPR’ do not have to be registered again in the registry

managing the digital product passport foreseen to be established under the ESPR. Instead, it

will be ensured that the central administrative part of EPREL and the common “model-

related” information in EPREL is interlinked with DPP registry item-level information.

Furthermore, for products where similar information is mandated at model level in EPREL

and in the DPP, a link between the two systems shall facilitate access to the relevant

information avoiding any potential reporting duplication for economic operators. This should

also be ensured for tyres in relation to information requirements set in delegated acts adopted

under Regulation (EU) 2024/1781. A similar interlinking exists between EPREL and the

Information and Communication System for the pan-European Market Surveillance of

technical products (ICSMS) in relation to in-depth inspection reports. Similarly, a second

identity verification should not be required, unless additional requirements need to be verified

for the DPP.

In addition, suppliers that have duly registered their products and provided the necessary

documentation in EPREL should be able to use that as evidence in relation to the assessment

of the product’s eligibility for Member States’ incentives (which, in accordance with Article

7(2) of the Energy Labelling Regulation, shall aim at the highest two significantly populated

classes of energy efficiency, or at higher classes laid down in the delegated act for the

EN 5 EN

product). Suppliers should not face additional requests for the same documentation where the

competent authorities can access the relevant documentation via EPREL. Member States will

therefore have to consider as sufficient proof of eligibility, information already registered in

EPREL (or in a DPP) to the extent this contains the information needed to assess eligibility

and provided suppliers upload supporting evidence such as test reports, declarations of

conformity, and where relevant, third-party conformity assessment documentation.

Clarifications of responsibilities of stakeholders along the supply chain

Both the Energy Labelling Regulation and the Tyre Labelling Regulation define

responsibilities for suppliers and dealers. However, unlike the Tyre Labelling Regulation, the

Energy Labelling Regulation does not distinguish between wholesale distributors and dealers

selling to the customers. Moreover, the Energy Labelling Regulation and the Tyre Labelling

Regulation do not clearly define the responsibilities of intermediaries such as installers,

professional repairers, tyre fitters or kitchen fitters. In fact, the only time that installers are

specifically mentioned in the Energy Labelling Regulation is as clients of another dealer. It is

relevant to specify that they are covered by dealers’ obligations when selling energy–related

products as part of their commercial services. The proposal clarifies that installers who offer

for sale, hire or hire-purchase energy labelled products as part of their commercial activity,

must include relevant product energy labels in their invitations to purchase, as this is

important precontractual information that ensures informed purchasing decisions, and make

available the product information sheet as indicated in the delegated act.

Similarly, it is appropriate to add the specific category of tyre fitters under the Tyre Labelling

Regulation as they often have a dual role: they do not just fit a tyre; in doing so they are also

typically engaged in selling or hiring out tyres as part of their commercial activity where their

role is then not different from that of brick and mortar or online shops.

By contrast, vehicle dealers, another possible intermediary in the tyre sales chain should no

longer have to display the tyre label in new car sales since end users in most cases cannot

choose the tyre fitted to their vehicle, and since the rolling resistance is typically already

reflected indirectly in other precontractual information related to emissions or autonomy.

Aligning the procedures for updating the parameters under the Tyre Labelling Regulation

with the ones under the Energy Labelling Regulation

The Tyre Labelling Regulation only allows the Commission to update via delegated acts the

values, calculation methods and information requirements on the label related to severe snow

and ice conditions. It does not empower the Commission to update or review the parts of the

label on fuel efficiency, wet grip or noise. The only way to update or rescale these parts of the

tyre label is therefore through an amendment of the Tyre Labelling Regulation in co-decision.

As a result, the current tyre label is out-of-date in relation to UNECE requirements and

market realities. By allowing for the revision of all tyre label aspects via delegated acts, the

proposal aligns with the approach under the Energy Labelling Regulation which allows the

updating of all parameters of the label in view of technological and market developments.

Update tyre information parameters in the public part of EPREL

The proposal amends current information requirements under the Tyre Labelling Regulation

to cover those parameters needed for unambiguous tyre selection, including for the purposes

of the EU taxonomy Regulation (EU) 2020/852 18.

18 Commission Delegated Regulation (EU) 2021/2139 establishing the technical screening criteria for

determining the conditions under which an economic activity qualifies as contributing substantially to

EN 6 EN

Adding test reports for tyres to the documentation to be uploaded in the compliance part of

EPREL which is accessible only to market surveillance authorities

Under the Tyre Labelling Regulation, type approval of tyres is carried out at product group

(‘tyre family’) level and based on a ‘worst case’ scenario. By contrast, the tyre label and

registration in EPREL is model based. This can lead to situations where some tyre models

have a better performance than the ‘worst-case’ documented by the type approval for the

entire ‘family’ (that can cover several models). The proposal replaces the requirement to

provide testing protocols with a requirement to provide test reports which should substantiate

the values declared in the label. It is clarified that where simulations or extrapolations are

used to determine the exact values for certain sizes/models within the tyre family, those

procedures should be provided together with the underlying results used as a basis for those

calculations. Type approval reports should only replace the need of a specific test report if the

declared performance is not better than the ‘worst case’ for the ‘family’.

Consistency with other Union policies

This proposal aims to ensure consistency with other instruments such as the ESPR and the

Digital Services Act (DSA)19.

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

Legal basis

The legal bases of the proposal are Articles 114 and 194(2) of the Treaty on the Functioning

of the European Union (TFEU). This reflects the underlying legal bases of the regulations that

are being revised: Article 194(2) (TFEU) for the Energy Labelling Regulation and Article 114

and Article 194(2) (TFEU) for the Tyre Labelling Regulation.

Subsidiarity (for non-exclusive competence)

This proposal relates to directly applicable regulations that govern the access to the internal

market. The proposal does not alter the division of competences between the EU and the

Member States. The targeted amendments to fully harmonised requirements established under

the Energy Labelling Regulation and the Tyre Labelling Regulation, do not change the

substance or ambition of the political objectives of these two regulations.

Proportionality

The targeted amendments improve the effectiveness of the existing rules and the benefits from

having EPREL for the internal market and do not go beyond what is necessary to maintain a

level playing field, ensure uniform compliance and better alignment with technological

developments. New obligations are targeted based on evidence. While the “one-fits-all"

requirement to have a printed label accompanying each product unit is removed, the right of

customers to have a label in display in shops is maintained and dealers keep the right to

request printed labels from suppliers.

Choice of the instrument

A proposal for a Regulation is the appropriate instrument as the underlying acts that are being

amended are also Regulations.

climate change mitigation or climate change adaptation and for determining whether that economic

activity causes no significant harm to any of the other environmental objectives. 19 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 (Digital Services Act) (OJ L

277, 27.10.2022, pp. 1–102, ELI: http://data.europa.eu/eli/reg/2022/2065/oj).

EN 7 EN

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENT

Ex-post evaluations/fitness checks of existing legislation

Article 19 of the Energy Labelling Regulation required the Commission to produce a report

on the implementation of that Regulation. Similarly, Article 15 of the Tyre Labelling

Regulation required the Commission to produce a report on the implementation of that

Regulation. Both reports are adopted together with this proposal and provide some of the

evidence for the impact assessment.

Stakeholder consultations

The Commission regularly consults stakeholders when establishing and reviewing product

requirements and energy labels through the Consultation forum established by Article 14 of

the Energy Labelling Regulation. This forum was also consulted in writing on the energy

labelling implementation report in 2025. Input was received from 12 Member States (Austria,

Bulgaria, Denmark, Estonia, Germany, Ireland, Italy, Latvia, Lithuania, the Netherlands,

Portugal and Slovenia), two European Economic Area / European Free Trade Association

countries (Norway and Iceland) and seven non-governmental members (APPLiA, Digital

Europe, EHI, EHPA, EPEE, EuroCommerce and Lighting Europe). The implementation

reports were also supported by two representative surveys, one on the Energy Labelling

Regulation and another one on the Tyre Labelling Regulation which are publicly available20.

On 14 October 2025, an implementation dialogue was held involving 23 organisations

covering all stakeholder groups, as follows:

– manufacturers: APPLiA, CEFACD, CEMEP, Digital Europe, EHI, EHPA, Eurovent,

Lighting Europe, Tyres Europe;

– dealers: Ebay, EDRA-GHIN, EuroCommerce, Independent Retail Europe;

– installers: GVP Europe;

– MSAs: the chair of the Administrative Cooperation group for Eco-Design and

Energy Labelling, Independent market surveillance experts, PROSAFE, RVO (NL);

– Non-governmental organisations (NGOs)/thinktanks/consumer associations: BEUC,

CLASP, ECOS, EEB; and

– others: SME United.

Following the implementation dialogue, a reality check meeting was convened in December

2025. Participation was open to the public (and announced on the website of the

Commission’s Directorate-General for Energy). Invitations were sent to the Consultation

Forum, the Administrative Cooperation Group for Ecodesign and Energy Labelling and the

Administrative Cooperation Group for Tyres Labelling21.

The reality check meeting brought together around 160 participants in person and online.

Participants were mainly manufacturers (40%), Member State/enforcement authorities (30%),

consumers/NGOs/think tanks (7 %,). Only one retail representative attended.

The agenda of the reality check meeting covered technical aspects of measures that could be

envisaged to make the rules under the Energy Labelling and the Tyre Labelling Regulation

simpler and more effective. The Commission presented two non-papers to structure the

20 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. 21 Adcos - Internal Market, Industry, Entrepreneurship and SMEs.

EN 8 EN

discussion. The agenda included a more in-depth exchange on a suggestion from APPLiA to

move to a ‘digital by default’ approach for the energy label, which was rejected by other

stakeholder groups. One of the main outcomes of the discussion was strong support for an

approach that gives flexibility to determine, on a product-specific basis, the most appropriate

way to provide the label with individual products. There was also broad agreement that the

transition between labels in case of rescaling could be simplified. Two national authorities

and Tyres Europe were the main stakeholders providing input on possible simplifications to

the Tyre Labelling Regulation.

A call for evidence was open for feedback from 12 February 2026 to 12 March 2026. It

received 58 responses, half of them from manufacturers. There was also a 75 % overlap with

participants in the reality check meeting. The submissions broadly confirmed the stakeholder

groups’ previously known positions. For more details on all consultation steps, see Annex 2

(synopsis report) to the impact assessment.

