EPREL: who registers a product model, the QR code, and what sellers must show

The Energy Labelling Regulation, Regulation (EU) 2017/1369Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office., sets the framework for energy labels. It tells the Commission to keep a product database, which is EPREL, the European Product Registry for Energy Labelling (Art. 12(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 1Click opens the article on EUR-Lex.), and it tells each supplier to enter its models in it (Art. 4(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 4, paragraph 1Click opens the article on EUR-Lex.). EPREL has a public part, which anyone can search, and a compliance part that only the market surveillance authorities and the Commission can see (Art. 12(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 3Click opens the article on EUR-Lex., Art. 12(4)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 4Click opens the article on EUR-Lex.).

EPREL registration is mandatory for the supplier of each energy-labelled model and for nobody else

The Regulation puts the registration duty on the supplier alone: before placing on the market a unit of a new model covered by a delegated act, the supplier enters the information of Annex I in the public and the compliance parts of the database (Art. 4(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 4, paragraph 1Click opens the article on EUR-Lex.). The Commission says the same: suppliers must register any model before they start placing products of that model on the Union market (Commission, What is EPREL?). A dealer has no registration duty. A consumer has none.

A business that has a product made by someone else and sells it under its own name or trademark is the manufacturer, and carries the supplier duties (Art. 2(10)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 10Click opens the article on EUR-Lex.). That is the position of a private-label seller.

Only a supplier established in the EU can register

The definition of supplier is built on establishment: a manufacturer established in the EU, the authorised representative of a manufacturer who is not established in the EU, or an importer (Art. 2(14)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 14Click opens the article on EUR-Lex.). An authorised representative is a person established in the EU who has a written mandate from the manufacturer for specified tasks (Art. 2(11)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 11Click opens the article on EUR-Lex.). An importer is a person established in the EU who places a product from a third country on the EU market (Art. 2(12)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 12Click opens the article on EUR-Lex.). The EPREL Regulation repeats it: suppliers must be based in the EU, and proof of establishment is part of verification (Art. 4(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 4, paragraph 1Click opens the article on EUR-Lex., recital 3 of Regulation (EU) 2024/994).

A manufacturer outside the EU therefore reaches EPREL in one of two ways: it appoints an authorised representative in the EU by written mandate, or it sells to an importer in the EU who places the product on the market. This mandate is a different one from the GPSR authorised representative; the roles are separated in EU authorised representative.

A seller outside the EU with none of these three in the EU has no way to register, and the product may not be placed on the EU market without one. Under the Market Surveillance Regulation a product subject to the laws on its list may be placed on the market only if an economic operator based in the EU is responsible for the tasks the Regulation sets (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). Directive 2009/125/EC, the Ecodesign Directive, is on that list, and most energy-labelled products are also subject to ecodesign requirements. An EU fulfilment service provider counts as that operator where no manufacturer, importer or authorised representative is established in the EU (Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex., point (d)), but it is not a supplier under the Energy Labelling Regulation and cannot register a model. Tyres are not on that list, but the tyre Regulation defines the supplier in the same way: a manufacturer established in the EU, an authorised representative established in the EU, or an importer (Art. 3(15)Regulation (EU) 2020/740, labelling of tyres with respect to fuel efficiency and other essential parametersArticle 3, point 15Click opens the article on EUR-Lex.).

A supplier becomes verified before it can register any model

Verification is a precondition. Suppliers of products under the Regulation must be verified suppliers, and only a verified supplier may register a model or change an existing one (Art. 3(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 3, paragraph 1Click opens the article on EUR-Lex., Art. 3(2)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 3, paragraph 2Click opens the article on EUR-Lex.). The steps differ for a company and for a person.

• A company submits a qualified electronic seal, supported by a qualified certificate for electronic seal from a qualified trust service provider. The certificate carries the company name exactly as in the business register and an identifier that starts with NTR, the country code and the register number (Art. 4(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(2)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 4, paragraph 2Click opens the article on EUR-Lex., Art. 4(3)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 4, paragraph 3Click opens the article on EUR-Lex.). The electronic signature of the company’s representative is not accepted, because it does not prove that the company is established in the EU (Art. 4(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 4, paragraph 1Click opens the article on EUR-Lex.).
• A natural person submits a qualified electronic signature, which proves identity. The signature does not prove establishment in the EU (recital 6 of Regulation (EU) 2024/994), so the person proves that with its business or trade register number, in a document signed or sealed by the competent register authority. Only where that is impossible does a qualified trust service provider seal the document and confirm that it is true. A person acting as authorised representative also submits the manufacturer’s written mandate, listing every brand the mandate covers (Art. 5(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 5, paragraph 1Click opens the article on EUR-Lex., Art. 5(3)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 5, paragraph 3Click opens the article on EUR-Lex.).

