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The supplier (manufacturer, authorised representative or importer) that first places a regulated product on the Great Britain (England, Scotland and Wales) or Northern Ireland market, or puts it into service, is responsible for its compliance. This extends to any means of online selling, distance selling, hire and hire purchase.

The dealer (retailer) also has obligations and is required to clearly display an energy label when selling products. This includes in store and via distance selling methods such as internet sales and catalogues.

How to comply

Suppliers must produce energy labels and fiches in accordance with the regulations, and the 91Ï㽶»ÆÉ«ÊÓƵing technical documentation, allowing their accuracy to be assessed.

They must also:

• provide labels to dealers promptly and for free
• include the product information sheet (also known as a product fiche) with each product
• make the technical documentation available to Office for Product Safety and Standards (OPSS) if requested and retain it for 15 years after the manufacturing of the product has stopped

Energy labels for certain products are being gradually re-scaled to display A – G energy rating classes instead of A+++ – G energy rating classes. The first phase of re-scaling took place in March 2021.

The new re-scaled energy label has been introduced for light sources from 1 October 2021. For light sources which will be placed on the market from 1 October 2021, suppliers will be required to print rescaled labels on to the packaging. For light sources placed on the market before 1 October 2021, upon request by dealers, suppliers must provide rescaled energy labels which are intended to replace existing labels to dealers. For existing printed labels this would be in the form of a printed sticker of a size which permits it to cover existing labels.

No label, mark, symbol, or inscription can be shown that could mislead consumers about the energy efficiency of a product.

For all energy labels, dealers must display the labels so that they are clearly visible, attaching them to the product where appropriate, and make the fiche available to consumers. For any means of distance selling, the information on the label and fiche must be provided to consumers before they buy the product.

New rules for dealers from 1 March 2021 (and 1 October 2021 for light sources)

There are new requirements on dealers when it comes to displaying the new, re-scaled energy labels for certain products. The products affected by these changes are:

• electronic displays
• dishwashers
• washer-dryers
• washing machines
• refrigeration appliances
• light sources

Dealers had until 18 March 2021 to replace old labels on display with rescaled labels for these products except light sources.

For light sources placed on the market before 1 October 2021 which bear the old energy label, dealers had until 1 April 2023 to replace the old labels on display with rescaled labels in such a way as to cover the existing label, including when the label is printed on or attached to the packaging. For this purpose, dealers can request rescaled labels from suppliers in the form of a printed sticker.

Further requirements:

• If, at the point of sale, a product model is only displayed in the packaging (not taken out of the packaging for display) the dealer must ensure visibility of the label for the consumer.
• In visual advertisements, technical promotional material and distance selling (see below for internet selling):
  • the full energy label does not have to be displayed alongside the product, but an arrow with the energy efficiency class and the range of energy efficiency classes must be provided
  • the dealer must provide a copy of the label or the product information sheet on a publicly accessible website and must provide paper copies on request
• In the case of internet selling:
  • an arrow with the energy efficiency class and the range of energy efficiency classes must be provided alongside the product, and this must link to the full energy label for the product
  • the dealer must make the product information sheet available alongside the product or by linking to it on a publicly accessible website

Requirements for all energy labels

Suppliers must provide the energy efficiency class alongside any advertisement or technical promotion.

The energy label is common across the United Kingdom, with variations according to GB or NI placement on market, and must include:

• the model number of the product and the suppliers name or trademark
• the amount of energy it uses according to the product specific regulations
• specific data in accordance with the applicable product regulation, in pictogram format
• its energy efficiency class, from best to worst, depending on the relevant scale for the product, with corresponding colour-coded arrows

From 1 January 2021 the energy label, for products placed on the GB market, must also include:

• the UK Flag
• English language text
• a QR code, where applicable, which must link to the required product information on a publicly accessible website

GB energy labels can be accessed using the service. To help you comply with the regulations there is a UK Energy Label Generator. This covers all the products listed under the ‘What is Covered’ section of which products need an energy label.

From 1 January 2021, the energy label, for products placed on the NI market, must include:

• the European Union flag
• a QR code where applicable, which must link to the required product information on the .

Suppliers placing products on the NI market can create their own energy labels using the EPREL database.

Monitoring and enforcement

OPSS is the appointed Market Surveillance Authority in GB and NI for suppliers.

Local authorities are responsible for enforcing the regulations in relation to dealers.

The Advertising Standards Authority (ASA) is responsible for enforcing the marketing of products with energy efficiency information.