Collection and use of expertise

Evidence gathering was carried out by the Commission. In addition to stakeholder input, the

analysis in the impact assessment and this proposal are based largely on the two

implementation reports and accompanying surveys, and on insights gathered from market

surveillance, reports of national compliance activities carried out in 2024, analysis of EPREL

and ICSMS statistics, complaints received by the Commission, publicly available market data

and research and findings from EU-funded projects supporting the implementation of the

energy and tyre labelling frameworks, in particular EEPLIANT Concerted Action22 and

Compliance Services23.

Impact assessment

An impact assessment accompanies this proposal and includes a comprehensive summary of

stakeholder consultation activities.

It sets out the intervention logic and problems to be addressed by the proposal and quantifies

the expected savings and costs in line with the Commission Better Regulation requirements,

in particular the recently adopted Communication on a simpler, clearer and better enforced

EU rulebook (COM (2026) 380). The scrutiny meeting with the Regulatory Scrutiny Board

(RSB) took place on 20 May 2026 and the impact assessment received a non-qualified

opinion on 22 May 2026 which recommended to improve:

(1) the analysis of non-compliance; and

(2) the rationale and comparison of the two policy options and the social/consumer

assessment.

The impact assessment was reviewed in the light of the RSB’s quality checklist and its non-

qualified opinion, and a revised impact assessment was shared as part of the interservice

consultation.

Regulatory fitness and simplification

The proposal is in line with the REFIT objectives. It proposes means to reduce compliance

costs for suppliers and dealers, increase the benefits of EPREL and improve the effectiveness

of MSAs. The proposal amends the existing Energy Labelling and Tyre Labelling

Regulations. In accordance with the ‘one in, one out’ principle, this omnibus is expected to

22 EEPLIANT - Home 23 Compliance Services

EN 9 EN

deliver up to EUR 12524 million in annual administrative cost savings, driven by the removal

and simplification of provisions over a 10-year period. The additional costs arising from new

obligations are estimated at EUR 11.5 million. The resulting indirect positive impacts for

suppliers, dealers, customers, and MSAs – stemming from a more level playing field – are not

captured in this monetisation.Fundamental rights

The proposal has no adverse impact on fundamental rights.

4. BUDGETARY IMPLICATIONS

Not applicable

5. OTHER ELEMENTS

Implementation plans and monitoring, evaluation and reporting arrangements

Not applicable.

Detailed explanation of the specific provisions of the proposal

Article 1 amends Regulation (EU) 2017/1369.

Article 2 amends Regulation (EU) 2020/740.

Article 3 repeals Regulation (EC) No 106/2008 and Regulation (EU) No 174/2013.

Annex I replaces Annex III to Regulation (EU) 2020/740.

Annex II amends Annex IV to Regulation (EU) 2020/740

Annex III amends Annex VII to Regulation (EU) 2020/740

24 This figure is EUR 2 million/year higher than the quantification in the Impact Assessment Report due to

slight adjustments in the measures proposed.

EN 10 EN

2026/0169 (COD)

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)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular Article 114

and Article 194(2) thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national Parliaments,

Having regard to the opinion of the European Economic and Social Committee25,

Having regard to the opinion of the Committee of the Regions26,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) The political guidelines for the Commission’s 2024-2029 term27 point to the goal of

simplifying legislation to eliminate any overlaps and contradictions, while maintaining

original policy objectives. In its communication on a Strategy for a single market28, the

Commission acknowledges digitalisation of paper formats as a key lever for a smooth

functioning single market. That digitalisation is partly implemented for the product

information sheet, but not yet for the energy label.

(2) The Draghi report29 points to insufficient market surveillance and poor enforcement as

major shortcomings in the implementation of the EU ecodesign and energy labelling

frameworks. This includes missing, fake or wrongly-placed labels, and wrong or

inconsistent declarations of energy efficiency on labels and in the European Product

Registry for Energy Labelling (‘EPREL’).

(3) In the context of the Commission’s commitment to reduce administrative burdens and

compliance costs, enhance interoperability, and stimulate competitiveness, it is opportune to

amend certain provisions of Regulation (EU) 2017/1369 of the European Parliament and of

25 OJ C [...], [...], p. [...]. 26 OJ C [...], [...], p. [...]. 27 Europe’s Choice, Political Guidelines for the next European Commission 2024−2029, Ursula von der Leyen. 28 COM (2025) 500. 29 Draghi, M. (2024), The future of European competitiveness.

EN 11 EN

the Council 30 setting a framework for energy labelling and Regulation (EU) 2020/740 of the

European Parliament and of the Council 31 on the labelling of tyres.

(4) It is appropriate to take advantage of opportunities for simplification and digitalisation,

which were not anticipated when Regulation (EU) 2017/1369 and Regulation (EU)

2020/740 were adopted. In particular, the further development and wider use of EPREL,

established in accordance with Article 12 of Regulation (EU) 2017/1369, represent such

opportunities that are not yet fully exploited. This database contains over two million model

entries for energy-related products and tyres, and the introduction of QR codes on the

respective labels unlocks access to comprehensive information on the products for dealers,

distributors, customers and end users.

(5) Energy-related products are very diverse and range from electronics and white goods to

large heating and cooling appliances. There is a need for more flexibility on when and how a

label is to be delivered with each product, in view of the diversity in products and

distribution channels. The requirement to have a printed label for each unit should be

adapted to the product specificities that enable to identify the best combination of digital and

printed label transmission.

(6) Experience shows that the electronic format of the product information sheet has been

accepted by the market, and it should be made fully digital. The right of dealers to request a

printed copy of this product information sheet should therefore be removed. In order to

ensure that customers, installer, dealers, professional repairers, recyclers and any other

stakeholder and the public in general nevertheless have access to product information such

as maintenance and repair instructions stored in EPREL, it is appropriate to specify that

suppliers should include information in the documentation accompanying the product, the

technical promotional material, in visual advertisements, and in distance selling, thereby

allowing to retrieve the information registered in EPREL.

(7) The reports under Article 19 of Regulation 2017/1369 and under Article 15 of Regulation

(EU) 2020/740, and the results of compliance checks carried out by national market

surveillance authorities and other market actors, point to persistent insufficient levels of

market surveillance and resulting high levels of non-compliance, particularly for online

sales. Some of them are rooted in unclear definitions and technical specifications that should

be clarified.

(8) To avoid the need for economic operators of energy-related products to register multiple

times the same model-related information, it is appropriate to ensure a technical link

between EPREL and the centralised element of the future digital registry under Regulation

(EU) 2024/178132. A single system for electronic verification of the identity of suppliers for

both databases also reduces the burden for suppliers. The reuse of information registered in

EPREL for national purposes, such as documenting eligibility with financial incentives for

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

for energy labelling and repealing Directive 2010/30/EU (OJ L 198, 28.7.2017, pp. 1–23, ELI:

http://data.europa.eu/eli/reg/2017/1369/oj). 31 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 (OJ L 177, 5.6.2020, pp. 1–31, ELI: http://data.europa.eu/eli/reg/2020/740/oj). 32 Regulation (EU) 2024/1781 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 (OJ L, 2024/1781,

28.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1781/oj).

EN 12 EN

products in scope, should also be encouraged in line with the ‘once-only’ mandate set out in

Regulation (EU) 2018/1724 establishing a single digital gateway33.

(9) The supplier obligations laid down in Regulation (EU) 2017/1369 apply to EU

manufacturers, importers and authorised representatives, all of which are required to comply

with those obligations. It is appropriate to eliminate ambiguity about the scope of the

mandates of Union-based authorised representatives registering energy-related products on

behalf of manufacturers established outside the Union. To provide more clarity for market

surveillance authorities about who can be requested to take corrective action if a product

fails to comply with energy labelling rules, authorised representatives should therefore be

required to include a copy of their mandate in the compliance part of EPREL. This is

without prejudice to the obligations of authorised representatives in accordance with other

Union legislation.

(10) Information referring to an offer of products placed on the market or made available on the

market which are not compliant with this Regulation should be considered to be illegal

content within the meaning of Regulation (EU) 2022/206534. Regulation (EU) 2022/2065

also provides that online marketplaces are obliged to design and organise their online

interface in a way that allows traders to provide, among others, information concerning the

labelling and marking in compliance with rules of applicable Union law on product safety

and product compliance. This information may include unambiguous product identifiers and

the related machine-readable and freely accessible pre-contractual information available via

the public interface of EPREL.

(11) Customers may be influenced by labelling information being shown at different stages of an

online shopping process and before the actual purchasing decision is made. In online

distance selling, the simplified label display with nested display mechanisms should

therefore be visible not only on the main product page, but also on other relevant pages such

as those listing or comparing alternatives and on the shopping basket page shown before a

purchase is completed.

(12) It is appropriate to continuously monitor that sufficient action is taken by market

surveillance authorities to address non-compliance and that the Commission regularly

reports on efforts and progress made.

(13) The existing provisions in Regulation (EU) 2017/1369 on greying out empty energy labels

classes on the label for lower classes in which models are no longer allowed to be placed on

the market or put into service because of an ecodesign implementing measure have proved

difficult to implement and should be removed.

(14) Intermediary actors such as installers or tyre fitters, as well as dealers not selling to

customers or end users directly, should make sure that the energy labelling related

information is handed down the supply chain. Intermediary actors should comply with the

obligations set for dealers under the energy labelling and tyre labelling frameworks when

they, as part of their commercial activity, offer products or tyres for sale, hire or hire-

purchase, or display products to customers or tyres to end users.

33 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018 establishing a

single digital gateway to provide access to information, to procedures and to assistance and problem-solving

services and amending Regulation (EU) No 1024/2012 (OJ L 295, 21.11.2018, pp. 1–38) 34 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 (Digital Services Act) (OJ L 277,

27.10.2022, pp. 1–102, ELI: http://data.europa.eu/eli/reg/2022/2065/oj).

EN 13 EN

(15) To simplify the transition period in case of label rescaling, suppliers should no longer be

required to provide both the non-rescaled and the rescaled labels with each unit placed on

the market during the 4-month transition period preceding the date as from which rescaled

labels apply. During that period, suppliers should be required to provide only the non-

rescaled or rescaled label, or should be allowed to supply both labels. After the rescaling

date, suppliers should only provide the rescaled label with any units placed on the market.

(16) The current 14-working-day deadline for dealers to substitute non-rescaled labels by

rescaled labels on products on display both in shops and online should be replaced by a

more flexible, stock-driven process managed by dealers. In that context, dealers should

simply ensure that the labels delivered with products to customers correspond to the label

used for display. Dealers should be able to continue displaying and selling units that they

received with only the non-rescaled label until 12 months after the rescaling date.

