Regulation (EU) 2017/1369
For appliance and electronics brands in the EU working out where the energy label appears, including ads and online shops. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
The EU energy label regulation, Regulation (EU) 2017/1369, sets the framework for the energy label: the A to G label and product information sheet for energy-related products, how they appear in shops, online and in ads, and a product database.1
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the requirements the EU energy label regulation describes for labels, information sheets and ads, according to its text, and who each one is placed on.1
| Requirement | Where it applies |
|---|---|
| Printed label and product information sheet | Suppliers: supplied with each unit, free of charge; delegated acts may put the label on the packaging. |
| Labels requested by dealers | Suppliers: delivered within five working days of a request, rescaled labels included. |
| Label at the point of sale | Dealers: displayed in a visible manner, including for online distance selling. |
| Product information sheet for customers | Dealers: made available, in physical form at the point of sale on request. |
| Energy class in advertising | Suppliers and dealers: visual advertisements and technical promotional material for a model refer to its class and the range of classes on the label. |
| Product database registration | Suppliers: model information entered before units of a new model go on the market, from January 1, 2019. |
| Other labels, marks and symbols | Suppliers and dealers: none likely to mislead or confuse customers about energy use, and no labels that mimic the energy label. |
| Rescaled labels | Dealers: old labels replaced in shops and online within 14 working days of the rescaling date. |
Where it goes wrong
One approved set of product information ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up without the warnings or details these rules require.
WM-8 washing machine: energy class B, A to G label
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
In more places than the box. The EU energy label regulation describes the label going with each unit and being displayed in shops and in online distance selling, and the energy class appearing in visual ads and technical promotional material,1 which for most brands means:
Treat the label and its class as approved product data with one source, not as images copied into each channel. The text gives dealers 14 working days to swap old labels in shops and online after a rescaling date,1 and we usually find the old images surviving in retailer feeds and archived campaign assets. Our packaging and labels page shows how teams track this.
Check that every ad for a specific model shows its energy class and the range of classes on its label, the two things the regulation describes for visual advertisements.1 Banners, social cuts and retail media are where the class tends to get dropped, because the layout has no room for it.
How it applies to a specific ad is a question for your legal adviser. Where that ad appears across your markets and languages is a question Arbitr answers.
Product compliance teams usually own the database registration, but the label itself is published by your packaging, e-commerce, marketing and retail teams, and by dealers working from your feeds. Each needs the current label and class for every model. Other product information rules are on our product labeling hub, and the UK marking rules on our UKCA marking page.
On August 1, 2017, according to the text of Regulation (EU) 2017/1369, which repealed the earlier energy label directive, Directive 2010/30/EU, from the same date. Its product database obligations for suppliers apply from January 1, 2019.1
For the first product groups, from March 1, 2021. The European Commission said the new A to G scale applied from that date to fridges, washing machines, dishwashers and televisions, with labels for light sources such as bulbs rescaled from September 1, 2021.2
It's the "European Product Registry for Energy Labelling", the Commission's name for the product database the regulation sets up.2 According to the text, it has a public part for customers and a compliance part for market surveillance authorities, and suppliers enter each new model before it goes on sale.1
Most companies do, and it works for the file it reviews, in the language it reviews, before a campaign ships. It doesn't cover what's published afterwards: the market versions, the agency reworks, the sales deck built from the campaign six months later. That's a volume problem, not a failure of your legal team.