The dates that matter, from the Commission’s suppliers page and the Regulation: verification became mandatory on 22 October 2024 (Art. 20Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 20Click opens the article on EUR-Lex.); from 22 April 2025 a new company seal must carry the NTR identifier; and a company verified before that date with a seal of another identifier type (VAT, LEI, PSD or a national scheme) renews with an NTR seal by 22 April 2027 (Art. 6(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 6, paragraph 1Click opens the article on EUR-Lex., Art. 6(2)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 6, paragraph 2Click opens the article on EUR-Lex., Commission, Suppliers).

The Commission’s suppliers page lists qualified trust service providers that confirmed they issue seals in the form EPREL needs; it says any qualified provider can do it in principle.

A verified supplier that is inactive for over one year and does not answer a double email alert loses the status of verified, and the system sets the end of placing on the market of its models (Art. 11(8)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 11, paragraph 8Click opens the article on EUR-Lex., Art. 11(9)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 11, paragraph 9Click opens the article on EUR-Lex.). A model can be transferred to another verified supplier that takes over the duties for it (Art. 9Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 9Click opens the article on EUR-Lex.).

Which products need an energy label and so an EPREL entry

The Regulation covers energy-related products, meaning goods or systems with an impact on energy consumption during use, and applies a label only to the product groups that a delegated act covers (Art. 1(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 1, paragraph 1Click opens the article on EUR-Lex., Art. 2(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 1Click opens the article on EUR-Lex., Art. 16(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 16, paragraph 3Click opens the article on EUR-Lex.). The EU energy label guide covers the A to G scale and how to show the label in a listing. The EPREL home page, read on 5 October 2026, lists these groups (EPREL):

• household dishwashers, washing machines, washer-dryers and tumble dryers;
• household, hotel and wine refrigerators, and fridge-freezers and minibars;
• commercial refrigerators and professional refrigerated storage cabinets;
• tyres for passenger cars, vans, trucks and buses;
• light sources;
• smartphones and tablets;
• electronic displays, meaning televisions, monitors, signage and professional displays;
• air conditioners, domestic ovens, range hoods and local space heaters;
• residential ventilation units;
• space heaters and combination heaters, water heaters and solid fuel boilers, with their packages, temperature controls, solar devices and hot water storage tanks.

The Regulation does not apply to second-hand products unless they are imported from a third country, or to means of transport for persons or goods (Art. 1(2)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 1, paragraph 2Click opens the article on EUR-Lex.). Tyres are in EPREL under their own Regulation, which requires the supplier to enter the tyre data before placing a tyre on the market (Art. 5(1)Regulation (EU) 2020/740, labelling of tyres with respect to fuel efficiency and other essential parametersArticle 5, paragraph 1Click opens the article on EUR-Lex.). The label for smartphones and slate tablets applies from 20 June 2025 (Delegated Regulation (EU) 2023/1669Delegated Regulation (EU) 2023/1669, energy labelling of smartphones and slate tablets (consolidated text of 10 May 2026)The whole regulationClick opens the law on the EU Publications Office., its article on entry into force and application).

Products on the Commission’s list with ecodesign requirements only, such as hobs, vacuum cleaners, computers, external power supplies, servers and welding equipment, carry no energy label and are not in the EPREL list of groups (Commission product list). The list of groups grows when the Commission adopts a new delegated act, so the product list is where a new group appears first.

A product is placed on the market at the first making available in the EU (Art. 2(8)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 8Click opens the article on EUR-Lex.). The Commission’s suppliers page gives examples of what is not placing on the market: a product produced and exported straight to a market outside the EU, one still in testing, one in transit or in a customs warehouse or free zone, and one made for the maker’s own use (Commission, Suppliers).

What goes into EPREL: the label data, the information sheet and the technical documentation

The database has three kinds of content (Art. 12(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 3Click opens the article on EUR-Lex., Art. 12(4)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 4Click opens the article on EUR-Lex., Annex I):

• The public part, entered by the supplier. The name or trademark, address, contact details and other legal identification of the supplier; the model identifier; the label in electronic form; the energy efficiency class and the other parameters of the label; and the parameters of the product information sheet in electronic form.
• The compliance part, entered by the supplier. The model identifiers of all equivalent models already on the market and the technical documentation: a general description of the model, the harmonised or other standards applied, precautions for assembly, installation, maintenance or testing, the measured technical parameters, the calculations made from them, and the testing conditions (Art. 12(5)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 5Click opens the article on EUR-Lex.). Only the market surveillance authorities and the Commission see this part (Art. 12(4)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 12, paragraph 4Click opens the article on EUR-Lex.).
• The portal, kept by the Commission. The contact details of the national authorities, the working plan, the minutes of the Consultation Forum and the inventory of delegated and implementing acts.