(17) Unlike Regulation (EU) 2017/1369, which relies on delegated acts to lay down product-

specific technical requirements, Regulation (EU) 2020/740 incorporates all technical

specifications directly in its annexes. However, the scope of the existing empowerment does

not allow for the update of important parameters of the tyre label in line with technological

and market developments, as is the case for energy labelling. The procedure for amending

the tyre label should therefore be aligned with the rules for energy labelling, by empowering

the Commission to amend the tyre label and the technical annexes, and to align with

ecodesign information requirements established under Regulation (EU) 2024/1781.

(18) There is a need to improve the effectiveness of the EU tyre label scheme and its enforcement

to enable end-users to identify safe and fuel-efficient tyres that are compliant. Obligations

for dealers should also be proportionate. Therefore, detailed specifications for simplified

label display via nested display mechanisms for online sales, in promotional material and in

tyre catalogues should be included and obligations for vehicle dealers should be removed.

(19) The Agreement between the Government of the United States of America and the European

Community on the coordination of energy-efficiency labelling programmes for office

equipment the Energy Star Agreement expired in February 2018. Regulation (EC) No

106/2008 of the European Parliament and of the Council35 and Regulation (EU) No

174/2013 of the European Parliament and of the Council36, which implemented that

agreement, should therefore be repealed.

HAVE ADOPTED THIS REGULATION:

Article 1

Amendments to Regulation (EU) 2017/1369

Regulation (EU) 2017/1369 is amended as follows:

(1) in Article 2, the following points are added:

‘(27) ‘European product registry for energy labelling’ or ‘EPREL’ means the product

database established and maintained by the Commission in accordance with Article 12;

35 Regulation (EC) No 106/2008 of the European Parliament and of the Council of 15 January 2008 on a

Community energy-efficiency labelling programme for office equipment (OJ L 39, 13.2.2008, p. 1, ELI:

http://data.europa.eu/eli/reg/2008/106/oj). 36 Regulation (EU) No 174/2013 of the European Parliament and of the Council of 5 February 2013 amending

Regulation (EC) No 106/2008 on a Community energy-efficiency labelling programme for office equipment

(OJ L 63, 6.3.2013, p. 1, ELI: http://data.europa.eu/eli/reg/2013/174/oj).

EN 14 EN

(28) ‘EPREL model registration number’ means the unique registration number of a model

in the product database established under Article 12;

(29) 'installer' means a natural or legal person responsible for the correct and safe

installation, setting up, or fitting of energy-related products on the Union market;

(30) ‘rescaling date’ is the date specified in the relevant delegated act at which each unit of

a model placed on the market by the supplier is to be accompanied only by the rescaled

label;

(31) ‘nested display’ means a visual interface where an image or data set is accessed by a

mouse click, mouse roll-over or tactile screen expansion of another image or data set;

(32) ‘invitation to purchase’ means invitation to purchase as defined in article 2 point (i),

of Directive 2005/29/EC37 of the European Parliament and of the Council.’

(2) Article 3 is amended as follows:

(a) paragraph 1 is replaced by the following:

‘1. The supplier shall ensure that products that are placed on the market are provided

with, for each individual unit, free of charge, accurate labels in accordance with this

Regulation and as specified in the relevant delegated acts In view of the

characteristics of the product, delegated acts shall specify how the label and other

labelling-relevant information, such as the QR code, is to appear on the product, on

its packaging or in the documents accompanying the product.

The supplier shall enter the parameters of the product information sheet into the

product database in accordance with Article 4 and the relevant delegated act. A link

to that information shall be provided by the supplier along with the label’;

(b) paragraph 2 is replaced by the following:

‘2. Upon a dealer’s request, suppliers shall send printed labels, including rescaled

labels in accordance with Article 11(13), free of charge, promptly and in any event

within five working days from receiving that request.’;

(3) Article 4 is amended as follows:

(a) the following paragraph (3a) is inserted:

‘(3a). The supplier shall indicate the EPREL model registration number, or provide

the link or insert the QR code to the model’s web page in EPREL, in the documents

accompanying the product, in visual advertisements and technical promotional

material as well as in online distance selling.’;

(b) the following paragraph (3b) is inserted:

‘(3b). The authorised representative of a manufacturer not established in the Union

shall upload in EPREL a signed copy of the mandate received from the manufacturer

in an official language of the Member State where the authorised representative is

37 Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair

business-to-consumer commercial practices in the internal market and amending Council Directive

84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of Directive

2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-

consumer commercial practices in the internal market and amending Council Directive 84/450/EEC, Directives

97/7/EC, 98/27/EC and 2002/65/EC of the Europe (OJ L149, 11.6.05, p14 ELI:

http://data.europa.eu/eli/dir/2005/29/2022-05-28).

EN 15 EN

established. The mandate shall, as a minimum, include contact details of both the

manufacturer and the authorised representative and shall confer on the authorised

representative the ability to follow up on requests of market surveillance authorities.

It shall specify the content and limits of the authorised representative’s tasks, as well

as information on the brands or trademarks, models and the geographical scope and

duration covered by that mandate.

Any changes in the tasks performed by the authorised representative on behalf of the

manufacturer, any change in the scope or duration of the mandate or any change in

the name and contact details of the authorised representative shall be registered by

the authorised representative in EPREL without delay.’;

(4) Article 5 is amended as follows:

(a) the title is replaced by the following:

‘Obligations of dealers and installers’;

(b) paragraph 1 is replaced by the following:

‘1. Dealers shall:

(a) ‘display, for products physically on display, the label in a visible manner in

proximity to the product in such a way that the label is unequivocally and easily

identified with the specific model;

(b) display, for products on display via online distance selling, the label in proximity

to the price and on the product detail page, search result pages and the shopping

basket page. Dealers may display the label in the simplified label format with nested

display consisting of an energy class arrow including the applicable range and

directly giving access to the complete label, as specified in the relevant delegated act;

(c) in invitations to purchase, and in contractual offers, include the relevant label as

material (pre-)contractual information that enables the customer to make informed

purchases;

(d) in any dealer to dealer transaction, provide the EPREL registration number or the

link or QR code leading to the registration of that model in EPREL;

(e) make available to customers the product information sheet as specified in the

relevant delegated act.’;

(c) paragraph 2 is replaced by the following:

‘2. Installers who, as part of their activity offer for sale, hire or hire-purchase a

product shall comply with the obligations under letters (c) and (d) of paragraph 1 of

this Article, and if applicable, the other obligations of dealers referred to in paragraph

1 of this Article.’;

(d) paragraph 3 is deleted;

(5) In Article 9(2), the following subparagraph is added:

‘Market surveillance authorities may reduce the visibility to the public of the product in

EPREL and display appropriate warnings until the non-compliance ceases, using the

harmonised functionalities provided for this purpose in EPREL.’;

(6) The following Article (9a) is inserted:

‘Article 9a

EN 16 EN

Reporting by the Commission

1. The Commission shall, every four years, draw up a report by 30 June based on the

information entered by market surveillance authorities into the information and

communication system referred to in Article 34 of Regulation (EU) 2019/1020.

That report may be combined and published simultaneously with the report required under

Article 67 of Regulation (EU) 2024/1781 and shall include:

(a) information on the nature and number of checks performed by market

surveillance authorities during the four preceding calendar years pursuant to

Article 34(4) and (5) of Regulation (EU) 2019/1020;

(b) information on the level and nature of non-compliance identified and, on the

nature and severity of penalties imposed in the four preceding calendar years in

relation to products covered by delegated acts adopted pursuant to Article 4 of

this Regulation;

(c) a comparison of the information referred to in points (a) and (b) of this

paragraph with the activities planned in the context of the section on the market

surveillance activities drawn up pursuant to Article 8(3);

(d) indicative benchmarks for market surveillance authorities in relation to the

frequency of checks and the nature and severity of penalties imposed;

(e) a list of priorities for market surveillance authorities in terms of products and

requirements.’

2. The Commission shall publish the report referred to in paragraph 1 of this Article in the

information and communication system referred to in Article 34 of Regulation

(EU) 2019/1020 and shall make it publicly available. The first of those reports shall be

published by 19 July 2032.’;

(7) Article 11 is amended as follows:

(a) paragraph (10) is deleted;

(b) paragraph (13) is replaced by the following:

‘13. Where, pursuant to paragraph 1 or 3, a label is rescaled:

(a) the suppliers shall, when placing a product on the market during the period

beginning four months before the rescaling date, provide either the non-

rescaled label and the related product information sheet or the rescaled label

and the related product information sheet, or may provide both. As of the

rescaling date, suppliers shall provide only the rescaled label and the related

product information sheet with products placed on the market;

(b) the dealer shall display or advertise the label at the point of sale that

corresponds to the label that is provided with the unit that is offered or sold to a

customer. When both the non-rescaled and rescaled label are provided by the

supplier, the dealer shall only use the rescaled label as of the rescaling date;

(c) the dealer shall be permitted to sell units of models placed on the market before

the rescaling date and accompanied only with the non-rescaled label until

12 months after the rescaling date.’;

(8) Article 12 is amended as follows:

EN 17 EN

(a) in paragraph (5), the second subparagraph is replaced by the following:

‘In addition, the supplier may upload, on a voluntary basis, additional parts of the

technical documentation, including test reports and other documents related to

ecodesign or energy labelling requirements or conformity assessment for the models

registered in EPREL. Where a supplier has chosen to upload such documents, or

where such documentation is available to the authorities via a Digital Product

Passport linked to the model’s registration in EPREL, the information included in

EPREL shall be accepted for the purposes of Article 7(2).’;

(b) the following paragraph is added:

‘(13.) Where provided for by Union law, the Commission shall ensure the integration

between EPREL and the central part of the registry to be established under Article 13

of Regulation (EU) 2024/1781.’;

(9) Article 16 paragraph (3) is amended as follows:

(a) point (e) is replaced by the following:

‘(e) the manner in which labels and QR codes appear on the product or on its

packaging, or are to be included in the user manual or other documentation provided

with the product;’;

(b) point (g) is replaced by the following:

‘(g) the manner in which the label and the product information sheet, the detailed

information in the product information sheet, or the link to the product registration in

EPREL, are to be provided, including in the case of distance selling;’;

(c) the following point (r) is added:

‘(r) where applicable, if and how installers have to display or provide the label.’.

