Erion and the Belt project: support to market actors during the transition period towards the introduction of the new energy label

In accordance with the provisions of the Framework Regulation (EU) 2017/1369 and the related delegated acts, starting from March 1st, 2021 some products such as dishwashers, washing machines, washer-dryers, refrigerators and electronic displays will be exhibit and sold in physical and online stores with a new energy label. Light sources are an exception: although these are also subject to the change of labelling system, it will be necessary to wait until September 1st, 2021 to see the new labels in the stores (the following indications therefore do not concern with this product category).

To allow producers, distributors and consumers to prepare for change, the European Union has provided a transition period during which it will be possible to find products on sale that contain both labels in the packaging, the current and the new rescaled one. This transition period corresponds to the four months preceding the date of March 1st, 2021: it therefore began on November 1st,2020.

What are the responsibilities of producers and distributors during this period?

First of all, it is necessary to clarify that distributors are not authorized either to exhibit the new label or to sell products with only the rescaled label before March 1st, 2021. Already now, distributors can sell products with both labels (of which only the new one is visible in the stores).

Let's take an example: if today a consumer purchases online and the product is delivered directly to her home, there is the possibility that she will receive a package containing both labels, the old and the new one. The consumer will see the new label even before it is exposed next to the product in the store (March 1st, 2021).

Distributors can also, for products placed on the market before November 1st, 2020 and which will be placed on the market after this date as well, require manufacturers to provide the new rescaled label for products that only have the old one.

What does this mean for appliance manufacturers? Producers are required to respond to any requests from distributors, then to provide the rescaled label for those products already on the market before November 2020. For products placed on the market starting from November 1st, 2020, the manufacturers must provide both the labels if they wants the product to be sold before March 1st, 2021, or just the new label if the product will be sold from March 1st, 2021.

In addition, from November 1st, 2020 (the date is postponed to May 1st, 2021 for lamps), manufacturers of dishwashers, washing machines, washer dryers, refrigerators and electronic displays are required to register their products on the European Product Database for Energy Labelling. (EPREL), by re-registering for products already placed on the market before November 1st, 2020 or re-registering for new models.