Three more rules shape the entry.

• A registration counts as complete only when every parameter value and document that the Regulations require for the product is entered, and the date of placing the first unit on the market is set. EPREL confirms the completeness (Art. 13(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 13, paragraph 1Click opens the article on EUR-Lex., Art. 13(2)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 13, paragraph 2Click opens the article on EUR-Lex.).
• The supplier names two contact points: a public one with a generic email address, and a compliance one for the market surveillance authorities, with a telephone number, a physical address in the EU and a generic email address (Art. 8Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 8Click opens the article on EUR-Lex.).
• The supplier registers either on the EPREL compliance website or by uploading data in the Commission’s data exchange model, which suits a seller with many models (Art. 15(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 15, paragraph 1Click opens the article on EUR-Lex.). The acceptance system is a copy where a supplier can try a dummy supplier and dummy models (Art. 2Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 2Click opens the article on EUR-Lex., point (20)).

A product with a change that is relevant to the label or the sheet is a new model (Art. 4(4)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 4, paragraph 4Click opens the article on EUR-Lex.). The supplier keeps the data of a model in the compliance part for 15 years after the last unit is placed on the market, unless the delegated act sets a shorter period (Art. 4(6)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 4, paragraph 6Click opens the article on EUR-Lex.); the tyre Regulation sets five years (Art. 5(7)Regulation (EU) 2020/740, labelling of tyres with respect to fuel efficiency and other essential parametersArticle 5, paragraph 7Click opens the article on EUR-Lex.). The supplier may add the GTIN and the EU countries where it places the model, as voluntary entries (Art. 12(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 12, paragraph 1Click opens the article on EUR-Lex.). A model registered after a delegated regulation is reviewed is a new registration, because the rules and parameters differ (Commission, EPREL: generated labels).

The QR code on the label opens the model’s record in EPREL

The labels under the reviewed delegated regulations, read for this page for washing machines, electronic displays, light sources, smartphones and tablets, and for tyres in their own Regulation, all carry a QR code. Labels under older delegated acts carry none, for example for air conditioners, domestic ovens and range hoods; for those groups the QR code is on the EPREL product information sheet, which carries it for every product group (Commission, EPREL: generated labels). Delegated Regulation (EU) 2019/2014Delegated Regulation (EU) 2019/2014, energy labelling of household washing machines and washer-dryers (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office. defines it as a matrix barcode on the label that links to the model’s information in the public part of the database (Annex I, point (7)). EPREL makes the code from the brand and the model identifier, and the label once all the parameter values are in; until the date of placing on the market only the supplier sees the record, and from that date scanning the code returns the model’s EPREL address (Commission, EPREL: generated labels).

Three rules keep the code useful.

• The supplier gives the EPREL registration number to its dealers and distributors, so that they can show the label, or its class and range, in online selling, advertising and technical promotional material (Art. 14(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 14, paragraph 1Click opens the article on EUR-Lex.).
• The dealer or distributor keeps the QR code readable when the product is put on display for sale (Art. 14(2)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 14, paragraph 2Click opens the article on EUR-Lex.). The Commission points out that fixing a label with adhesive tape often makes the code unreadable, and tells suppliers to deliver labels as stickers where the product allows (Commission, Suppliers).
• For washing machines, and for smartphones and slate tablets, the user manual or other literature that comes with the product shows the link to the model in the database as a web address, as a QR code, or as the registration number (Annex V of Delegated Regulations (EU) 2019/2014 and (EU) 2023/1669).

Anyone can search EPREL by registration identifier or by GTIN on the public website. A model of a supplier that is not verified is not listed in search results and not exported through the API; when its QR code is scanned, a text says it was registered by an unverified supplier (Art. 7(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 7, paragraph 1Click opens the article on EUR-Lex., Art. 7(2)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 7, paragraph 2Click opens the article on EUR-Lex.).