Article 2

Amendments to Regulation (EU) 2020/740

Regulation (EU) 2020/740 is amended as follows:

(1) in Article 3, the following points are added:

‘(25) ‘European product registry for energy labelling’ or ‘EPREL’ means the product

database established and maintained by the Commission in accordance with Article 12 of

Regulation (EU) 2017/1369;

(26) ‘tyre fitter’ means a natural or legal person who is responsible for the correct and safe

fitting and setting up of tyres on vehicles.’;

(27) ‘nested display’ means a visual interface where an image or data set is accessed by a

mouse click, mouse roll-over or tactile screen expansion of another image or data set;’

(2) in Article 4(1), point (b) is replaced by the following:

‘(b) for each batch of two or more identical tyres, by a tyre label that complies with the

requirements set out in Annex II, indicating the information and class for each of the

parameters set out in Annex I.’;

(3) in Article 5, paragraph1 is replaced by the following:

EN 18 EN

‘1. Suppliers shall enter the information set out in Annex III and in Annex VII into EPREL

before placing on the market a tyre produced after that date. A link to that information

shall be provided along with the label.’;

(4) Article 6 is amended as follows:

(a) the title is replaced by the following:

‘Obligations of tyre distributors and tyre fitters’;

(b) in paragraph 1, points (a) and (b) are replaced by the following:

‘(a) at the point of sale, tyres bear a tyre label, in the form of a sticker, that complies

with the requirements set out in Annex II, provided by the supplier in accordance

with point (a) of Article 4(1) in a clearly visible position and legible in its entirety; or

(b) before the sale of a tyre that is part of a batch of two or more identical tyres, a

tyre label that complies with the requirements set out in Annex II, is shown to the

end-user and is clearly displayed close to the tyre at the point of sale.’;

(c) paragraph 2 is replaced bythe following:

‘2. Distributors shall ensure that the EPREL tyre registration number or the link or

QR code leading to the tyre registration in EPREL is included in all tyre offers,

visual advertisements and on invoices. If a price is indicated, the tyre label, or the

tyre classes as set out in Annex IV, shall be displayed close to the price

indication. For online sales, distributors may make the tyre label available in a nested

display as set out in Annex IV close to the price indication.’;

(d) paragraphs 4, 5 and 6 are deleted;

(e) the following paragraph is added:

‘4. In catalogues or technical promotional material, where displaying the full label is

not possible or advisable, the rolling resistance, the wet grip and the noise classes

may be shown by the means of a simplified label format with nested display

consisting of class arrows including the applicable ranges as set out in Annex IV and

directly giving access to the complete label.’;

(5) Article 7 is deleted.

(6) Article 13 is amended as follows:

Paragraph 1, point (b), is replaced by the following:

‘(b) Annexes I, II, III, IV, V, VI and VII, by adapting the values, calculation methods and

requirements set out therein to technological or market developments or to ecodesign

information requirements set out in delegated acts adopted pursuant to Regulation (EU)

2024/1781’;

(7) Annex III is replaced by the text in Annex I to this Regulation;

(8) Annex IV amended in accordance with Annex II to this Regulation;

(9) Annex VII is amended in accordance with Annex III to this Regulation.

Article 3

Repeal of Regulation (EC) No 106/2008 and Regulation (EU) No 174/2013

Regulation (EC) No 106/2008 and Regulation (EU) No 174/2013 are repealed.

EN 19 EN

Article 4

Entry into force

This Regulation shall enter into force on the twentieth day following that of its publication in the

Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels,

For the European Parliament For the Council

The President The President

Roberta Metsola António Costa

EN 20 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Regulation of the European Parliament and of the Council amending

Regulation (EU) 2017/1369 setting a framework for energy labelling and Regulation (EU)

2020/740 on tyre labelling

1.2. Policy area(s) concerned

Energy

1.3. Objective(s)

1.3.1. General objective(s)

The general objective pursued by this legislative proposal is to simplify elements of

Regulations (EU) 2017/1369 and (EU) 2020/740 in order to reduce administrative costs for

businesses and improving compliance, while preserving the effectiveness of existing

legislation and the framework established by the recently agreed Ecodesign for sustainable

Products Regulation (EU) 2024/1781.

The regulatory framework for energy efficient products is well established and enjoys the

support of most manufacturers, retailers and consumers. With the European Product

Registry for Energy Labelling (EPREL) database offering digital possibilities that were not

anticipated at the time, it seems opportune to revisit the interplay between obligations

asking for printed documents and digital formats.

The proposal also aims to tackle the persistent high levels of non-compliant products

(particularly in online shops).

1.3.2. Specific objective(s)

The specific objectives of the proposed amendments to Regulations (EU) 207/1369 and

(EU) 2020/740 included in this proposal aim to achieve the following results:

Reducing administrative complexity and cumulative burden by providing the possibility to

adjust supplier obligation to accompany each unit with a printed label in view of the

particular characteristics of the product. Remove the option for dealers to request printed

product information sheets.

Digitalising product information for easier display in shops as well as easier and more

long-term access to product life span related information accessible in the product database

to end users/consumers such as maintenance information, information on spare parts and

end of life product.

Streamlining EPREL registration obligations to increase usefulness and usability of the

registered information, and to facilitate online compliance.

Increasing compliance with labels, particularly for tyres, heating and cooling appliances,

and in online shops

Simplifying processes for adapting tyre label requirements to changes in technology or

market conditions

Improving market surveillance by clarifying legal concepts and by making better use of

EPREL to tackle non-compliance

EN 21 EN

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the beneficiaries/groups

targeted.

The proposed amendments to Regulations (EU) 2017/1369 and Regulation (EU) 2020 will

affect: manufacturers (EU-based or from third countries) of energy-related products with

an energy label, tyre manufacturers, tyre and car dealers, tyre distributors, energy

product dealers (both wholesale and direct-to-consumer sellers), consumers, SMEs and

other businesses buying or leasing energy-related products and tyres, providers of online

marketplaces, importers and authorised representatives of products within scope, installers

and national market surveillance authorities.

The proposal will improve the effectiveness of the policies through a better interplay of

digital and printed documents. It will improve the level playing field for compliant

suppliers and dealers.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

To monitor progress towards achieving the proposal’s specific objectives, the Commission

will use existing fora (AdCO (sector-specific formations); Ecodesign and Energy Labelling

Consultation Forum and ecodesign for sustainable products and energy labelling

Consultation Forum) and monitor developments as part of EU funded projects to support

implementation and compliance.

Product-specific reviews under the energy labelling framework and their accompanying

evaluations will shed light on the effect of the changes.

In addition, the EPREL product database allows for continued market monitoring and for

receiving complaints on non-compliant products. Finally, compliance will be monitored

through the relevant procedures, including the ICSMS database that is interlinked with

EPREL.

1.4. The proposal/initiative relates to:

☐ a new action

☐ a new action following a pilot project/preparatory action 38

☐ the extension of an existing action

☑ a merger or redirection of one or more actions towards another/a new action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long-term including a detailed timeline for roll-

out of the implementation of the initiative

N/A. The Regulations are directly applicable.

The Commission will in its role as manager of the database implement accompanying

changes in the set-up of the EPREL database once the proposal is adopted.

1.5.2. Added value of EU involvement (it may result from different factors, e.g. coordination

gains, legal certainty, greater effectiveness or complementarities). For the purposes of this

38 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 22 EN

section 'added value of EU involvement' is the value resulting from EU action, that is

additional to the value that would have been otherwise created by Member States alone.

Improved harmonised single market rules.

Greater effectiveness of EU-wide product database, including for national enforcement

activities and national funding schemes

for more details cf. subsidiarity chapter of the IA

1.5.3. Lessons learned from similar experiences in the past

The reports required under Article 19 of Regulation (EU) 2017/1369 and Article 15 of

Regulation (EU) 2020/740 contain evidence on effectiveness of implementation and

legislative set-up.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with other

appropriate instruments

N/A

1.5.5. Assessment of the different available financing options, including scope for redeployment

N/A

1.6. Duration of the proposal/initiative and of its financial impact

☐ limited duration

☐ in effect from [DD.MM]YYYY to [DD.MM]YYYY

☐ financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

☑ unlimited duration

Implementation with a start-up period from YYYY to YYYY,

followed by full-scale operation.

1.7. Method(s) of budget implementation planned 39

☐ Direct management by the Commission

☐ by its departments, including by its staff in the Union delegations;

☐ by the executive agencies

☐ Shared management with the Member States

☐ Indirect management by entrusting budget implementation tasks to:

☐ third countries or the bodies they have designated;

☐ international organisations and their agencies (to be specified);

☐ the European Investment Bank and the European Investment Fund;

☐ bodies referred to in Articles 70 and 71 of the Financial Regulation;

39 Details of budget implementation methods and references to the Financial Regulation may be found on the

BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 23 EN

☐ public law bodies;

☐ bodies governed by private law with a public service mission to the extent that

they are provided with adequate financial guarantees;

☐ bodies governed by the private law of a Member State that are entrusted with

the implementation of a public-private partnership and that are provided with

adequate financial guarantees;

☐ bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on

European Union, and identified in the relevant basic act

☐ bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance with

sector-specific rules, with the implementation of Union funds or budgetary

guarantees, to the extent that such bodies are controlled by public law bodies or

by bodies governed by private law with a public service mission, and are

provided with adequate financial guarantees in the form of joint and several

liability by the controlling bodies or equivalent financial guarantees and which

may be, for each action, limited to the maximum amount of the Union support.

Comments

N/A

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

N/A

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

N/A

2.2.2. Information concerning the risks identified and the internal control system(s) set up to

mitigate them

N/A

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between the

control costs and the value of the related funds managed), and assessment of the expected

levels of risk of error (at payment & at closure)

N/A

2.3. Measures to prevent fraud and irregularities

N/A

EN 24 EN

3.

EN 25 EN

4. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

4.1. Heading(s) of the multiannual financial framework and expenditure budget line(s) affected

Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading

of

multiannu

al

financial

framework

Budget

line

Type of

expenditur

e

Contribution

Number Diff./Non-

diff. 40

from

EFTA

countries 41

from

candidate

countries

and

potential

candidates 42

from other

third

countries

other

assigned

revenue

N/A Diff./Non-

diff.

New budget lines requested

In order of multiannual financial framework headings and budget lines.

