EU energy label and EPREL registration: what non-EU manufacturers must do
Energy-labelled products sold in the EU must be registered in EPREL, the European Product Registry for Energy Labelling, before the first unit of a model is placed on the market. The supplier, meaning the EU manufacturer, the importer or an authorised representative, registers the model, supplies the A-G label and product information sheet with each unit and keeps the compliance data for 15 years. A manufacturer outside the EU is not the supplier but must make sure these duties are met.
Checked against official sources: 2026-10
At a glance
Who is the supplier
Under EU energy labelling, the supplier is the manufacturer established in the EU, the importer that brings a product from a third country onto the EU market, or an authorised representative established in the EU acting under a written mandate. For a non-EU manufacturer with no importer, the mandate must cover all supplier tasks, and the representative must show it to market surveillance authorities on request.
A manufacturer outside the EU is not itself a supplier, but it must ensure, through its representative or importer, that the technical documentation, the labels in product boxes, the database data and any corrective action are in place. Products offered online count as made available on the EU market if the offer targets EU end users.
Supplier obligations
- Register each new model in the public and compliance parts of EPREL before placing it on the EU market.
- Supply each unit with an accurate printed label and product information sheet, free of charge.
- Deliver labels and sheets to dealers free of charge within five working days of a request.
- Prepare technical documentation that allows the accuracy of the label to be checked.
- Show the efficiency class and the available range in visual advertising and technical promotional material.
- Mark in EPREL when units are no longer placed on the market, and keep the model's compliance information for 15 years.
- Get the customer's explicit consent before a software update that would worsen the label parameters.
The A-G label and QR code
Since 2021, the A+++ to D labels have been replaced step by step by an A-G scale, first for six product groups in March 2021; old and new classes cannot be compared directly. The label shows the efficiency class, energy consumption and other parameters such as noise, water consumption, capacity, repairability or reliability class, plus a QR code that leads to the model's EPREL record. EPREL had more than 1.5 million registered models by spring 2023.
Step by step
- Check whether your product belongs to a product group with an EU energy label.
- Agree who will be the supplier: your EU importer or an authorised representative with a written mandate covering all supplier tasks.
- Test the model and prepare the technical documentation.
- Register the model in EPREL before the first unit is placed on the EU market, and generate the label with its QR code.
- Pack the printed label and product information sheet with each unit, and give dealers and online platforms the electronic versions.
Documents you usually need
- EPREL registration for each model
- Energy label (A-G) with QR code
- Product information sheet
- Technical documentation
- Written mandate for the authorised representative, if used
Common problems and how to avoid them
What to do: The EU importer or an authorised representative must register each model before it is placed on the market.
What to do: Suppliers must send labels and information sheets free of charge within five working days.
What to do: Visual advertising and technical promotional material must show the efficiency class and the available range.
What to do: Keep the model's information in the compliance part of EPREL for 15 years.
Sources
- Who does what under Energy Labelling? European Commission
- What is EPREL? European Commission
- Understanding the Energy Label European Commission
Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.
Trade notes
Common questions
What is EPREL?
The European Product Registry for Energy Labelling, where suppliers must register each energy-labelled model before placing it on the EU market, required since 1 January 2019.
Can a manufacturer outside the EU register in EPREL?
The supplier is the EU manufacturer, the importer or an authorised representative; a non-EU manufacturer acts through its representative or importer.
When must a model be registered?
Before the first unit of the model is placed on the EU market.
What does the QR code on the label do?
It leads to the model's record in EPREL; EPREL never asks for personal data or payment.
How long must the data be kept?
The model's information stays in the compliance part of the database for 15 years.
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