An online seller shows the label and the information sheet next to the price

The dealer carries the display duty. The Regulation says the dealer displays the label the supplier provided, in a visible manner and including in online distance selling, and makes the product information sheet available to customers (Art. 5(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 5, paragraph 1Click opens the article on EUR-Lex.). Distance selling includes the internet (Art. 2(15)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 2, point 15Click opens the article on EUR-Lex.). The layout is set by the delegated regulation of each product group (Art. 16(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 16, paragraph 3Click opens the article on EUR-Lex., point (g)). For household washing machines and washer-dryers, as the worked example (Art. 4Delegated Regulation (EU) 2019/2014, energy labelling of household washing machines and washer-dryers (consolidated text of 1 May 2021)Article 4Click opens the article on EUR-Lex., Annex VIII):

• the label appears on the display mechanism in proximity to the price, clearly visible and legible;
• or a nested display is used: an arrow in the colour of the energy class, with the class letter in the font size of the price and the range of classes in black, that links to the label, which appears on a mouse click, a mouse roll-over or a tactile expansion, in a pop-up, a new tab, a new page or an inset;
• if the label fails to display, the alternative text gives the energy classes in the font size of the price;
• the product information sheet appears in proximity to the price too, by a nested display or by a link that is clearly and legibly labelled ‘Product information sheet’.

The Commission’s dealers page reads the duty widely: the label and sheet belong on every page of the web store that shows the product, including list pages and the basket, and whenever the product is shown, even when it cannot be added to the cart (Commission, Dealers). It also names the practical route: with the supplier’s EPREL registration number, an online store can fetch the label and the nested arrow from EPREL through an API. The dealer may also print the product information sheet from the database where that function exists (Art. 5(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 5, paragraph 3Click opens the article on EUR-Lex.).

Advertising has its own rule. A visual advertisement or technical promotional material for a specific model shows the energy efficiency class and the range of classes on the label, as the delegated regulation sets it (Art. 6Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 6Click opens the article on EUR-Lex., point (a)). A supplier, or a dealer, who shows other labels or marks that could mislead a customer about energy consumption breaks the Regulation too (Art. 6Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 6Click opens the article on EUR-Lex., point (c)).

If you buy a product to resell and your supplier did not give you a label, ask for one: the supplier delivers printed labels and sheets within five working days of a dealer’s request (Art. 3(2)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 3, paragraph 2Click opens the article on EUR-Lex., Art. 5(2)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 5, paragraph 2Click opens the article on EUR-Lex.).

A marketplace must let the label and sheet be shown and tell the seller to show them

The delegated regulations give the platform a duty of its own. Where a hosting service provider allows the direct selling of household washing machines or washer-dryers through its website, it must enable the display of the electronic label and the electronic product information sheet that the dealer provides, and inform the dealer of the obligation to display them (Art. 5Delegated Regulation (EU) 2019/2014, energy labelling of household washing machines and washer-dryers (consolidated text of 1 May 2021)Article 5Click opens the article on EUR-Lex.). The same duty appears for electronic displays (Article 5Delegated Regulation (EU) 2019/2013, energy labelling of electronic displays (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office. of Delegated Regulation (EU) 2019/2013Delegated Regulation (EU) 2019/2013, energy labelling of electronic displays (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office.), for light sources (Article 5Delegated Regulation (EU) 2019/2015, energy labelling of light sources (consolidated text of 30 September 2023)The whole regulationClick opens the law on the EU Publications Office. of Delegated Regulation (EU) 2019/2015Delegated Regulation (EU) 2019/2015, energy labelling of light sources (consolidated text of 30 September 2023)The whole regulationClick opens the law on the EU Publications Office.) and for tyres (Art. 8Regulation (EU) 2020/740, labelling of tyres with respect to fuel efficiency and other essential parametersArticle 8Click opens the article on EUR-Lex.).

The recital explains the split. The platform should be responsible for displaying the label the supplier provided in proximity to the price, but not for the accuracy or content of the label and the sheet. It should act expeditiously to remove or disable access to the offer if it becomes aware of a missing, incomplete or incorrect label or sheet, for example when a market surveillance authority informs it (recital 15 of Delegated Regulation (EU) 2019/2014). A recital is not a rule of its own. The binding force comes from the Digital Services Act: a hosting provider keeps its exemption from liability only if, once it knows of illegal content, it acts expeditiously to remove it or disable access (Art. 6(1)Regulation (EU) 2022/2065, Digital Services ActArticle 6, paragraph 1Click opens the article on EUR-Lex., point (b)). A supplier that sells straight to buyers on its own website is covered by the dealer duties (recital 15).

For a seller on a marketplace, this means:

• The label and the sheet are your duty as the dealer, and the platform’s listing screens are the place where you show them. The delegated regulations do not name a marketplace screen or field; the platform must make room for the electronic label and sheet in its display mechanism.