Heading

of

multiannu

al

financial

Budget

line

Type of

expenditur

e

Contribution

Number Diff./non- from from from other other

40 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 41 EFTA: European Free Trade Association. 42 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 26 EN

framework diff. EFTA

countries

candidate

countries

and

potential

candidates

third

countries

assigned

revenue

N/A Diff./Non-

diff. YES/NO YES/NO YES/NO YES/NO

4.2. Estimated financial impact of the proposal on appropriations

4.2.1. Summary of estimated impact on operational appropriations

☑ The proposal/initiative does not require the use of operational appropriations

☐ The proposal/initiative requires the use of operational appropriations, as explained below:

4.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

EN 27 EN

Appropriations of an administrative nature financed from the envelope of specific programmes 43

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 44

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

43 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research. 44 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 28 EN

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational

appropriations

Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative

nature financed from the envelope for specific

programmes

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING <....>

of the multiannual financial

framework

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial

framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

EN 29 EN

Appropriations of an administrative nature financed from the envelope of specific programmes 45

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 46

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

45 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research. 46 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 30 EN

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational

appropriations

Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative

nature financed from the envelope for specific

programmes

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING <....>

of the multiannual financial

framework

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational

appropriations (all operational

headings)

Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative

nature financed from the envelope for specific

programmes (all operational headings)

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

Under Heading 1 to 6

of the multiannual financial

framework

(Reference amount)

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

EN 31 EN

Heading of multiannual financial framework 7 ‘Administrative expenditure’ 47

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

TOTAL DG <.......> Appropriations 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

TOTAL DG <.......> Appropriations 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations under HEADING 7

of the multiannual financial framework

(Total

commitmen

ts = Total

payments)

0.000 0.000 0.000 0.000 0.000

EUR million (to three decimal places)

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-2027

47 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 32 EN

TOTAL appropriations under

HEADINGS 1 to 7

of the multiannual financial framework

Commitments 0.000 0.000 0.000 0.000 0.000

Payments 0.000 0.000 0.000 0.000 0.000

4.2.1.2. Appropriations from external assigned revenues

EUR million (to three decimal places)

Heading of multiannual financial

framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line

Commit

ments (1a) 0.000

Payment

s (2a) 0.000

Budget line

Commit

ments (1b) 0.000

Payment

s (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 48

Budget line (3) 0.000

48 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 33 EN

TOTAL appropriations

for DG <.......>

Commit

ments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payment

s =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line

Commit

ments (1a) 0.000

Payment

s (2a) 0.000

Budget line

Commit

ments (1b) 0.000

Payment

s (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 49

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commit

ments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

49 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 34 EN

Payment

s =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational

appropriations

Commit

ments (4) 0.000 0.000 0.000 0.000 0.000

Payment

s (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an

administrative nature financed from the

envelope for specific programmes

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING <....>

of the multiannual financial

framework

Commit

ments =4+6 0.000 0.000 0.000 0.000 0.000

Payment

s =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial

framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commit

ments (1a) 0.000

EN 35 EN

Payment

s (2a) 0.000

Budget line

Commit

ments (1b) 0.000

Payment

s (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 50

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commit

ments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payment

s =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line

Commit

ments (1a) 0.000

Payment

s (2a) 0.000

50 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 36 EN

Budget line

Commit

ments (1b) 0.000

Payment

s (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 51

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commit

ments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payment

s =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational

appropriations

Commit

ments (4) 0.000 0.000 0.000 0.000 0.000

Payment

s (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an

administrative nature financed from the

envelope for specific programmes

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations Commit =4+6 0.000 0.000 0.000 0.000 0.000

51 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 37 EN

under HEADING <....>

of the multiannual financial

framework

ments

Payment

s =5+6 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational

appropriations (all operational

headings)

Commit

ments (4) 0.000 0.000 0.000 0.000 0.000

Payment

s (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an

administrative nature financed from the

envelope for specific programmes (all

operational headings)

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under Headings 1 to 6

of the multiannual financial

framework (Reference

amount)

Commit

ments =4+6 0.000 0.000 0.000 0.000 0.000

Payment

s =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial

framework 7 ‘Administrative expenditure’ 52

EUR million (to three decimal places)

DG: <.......> Year Year Year Year TOTAL

MFF

52 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 38 EN

2024 2025 2026 2027 2021-2027

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

TOTAL DG <.......> Appropriations 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-2027

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

TOTAL DG <.......> Appropriations 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations under HEADING 7 of the

multiannual financial framework

(Total

commit

ments

= Total

payme

nts)

0.000 0.000 0.000 0.000 0.000

EUR million (to three decimal places)

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-

2027

TOTAL appropriations under HEADINGS 1 to 7 Commitments 0.000 0.000 0.000 0.000 0.000

EN 39 EN

of the multiannual financial framework Payments 0.000 0.000 0.000 0.000 0.000

4.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indi

cate

obje

ctive

s

and

outp

uts

⇓

Year

2024

Year

2025

Year

2026

Year

2027

Enter as many years as necessary to show

the duration of the impact (see Section 1.6) TOTAL

OUTPUTS

Type 53

Aver

age

cost

No Cost No Cost No Cost No Cost No Cost No Cost No Cost Total

No

Total

Cost

SPECIFIC

OBJECTIVE No 1 54: [...]

-

Outp

ut

-

Outp

ut

-

Outp

53 Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.). 54 As described in point 1.4.2. 'Specific objective(s)...'

EN 40 EN

ut

Subtotal for specific

objective No 1

SPECIFIC

OBJECTIVE No 2

...

-

Outp

ut

Subtotal for specific

objective No 2

TOTALS

4.2.3. Summary of estimated impact on administrative appropriations

☑ The proposal/initiative does not require the use of appropriations of an administrative nature

☐ The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:

4.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

EN 41 EN

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

Outside HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

4.2.3.2. Appropriations from external assigned revenues

EXTERNAL ASSIGNED REVENUES Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

Outside HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000

EN 42 EN

Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

4.2.3.3. Total appropriations

TOTAL

VOTED APPROPRIATIONS

+

EXTERNAL ASSIGNED REVENUES

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-2027

HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

Outside HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other expenditure of an administrative

nature 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

EN 43 EN

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from

the DG that are already assigned to management of the action and/or have been redeployed within the DG, together, if necessary, with

any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary

constraints.

4.2.4. Estimated requirements of human resources

☑ The proposal/initiative does not require the use of human resources

☐ The proposal/initiative requires the use of human resources, as explained below

4.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs) 55

VOTED APPROPRIATIONS Year

2024

Year

2025

Year

2026

Year

2027

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's Representation Offices) 0 0 0 0

20 01 02 03 (EU Delegations) 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0

Other budget lines (specify) 0 0 0 0

External staff (in FTEs)

20 02 01 (AC, END from the 'global envelope') 0 0 0 0

55 Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed within

your DG and what are your net needs.

EN 44 EN

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0

Admin. support line

[XX.01.YY.YY]

- at Headquarters 0 0 0 0

- in EU Delegations 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0

TOTAL 0 0 0 0

4.2.4.2. Financed from external assigned revenues

EXTERNAL ASSIGNED REVENUES Year

2024

Year

2025

Year

2026

Year

2027

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's Representation Offices) 0 0 0 0

20 01 02 03 (EU Delegations) 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0

Other budget lines (specify) 0 0 0 0

EN 45 EN

External staff (in full time equivalent units)

20 02 01 (AC, END from the global envelope) 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0

Admin. support line

[XX.01.YY.YY]

- at Headquarters 0 0 0 0

- in EU Delegations 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0

TOTAL 0 0 0 0

4.2.4.3. Total requirements of human resources

TOTAL

VOTED APPROPRIATIONS

+

EXTERNAL ASSIGNED REVENUES

Year

2024

Year

2025

Year

2026

Year

2027

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's Representation Offices) 0 0 0 0

20 01 02 03 (EU Delegations) 0 0 0 0

EN 46 EN

01 01 01 01 (Indirect research) 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0

Other budget lines (specify) 0 0 0 0

External staff (in full time equivalent units)

20 02 01 (AC, END from the global envelope) 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0

Admin. support

line

[XX.01.YY.YY]

- at Headquarters 0 0 0 0

- in EU Delegations 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0

TOTAL 0 0 0 0

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

EN 47 EN

To be financed

under Heading

7 or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts N/A

External staff

(CA, SNEs,

INT)

Description of tasks to be carried out by:

Officials and temporary staff

External staff

4.2.5. Overview of estimated impact on digital technology-related investments

TOTAL Digital and IT

appropriations

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-2027

HEADING 7

IT expenditure (corporate) 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

Outside HEADING 7

Policy IT expenditure on

operational programmes 0.000 0.000 0.000 0.000 0.000

EN 48 EN

Subtotal outside HEADING

7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

EN 49 EN

4.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

☐ can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF).

☐ requires use of the unallocated margin under the relevant heading of the MFF and/or

use of the special instruments as defined in the MFF Regulation.

☐ requires a revision of the MFF.

EN 50 EN

4.2.7. Third-party contributions

The proposal/initiative:

☑ does not provide for co-financing by third parties

☐ provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year

2024

Year

2025

Year

2026

Year

2027 Total

Specify the co-financing body

TOTAL appropriations co-financed

4.3. Estimated impact on revenue

☑ The proposal/initiative has no financial impact on revenue.

☐ The proposal/initiative has the following financial impact:

☐ on own resources

☐ on other revenue

☐ please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

Budget revenue line:

Appropriations

available for the

current financial year

Impact of the proposal/initiative 56

Year

2024

Year

2025

Year

2026

Year

2027

56 As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20% for

collection costs.

EN 51 EN

Article ..........

For assigned revenue, specify the budget expenditure line(s) affected.

N/A

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

N/A

5. DIGITAL DIMENSIONS

5.1. Requirements of digital relevance

If the policy initiative is assessed as having no requirement of digital relevance, provide an explanation as to why digital means are not

used.

N/A

Otherwise, please list the requirements of digital relevance in the table below:

Reference to the

requirement

Requirement

description

Actor(s) affected or

concerned by the

requirement

High-level Processes Categories

Art 2 [Art 3(1) Article 4

and Art 11(13) of

Regulation 2017/1369]

Provide EPREL

registration number

and/or link to EPREL

Suppliers (manufacturers,

authorised representatives

of manufacturers outside

the EU) and importers).

Management of EPREL

for compliance

Digital public

service/data

Art 3 [Art 4 (8) of

Regulation 2017/1369]

Authorised

representatives to

upload voluntarily into

the compliance part of

EPREL a copy of the

mandate of the

manufacturer.

Authorised

representatives of 3rd

country manufacturers

Management of EPREL

for compliance

Digital public

service/data

EN 52 EN

Art 3 [Art 5 (1) of

Regulation 2017/1369]

Download and print

from EPREL database

the energy label for the

correct model and with

right colour scheme

and size.

Retailer

download and print label

if specified in product

specific act

Digital public service/

digital solution

Art 3 [Art 5 (2) of

Regulation 2017/1369]

Retailers can use

electronic displays for

label display

Retailers at point of sale Display label Digital solution

Art 3 [Annex I of

Regulation (EU)

2017/1369]

Suppliers to upload

into the compliance

part of the EPREL

database the testing

reports (or summary if

reports contain

sensitive info) on a

voluntary basis

Suppliers Management of EPREL

for compliance Digital solution

Art 3 [Art5 (3) of

Regulation 2017/1369]

Providers of online

marketplaces to verify

registration of a

product/supplier in

EPREL before offering

product for sale

Providers of online

marketplaces

Management of registry

for compliance Digital solution

Art 3 [Art 7 (2) of

Regulation 2017/1369]

Obligation on MS to

accept the information

contained in EPREL

for the purposes of

financial schemes

MS and applicants

for financial schemes

Digitalisation of

procurement

Data/Digital public

service

EN 53 EN

Art 4 [Annex III of

Regulation 2020/740]

information on tyre

characteristics to be

entered into EPREL

database (public part)

tyre manufacturers Management of registry Digital public service

Art 4 [Annex IV of

Regulation 2020/740]

information to be

provided in visual

advertisement

including access/link

to EPREL

tyre manufacturers Display Digital solution

Art 4 [Annex VII of

Regulation 2020/740]

information, including

test reports, to be

provided in the

compliance part of

EPREL

tyre manufacturers Data Digital public service

5.2. Data

High-level description of the data in scope and any related standards/specifications

Type of data Reference to the requirement(s) Standard and/or specification (if

applicable)

Public data and non-public compliance

data for energy-related products with label

placed on the single market and tyres.

Art 3 [Art 12 of Regulation (EU)

2017/1369 and annexes to Regulation

(EU) 2020/740 ]

Existing EPREL database and data

formats Implementation Regulation

2024/994.

Alignment with the European Data Strategy

Explain how the requirement(s) are aligned with the European Data Strategy

The proposal advances the European Data Strategy by ensuring adaptive and proportionate data management, sharing of data between

EU and national authorities and simplifying registration in EPREL. It maintains and extends interoperability and transparency of

EN 54 EN

EPREL. It makes better use of data already collected in EPREL. Registration and verification only to be done once for EPREL and the

registry to be set up under Regulation (EU) 2024/1781.

Alignment with the once-only principle

Explain how the once-only principle has been considered and how the possibility to reuse existing data has been explored

Existing information in EPREL is proposed to be used better by national authorities for financial incentives. Newly asked

documentation for the compliance part in EPREL and will avoid that the same information is requested from national authorities each

time when compliance is checked.

Explain how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

The changes build up on the established EPREL database set-up which is constantly improved for its user-friendliness. Additional

suggestions from stakeholders for which no change in legal mandate are required (e.g. including a photo and the brand name of the

product) will be implemented alongside the legal proposal by the European Commission. Modified data remains findable, accessible,

interoperable and reusable with different rules applying to the public and the compliance part.

Data flows

For each data flow, please fill the table below:

Type of data Reference(s) to the

requirement(s)

Actor who

provides the data

Actor who receives

the data

Trigger for the

data exchange

Frequency (if

applicable)

Testing reports for

all suppliers and

copy of the mandate

for and for

authorised

representatives the

mandate

Art 2 [Annex I and

Art 4 (8) of

Regulation (EU)

2017/1369]

Supplier of energy

related product with

label and authorised

representatives of

3rd country

manufacturers of

energy-related

products

National market

surveillance

authorities via EC

run EPREL

database

(compliance part)

upon entry into

force of revised

rules for existing

entries and when

putting a product

model on the EU

market

once

Testing reports for

tyre suppliers Art 3 [Annex VII of

Regulation Tyre suppliers

National market

surveillance

authorities via EC

upon entry into

force of revised

rules for existing

once

EN 55 EN

2020/447] run EPREL

database

(compliance part)

entries and when

putting a product

model on the EU

market

Additional product

specifications for

tyres

(Art 3 [Annexes III,

IV and VII of

2020/740]

Tyre supplier European

Commission

upon entry into

force of revised

rules for existing

entries and when

putting a product

model on the EU

market

once

5.3. Digital solutions

For each digital solution, please provide the reference to the requirement(s) of digital relevance concerning it, a description of the

digital solution's mandated functionality, the body that will be responsible for it, and other relevant aspects such as reusability and

accessibility. Finally, explain whether the digital solution intends to make use of AI technologies.

Digital solution

Reference(s) to

the

requirement(s)

Main mandated

functionalities

Responsible

body

How is

accessibility

catered for?

How is

reusability

Use of AI

technologies (if

EPREL

Article 3 [Art 3,

4, 5, 7, 11 (13)

and Annex of

Regulation]

Data collection,

data use

European

Commission

Compliance with

requirements of

accessibility act

ensured for

EPREL website.

Transition

ongoing to

ensure PIS and

energy label

output formats

from EPREL are

Develops an

already existing

database EPREL

n/a

EN 56 EN

aligned with

accessibility

For each digital solution, explain how the digital solution complies with the requirements and obligations of the EU cybersecurity

framework, and other applicable digital policies and legislative enactments (such as eIDAS, Single Digital Gateway, etc.).

Digital solution #1

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI n/a

EU Cybersecurity Incident management in place in MOV-ENER -SRD.

E-IDAS eIDAS is obligatory identity verification for suppliers as stipulated in Implementing

Regulation 2024/994. Considerations ongoing to expand to business wallet.

n/a

Others n/a

5.4. Interoperability assessment

Describe the digital public service(s) affected by the requirements

Digital public service

or category of digital

public services

Description Reference(s) to the

requirement(s)

Interoperable Europe

Solution(s)(NOT

APPLICABLE)

Other interoperability

solution(s)

national market

surveillance authorities

and national authorities

providing incentives for

Art 3 [Art 4 (8) and An

ex I of Regulation (EU)

2017/1369]

EN 57 EN

products within scope

Category of digital

public services

according to COFOG 57

#1

05 environment

protection

Assess the impact of the requirement(s) on cross-border interoperability

Digital public service #1 EPREL

Assessment Measure(s) Potential remaining barriers (if

applicable)

Alignment with existing digital and

sectorial policies. Please list the

applicable digital and sectorial policies

identified

Proposal to clarify integration of EPREL

with future digital product passport (DPP)

registry under Regulation (EU)

2024/1087. Ensuring output documents

from EPREL are accessible. Alignment

with GDPR.

Organisational measures for a smooth

cross-border digital public services

delivery. Please list the governance

measures foreseen

Proposal to obligate Member States to

accept information registered in EPREL

for purposes of national compliance

checks and financial incentive schemes

Measures taken to ensure a shared

understanding of the data. Please list

such measures

Explanatory pages and tutorial on EPREL

Use of commonly agreed open technical

specifications and standards. Please list applicable

57 https://op.europa.eu/en/web/eu-vocabularies/concept-scheme/-/resource?uri=http://data.europa.eu/7yx/cofog

EN 58 EN

such measures

5.5. Measures to support digital implementation

For each measure to support digital implementation, please fill in the table below

Description of the

measure

Reference(s) to the

requirement(s)

Commission role (if

applicable)

Actors to be involved

(if applicable)

Expected timeline (if

applicable)

update of tutorials

and explanations

provided on EPREL

website

European Commission

EN EN

EUROPEAN COMMISSION

Brussels, 24.6.2026

COM(2026) 565 final

ANNEXES 1 to 3

ANNEXES

to the

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

{SEC(2026) 565 final} - {SWD(2026) 565 final} - {SWD(2026) 566 final}

EN 1 EN

ANNEX I

‘ANNEX III

PUBLIC INFORMATION TO BE ENTERED INTO THE PRODUCT DATABASE BY

THE SUPPLIER

Pursuant to point 1 of Article 5, the supplier shall enter into the product database the

information as set out in Tables III A-D below, that becomes the product information sheet.

Promotional material or other commercial documents provided with the tyre shall include the

EPREL registration number or the link or QR code leading to the tyre type registration in

EPREL.

Table III A

Product Information Sheet

C1 tyres, C2 tyres and C3 tyres

1 Trade name or

trademark:

text Commercial

designation:

text

2 Tyre type

identifier

(article

code/number):

text Tyre class: C1 / C2 / C3

3 Tyre-size

designation:

xxx xx R / B / D xx xx E/F/G/J/K/L/M/N/P/Q/R/S/

T/U/H/V/ZR/W/Y

nominal

section

width

(s1) /

nominal

aspect

ratio

construction

type

nominal

diameter

“d” of

the rim

in

inches

load

index

speed rating

4 Fuel

efficiency

class:

A / B / C / D / E Rolling resistance

coefficient value

(N/kN)

x,x

5 Wet grip

class:

A / B / C / D / E Wet grip index value x,xx

6 External

rolling noise

class:

A / B / C External rolling noise

level in dB(A):

xx

7 For use in

severe snow

conditions

(3PMSF

marking):

yes / no For use in severe snow

conditions (ice

stalagmite marking):

yes / no

8 Tyre

certification

number (type

approval):

text UN ECE revision: text

EN 2 EN

Complementary parameters not relevant for compliance verification

Table III B

C1 tyres

1 A Extended mobility (1): (RF) Run flat / EMT) Extended mobility / Support Ring

2 A OEM vehicle brand

marking:

None/OEM mark Vehicle brand(s)

3 A Category of use (4): normal / special

use

If special use: M&S / ET

Table III C

C2 tyres

1 B Extended mobility: RF / EMT / Support Ring

2 B Additional service

description:

xxx xxx E / F / G / J / K / L /

M / N / P / Q / R / S

/ T / U / H

load-capacity

index for single

mounting

load-capacity

index for dual

mounting

speed category

symbol

3 B Category of use (4): normal / special

use

If special use: M&S / ET / ML /

MPT (multiple

possible)

Table III D

C3 new tyres

2C Mission profile:

(multiple possible) (2):

Long haul

Regional Urban Municipal Construc

tion (on-

off)

yes / no yes / no yes / no yes / no yes / no

1C Axle position (3): F / D / T/ Z If axle=T: FRT

3C Additional service

description (load-capacity

index):

xxx xxx E / F / G / J / K / L /

M / N / P / Q / R / S /

T / U / H

single

mounting

dual mounting speed category

symbol

4 C Tread depth (mm): xx Wet grip index

value of half worn

x,xx

EN 3 EN

tyre:

5 C Category of use (4): normal /

special use

If special use: M&S / ET / ML /

MPT (multiple

possible)

(1) RF) Run flat, “snail” marking, / EMT) Extended mobility, “swirl” marking, UNECE R30

E/ECE/324/Rev.1/Add.29/Rev.3/Amend.7

(2) As from Annex I, table 1 of Regulation 2017/2400

(3) F=front, D=drive, T=trailer, Z=any, FRT=free rolling as in UNECE R.54 E/ECE/324/Rev.1/Add.53/Rev.3/Amend.5

(4) As defined in UNECE R54 E/ECE/324/Rev.1/Add.53/Rev.3, in R.117 E/ECE/324/Rev.2/Add.116/Rev.5 and in R.54

E/ECE/324/Rev.1/Add.53/Rev.3/Amend.5

EN 4 EN

ANNEX II

Annex IV to Regulation (EU) 2020/740 is amended as follows:

(1) the title is replaced by the following:

‘INFORMATION TO BE PROVIDED IN VISUAL ADVERTISEMENTS, IN

PRODUCT CATALOGUES, IN TECHNICAL PROMOTIONAL MATERIAL

AND IN DISTANCE SELLING, INCLUDING DISTANCE SELLING ON THE

INTERNET”

(2) points 1 and 2 are replaced by the following:

‘1. Printed material

(I.) For the purposes of ensuring conformity with the requirements laid down in Articles

4(3), 4(4) and 6(2), in visual advertisements, in product catalogues and in technical

promotional material, and in the case of paper-based distance selling and telemarketing-based

distance selling, the rolling resistance class and the range of classes available on the label, the

wet grip class and the range of classes available on the label and the external rolling noise

class and value shall be displayed as indicated in Figure 1, and in accordance with the

following additional specifications:

(a) ‘class arrows’ shall be used, containing the letter, indicating the fuel efficiency,

wet grip and noise, centred in the rectangular part of the arrow;

(b) the class arrows shall have a border, and the internal background colour shall

match the colour of respectively fuel efficiency, wet grip and noise class in the

full label;

(c) the typeface of the ‘class letter’ shall be Noto Sans, bold, 100 % white, with an

outline in 100 % black and in a size equivalent to that of the price, if the price

is shown;

(d) the typeface of the range of available energy-efficiency classes shall be in Noto

Sans 100 % black on a white background.

(a) class arrow, with range of fuel efficiency classes

(a) (b) class arrow, with range of wet grip classes

(c) class arrow, with range of external rolling

noise classes

Figure 1: class arrows example, with range of energy-efficiency classes

(II.) By way of derogation from point I, if the visual advertisement, technical promotional

material or paper-based distance selling is printed in monochrome, points I.(b) and I.(c) are

replaced by the following:

(b) the class arrow shall have a border, and the internal background shall be

uncoloured, matching the colour of the background support;

(c) the typeface of the ‘class letter’ shall be Noto Sans bold, 100 % black, and in a

size equivalent to that of the price, if the price is displayed.

2. Online material

EN 5 EN

(III.) For the purposes of ensuring conformity with the requirements laid down in Articles

4(3), 4(4) and 6(2), in visual advertisements, in product catalogues and in technical

promotional material, in distance selling and telemarketing on the internet, both for products

and for packages, the rolling resistance class and the range of classes available on the label,

the wet grip class and the range of classes available on the label and the external rolling noise

class and value shall be displayed as indicated in Figure 1, in accordance with the following

additional specifications:

(a) the class-arrow images shall be each the nested display of the label set out in

Annex III and as available from the product database;

(b) the label shall be displayed by pop up, new tab, new page or inset screen

display and must appear on the first mouse click or mouse-over on the class

arrow image;

(c) for magnification of the label on tactile screens, the device conventions for

tactile magnification shall apply;

(d) the label shall cease to be displayed by means of a close option or other

standard closing mechanism;

(e) the alternative text for the class arrow image, appearing with a mouse-over,

shall be respectively “fuel-efficiency class is”, “wet grip class is”, “external

rolling noise class is”, followed by the class letter and the text “(range A-x)”,

where “x” is the worst permitted class.

(f) a text indicating ‘Product Information Sheet’, in proximity to the class arrow,

shall give direct access to the product-information sheet, as available from the

product database, or to the model page in the product database.’.

EN 6 EN

ANNEX III

Annex VII to Regulation (EU) 2020/740 is amended as follows:

(1) the title is replaced by the following:

‘INFORMATION TO BE ENTERED IN THE COMPLIANCE PART OF THE

PRODUCT DATABASE BY THE SUPPLIER’;

(2) point 1 is deleted.

(3) point 2 is replaced by the following:

‘2. Information to be entered into the compliance part of the product database:

(a) the tyre type identifier of equivalent tyre types placed on the market;

(b) the parameters of the product information sheet set in Annex III table III A that

are part of compliance assessment;

(c) copy of the type approval document relevant for the specific tyre type family;

(d) copy of test reports for any parameter in the label if the class corresponds to a

coefficient of rolling resistance, to an index of wet grip or to a noise emission

value more favourable than the one corresponding to the worst case as resulting

from the type-approval documentation in point (c). The test reports can be

those corresponding to the type approval or any other of equivalent level of

accuracy that justifies the declared values;

(e) alternatively to point (d), when the declared value does not correspond to a test

result, the supplier shall provide detailed description of how the value used to

determine the class was determined. Any simulation or extrapolation procedure

must ensure that the declared values are identical -or worse- to those obtained

in a physical test of the relevant tyre dimension;

(f) specific precautions, if any, that shall be taken when the tyre type is

maintained, mounted or tested.’.

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 [email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / Omnibus1 to simplify energy product legislation

Overall opinion: Not qualified

(A) Policy context The omnibus focuses on the labelling framework and foresees the amendment of 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 (Energy Labelling Regulation) and of 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 (Tyre Labelling Regulation).

(B) Key issues The Board notes the need for improvements to the quality of the report and makes the following recommendations for the lead Service to rectify: (1) The report’s analysis of non-compliance requires further development. (2) The report does not clearly differentiate the two policy options and does not

adequately assess the social impact.

(C) What to improve (1) The report should improve explanations regarding non-compliance with labelling

obligations (Problem 2), including when providing estimates on the share of non- compliance for tyres and energy labelling. The report should more effectively support its assessment by drawing on the data from the implementation reports for the Energy Labelling Regulation and the Tyre Labelling Regulation. The report should improve

1 This initiative is an omnibus on which, following the President decision P(2026)1 of 28.4.2026, the Board shall issue an opinion that is not qualified.

2

the description of the import market for the products in scope and explain better the issue of level playing field for suppliers.

(2) The report should more clearly take into account data gaps when assessing economic impacts (e.g. for M10). The report should enhance its analysis of social impacts, in particular on consumer behaviour. Regarding M3, the report should explain how it will be ensured that electronic labels are fully legible and enable informed choice. The report should also be clear about the obligations for consumer testing. Regarding M4 and M5, the report should describe what the changes will be in terms of overlaps of products at the point of sale with reviewed and non-reviewed labels and analyse the potential consequences for consumers’ ability to make informed choices.

(3) The report should more clearly present the two policy options as distinct scenarios, given that the bulk of the proposal is identical. The comparative analysis of impacts should be further developed and the comparison of the effectiveness of the two policy options should be better explained, in particular with regards to entry into force. Assumptions should be systematically described: the costs and benefits for M14 and M15 are not sufficiently explained which weakens the comparison between the two options. The report should outline the total figures and expected cost savings, including in terms of monetised administrative savings.

(D) Conclusion The lead Service should revise the report and the executive summary in accordance with the Board’s recommendations before launching the interservice consultation.

Full title Omnibus to simplify energy product legislation

Reference number PLAN/2025/2742

Submitted to RSB on 29 April 2026

Date of RSB meeting 20 May 2026

Electronically signed on 22/05/2026 12:04 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

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. INTRODUCTION: POLITICAL AND LEGAL CONTEXT ....................................................................... 6

2. 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

8. PREFERRED OPTION .............................................................................................................................. 44

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

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

3

Glossary

AdCo Administrative Cooperation Group (for Eco-Design and Energy Labelling

or Tyre Labelling as indicated)

AI Artificial Intelligence

API Application Programming Interface

APPLiA Home Appliance Europe (industry association)

B2B Business-to-Business

BEUC 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 European Committee of Manufacturers of Electrical Machines and Power

Electronics

CfE Call for Evidence

CFL Compact Fluorescent Lamp

CLASP Collaborative Labelling and Appliance Standards Program

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

DIY Do It Yourself

DoC Declaration of conformity

DPP Digital Product Passport

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

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

Improvement Network (GHIN)

EEB European Environmental Bureau

EED Energy Efficiency Directive

EEI Energy Efficiency Index

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

EHI European Heating Industry (association)

EHPA European Heat Pump Association

4

e-IDAS electronic Identification, Authentication and trust Services (EU Regulation)

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

ENEA Italian National Agency for New Technologies, Energy and Sustainable

Economic Development

EPBD Energy Performance of Buildings Directive

EPEE European Partnership for Energy and the Environment

EPREL European Product Registry for Energy Labelling

ESPR Ecodesign for Sustainable Products Regulation (Regulation (EU)

2024/1781)

ETRMA European Tyre and Rubber Manufacturers' Association (now TyresEurope)

EU27 The 27 Member States of the European Union

EEA European Economic Area

F-Gas Fluorinated Greenhouse Gas

GCP Europe European Association of Installers / Heating, Cooling and Plumbing

contractors

GHG Greenhouse Gas

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

GTIN Global Trade Item Number

HVAC Heating, Ventilation and Air Conditioning

IA Impact Assessment

IEA International Energy Agency

IEA 4E International Energy Agency – Energy Efficient End-use Equipment

(Technology Collaboration Programme)

ICSMS Information and Communication System for Market Surveillance

ITI Information Technology Industry Council

JRC Joint Research Centre (European Commission)

kW Kilowatt

LED Light-Emitting Diode

MS Member State(s)

MSA Market Surveillance Authority / Authorities

5

NACE Nomenclature statistique des activités économiques dans la Communauté

européenne (Statistical Classification of Economic Activities in the EU)

NLF New Legislative Framework

OEM Original Equipment Manufacturer

PFAS Per- and Polyfluoroalkyl Substances

PIS Product Information Sheet

PV Photo Voltaic

QR code Quick Response code

RED Renewable Energy Directive

RSB Regulatory Scrutiny Board

RVO Rijksdienst voor Ondernemend Nederland (Netherlands Enterprise Agency)

SBS Structural Business Statistics (Eurostat)

SDG Sustainable Development Goal

SME Small and Medium-sized Enterprise

SWD Staff Working Document

TFEU Treaty on the Functioning of the European Union

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

TSO Transmission System Operator

TWh Terawatt-hour

UN ECE United Nations Economic Commission for Europe

ZVEI Zentralverband Elektrotechnik- und Elektronikindustrie (German Electrical

and Electronic Manufacturers' Association)

6

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.