• Take the electronic label and the electronic sheet from your supplier, or from EPREL with the supplier’s registration number. The supplier answers for the accuracy of the label and the sheet it provides (Art. 3(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 3, paragraph 3Click opens the article on EUR-Lex.), and the dealer displays that label, or the one it obtained from the supplier or the database (Art. 5(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 5, paragraph 1Click opens the article on EUR-Lex., Art. 5(2)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 5, paragraph 2Click opens the article on EUR-Lex., Art. 5(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 5, paragraph 3Click opens the article on EUR-Lex.).

• If you are the supplier and also sell on the marketplace, you carry both sets of duties: the registration and the label, and the display in your own listing.

The smartphone and tablet regulation, as read, contains no article on hosting platforms; its dealer duty on distance selling applies as for any dealer (Delegated Regulation (EU) 2023/1669, Article 4(b)Delegated Regulation (EU) 2023/1669, energy labelling of smartphones and slate tablets (consolidated text of 10 May 2026)Article 4, point (b)Click opens the article on EUR-Lex.).

What happens when a product is not registered

The Regulation sets no fine. It makes four things follow.

• The supplier is in breach. A supplier must register the model before placing it on the market, supply the label with every unit and keep both accurate (Art. 3(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 3, paragraph 1Click opens the article on EUR-Lex., Art. 3(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 3, paragraph 3Click opens the article on EUR-Lex., Art. 4(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 4, paragraph 1Click opens the article on EUR-Lex.). EPREL is also where the correct label is made, from the data entered (Commission, EPREL: generated labels), so an unregistered model has no label from EPREL.
• The authorities can act on the supplier or the dealer. Where a market surveillance authority has sufficient reason to believe a product presents a risk to public interest protection, such as environmental and consumer protection, it evaluates the product; if the evaluation finds non-compliance, it requires the supplier, or where appropriate the dealer, to take corrective action, to withdraw the product or to recall it, and can provisionally prohibit or restrict its availability if that does not happen (Art. 9(1)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 9, paragraph 1Click opens the article on EUR-Lex., Art. 9(2)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 9, paragraph 2Click opens the article on EUR-Lex., Art. 9(5)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 9, paragraph 5Click opens the article on EUR-Lex.). The measures extend to all units of the model and of its equivalent models, except units the supplier shows to be compliant (Art. 10(5)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 10, paragraph 5Click opens the article on EUR-Lex.). The authority can recover the costs of document inspection and product testing from the supplier (Art. 8(5)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 8, paragraph 5Click opens the article on EUR-Lex.).
• Each EU country sets the penalties. They must be effective, proportionate and dissuasive (Art. 7(4)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 7, paragraph 4Click opens the article on EUR-Lex.). Germany sets a fine of up to EUR 50,000 for an administrative offence under its energy labelling act (§ 15(1) and (2) EnVKG), and its labelling ordinance lists, among the offences, a supplier who does not provide an electronic label or sheet and a dealer who does not display one (§ 8 Nos. 2 and 13 EnVKV).
• A dealer is exposed too. Dealers and suppliers must cooperate with the authorities and put right any non-compliance for which they are responsible (Art. 6Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)Article 6Click opens the article on EUR-Lex., point (b)). On tyres, the Commission says a distributor must not supply a tyre that is not registered in EPREL or does not bear its label (Commission, Dealers).

A model whose supplier is not verified stays in EPREL but is not shown in search, and its QR code leads to a text saying so (Art. 7(1)Implementing Regulation (EU) 2024/994, EPREL operational detailsArticle 7, paragraph 1Click opens the article on EUR-Lex.). A buyer, a competitor or an authority scanning the label sees that.

A pending proposal would change the printed label and the dealer display rules

This is a proposal, not law. The Commission proposed on 24 June 2026 to amend Regulation (EU) 2017/1369Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office. and the tyre Regulation (proposal COM(2026) 565). It would remove the default of a printed label with every unit, while dealers could still ask the supplier for one (proposed Article 3(1) and 3(2)). An authorised representative would have to upload a signed copy of its mandate to EPREL (proposed Article 4(3b)). A dealer would have to show the label on the product page, in search results and on the basket page, and the rule in Article 5(3)Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office. would be deleted (proposed Article 5(1)(b), Article 5(3)). Until it is adopted and published, the rules on this page apply as written (Proposal COM(2026) 565).

What the law leaves open

• Whether a fine applies to a missing registration alone. The Regulation leaves the penalties to the EU countries. The German ordinance read lists offences about labels and data sheets and does not list a registration duty. Meanwhile: treat the registration as the condition of the label, because the label comes out of the registration.

What you can skip