7

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.

8

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.

9

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, airconditioners (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.

10

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.

11

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.

12

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

13

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.

14

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.

15

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.

16

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.

17

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;

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

• AI-supported checks; and

• joint enforcement activities between MSAs and operators.

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.

18

installer obligations specifically as part of the training activities under the ongoing EU-funded

project Compliance Services.46 The Irish MSA recommended clarifying 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.

19

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.

20

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.

21

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

Dominant sales channel: manufacturer→ wholesaler →

installer: ~65–75% 59 Low single digit shares for direct

brand sale and very low for online sale.

Large domestic appliances

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.

22

Washing machines

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.

Ovens & cooking appliances

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.

Electronics and other

Smartphones

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.

Light sources 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 for residential lamps and decorative

luminaires). Online sales are higher than for other energy-

related products and rapidly rising.

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.

23

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.

24

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

Thegeneral objectiveis 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.

25

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.

26

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 Option 1 Option 2

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.

x x

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

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.

x x

27

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.

x x

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.

x x

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.

x x

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

x x

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.

x x

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.

x x

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.

x x

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.

x x

M12Obligation to upload actual test reportsfor 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.

x x

28

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.

x

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.

x

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

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)

29

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.

30

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.

31

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.

32

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

33

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.

34

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 .

35

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.

36

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.

37

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 Up to 83 for

supplier ELR

7 for retailers

M2 - - - -

M3 - - - -

M4 2 for suppliers

ELR

- -

M5 - 3 for retailers - -

M6 - 3 for MSAs 10 for authorised

representatives

-

M7 Up to 2 for online

marketplaces

M8 Up to 66 for

suppliers

Yes

M9 Yes Yes

M 10 - - - -

M11 - - - -

M 12 - 0.7 for MSAs 6 for tyre suppliers

who need to

demonstrate better

performance

-

M15 40 for car

manufacturers

and dealers

TOTAL Up to 66 Up to 131.7

including public

authorites (up to

16 Up to 9

38

128 only

companies)

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

39

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

40

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.

41

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.

42

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

#

One-off

savings

(EURm)

Recurrent savings

(EURm,

annually)

One-off

costs

(EURm)

Recurrent costs

(EURm,

annually)

M13 - - 9.5 for tyre

suppliers Yes

M14 - - - -

Total administrative costs and savings under option 2:

One-off

savings

(EURm)

Recurrent

savings

(EURm,

annually)

One-off

costs

(EURm)

Recurrent costs

(EURm,

annually)

TOTAL Up to 66

Up to 131,7

including public

authorities

(Up to 128 only

companies)

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.

43

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.

44

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

45

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.

46

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.

47

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.

48

49

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.

50

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.

51

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

• Independent Retail Europe

• Independent market surveillance expert (DK)

• Lighting Europe

52

• 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.

53

• 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:

54

• 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).

55

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)

56

· 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

57

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

58

• 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

59

• 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

60

• 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.

61

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

62

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

63

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:

64

APPLiA

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.

BE 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

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.

On tyres, DE supports wider empowerment for 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

DK 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.

65

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).

EHPA 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) 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.

NL (RVO) 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.

ZVEI (German

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.

66

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

67

• 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.

68

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 Retail

Europe

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.

69

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.

70

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).

71

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.

72

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 Comments

Direct benefits

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.

More effective use of MSA

resources for compliance

checking

EUR 3.7 million annually For both ELR and TLR

Indirect benefits

Fairer competition among

retailers

Clarification of intermediary

responsibilities

More compliance and in a

second step more energy

savings

EPREL database

information more useful

II. Overview of costs – Preferred option

Citizens/Consumers Businesses Administrations

One-off Recurrent One-off Recurrent One-off Recurrent

Action (a)

Direct adjustment

costs -

Adjusting to

product-specific

delivery mode

for label

Direct

administrative

costs

EUR 15.5

million tyre

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 - - - - - -

73

Indirect costs - - - - - -

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

[M€]

One-off

(annualised total net present

value over 10 years)

Recurrent

(nominal values per year)

Total

Businesses

New administrative burdens

(INs)

2.99 9 11.99

Removed administrative burdens

(OUTs)

7.74 UP TO 128 135,74

Net administrative burdens* -4.75 UP TO -119 -123.75

Adjustment costs**- -

Public authorities

Removed administrative

burdens (OUTs) 3.7 3.7

Citizens

New administrative burdens

(INs)

- - -

Removed administrative burdens

(OUTs)

- - -

Net administrative burdens* - - -

Adjustment costs**- - -

Total administrative burdens*** -4.75 -122.7 -127.45

(*) 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 Increased compliance through 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

SDG no 8 - Promote

sustained, inclusive and

sustainable economic

growth, full and

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.

74

productive employment

and decent work for all

SDG no. 13 – Climate

action Expected increase in energy savings with more compliance

75

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.)

References to sub-sections of the

main report or annexes

Cost and price

competitiveness +

Reduction of compliance costs for

retailers and suppliers

International

competitiveness +

Authorised representatives’

clarifications improve situation for

EU based suppliers and retailers.

Additional action for more

compliance under tyre label is

expected to affect more low-cost

brand imports than EU based

manufacturers.

All provisions apply equally to EU

based and outside EU enterprises.

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 into stock

management systems.

76

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.

77

(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.

78

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.

79

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

target for SMEs?

The share of SMEs in the overall identified savings

80

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

electronic product

information sheet

available to dealers

for each model.

entered into EPREL.

Nested label in

proximity to price.

Telemarketing: must

inform customer of

energy class, range, and

how to access the full

label or request a printed

copy.

2 EU

2019/2016

Household

refrigerating

appliances

(fridges,

freezers, wine

coolers)

Printed label for each

unit

electronic label and

electronic product

information sheet

available to dealers

for each model.

entered into EPREL.

Nested label in

proximity to price

Telemarketing: must

inform customer of

energy class, range, and

that full label 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

Refrigerating

appliances

with a direct

sales function

(display

cabinets,

vending

machines,

beverage

coolers)

Printed label for each

unit

electronic label and

electronic product

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 the display

mechanism and inform

the dealer of the

obligation.

4 EU

2019/2014

Household

washing

machines &

Printed label for each

unit

electronic label and

electronic product

Nested label display in

proximity to price .

Internet hosting

platforms must ensure

81

washer-

dryers

information sheet

available to dealers

for each model.

Entered into EPREL.

electronic label and

product information

sheet are clearly

displayed according to

Annex VIII.

5 EU

2019/2013

Electronic

displays

(TVs,

monitors,

digital

signage)

Printed label for each

unit and in addition

label printed on the

packaging or stuck

on it

electronic label and

electronic product

information sheet

available to dealers

for each model.

entered into EPREL.

Hosting platforms must

enable the showing of

the electronic label and

electronic product

information sheet on the

display mechanism and

inform the dealer of the

obligation.

6 EU

2019/2015

Light sources

(LED,

fluorescent,

etc.) incl.

those in

containing

products

label printed on or

affixed to the outer

packaging

electronic label and

electronic product

information sheet

available to dealers

for each model.

entered into EPREL.

Telemarketing: must

inform customer of

energy class, range, and

that full label and

product information

sheet are accessible via

free-access website or

printed copy on request.

7 EU

2023/2534

Household

tumble dryers

Printed label for each

unit

electronic label and

electronic product

information sheet

available to dealers

for each model.

entered into EPREL.

Electronic label and

product information

sheet displayed in online

display mechanism

(nested label).

Telemarketing must

communicate energy

class and range.

8 EU

2023/1669

Smartphones

& slate

tablets

Printed label for each

unit

electronic label and

electronic product

information sheet

available to dealers

for each model.

entered into EPREL.

Providers of online

platforms must enable

traders to provide

labelling information

(energy label and

product information

sheet) in compliance

with Article 31(2) of the

Digital Services Act (EU

2022/2065). Visual

advertisements must

82

show the energy class

and range.

9 EU

626/2011 (in

force;

originally

under

2010/30/EU)

Air

conditioners

≤12 kW

(single-split,

multi-split,

single duct,

double duct)

Printed label for each

unit

Supplier makes

electronic label

available to dealers.

Electronic product

fiche on free-access

websites.

No full label to be

provided in cases where

end-users cannot be

expected to see the

product displayed (only

energy class and key

parameters)

10 EU

811/2013 (in

force;

originally

under

2010/30/EU)

Space

heaters,

combination

heaters, and

packages

(heater +

temperature

control +

solar device)

Printed label for each

unit.

Supplier makes

electronic label

available to dealers.

Electronic product

fiche on free-access

websites.

No full label to be

provided in cases where

end-users cannot be

expected to see the

product displayed (only

energy class and key

parameters)

11 EU

812/2013 (in

force;

originally

under

2010/30/EU)

Water

heaters, hot

water storage

tanks, and

packages

(water heater

+ solar

device)

Printed label for each

unit

Supplier makes

electronic label

available to dealers.

Electronic product

fiche on free-access

websites.

No full label to be

provided in cases where

end-users cannot be

expected to see the

product displayed (only

energy class and key

parameters)

12 EU 65/2014

(in force;

originally

under

2010/30/EU)

Domestic

ovens and

range hoods

Printed label for each

unit

Supplier makes

electronic label

available to dealers.

Electronic product

fiche on free-access

websites.

No full label to be

provided in cases where

end-users cannot be

expected to see the

product displayed (only

energy class and key

parameters)

13 EU

1254/2014

(in force;

originally

under

2010/30/EU)

Residential

ventilation

units

Printed label for each

unit.

Supplier makes

electronic label

available to dealers.

Electronic product

fiche on free-access

websites.

No full label to be

provided in cases where

end-users cannot be

expected to see the

product displayed (only

energy class and key

parameters)

14 EU

2015/1186

(in force;