Retailer FAQs

We'll update these questions and answers on a regular basis. When a question is submitted via the contact form, it is added to these questions for the benefit of all UK retailers.

Last updated: 8 November 2022

General topics

When do the old labels need to be replaced with the new labels for household appliances and TVs?

  • For products that will continue to be placed on the market after November 2020, the replacement must be carried out by 18 March 2021 (i.e. within 14 working days from 1 March 2021). The new labels must not be shown in store, online shops or in promotional materials before 1 March 2021.
  • You can find details of all the key legislation milestones here. 

Do labels included in product packaging already in retailer stocks also have to be replaced?

  • No. Modification of the content of packaging is required for units in the retailers’ stock. Retailers only need to display the rescaled label in store and online from 1 March 2021.

Can visual advertisements or catalogues with the new labels be shown before 1 March 2021?

  • No. Any visual advertisement for a specific rescaled product containing its new energy efficiency class should not be made public before the 1 March 2021. Catalogues and other promotional materials can be prepared but not disseminated before this date.

Are any products in the rescaled categories (household appliances, TVs and electronic displays) exempt from relabelling, and when are such products allowed to be sold by retailers?

  • If a manufacturer/supplier has ceased its activities and a retailer is unable to obtain a rescaled label for units already in its stock, they are allowed to sell those units exclusively with the non-rescaled label until the 30 November 2021.
  • If no new units belonging to the same model or equivalent models are placed on the market after 1 November 2020, the manufacturer/supplier does not need to supply a rescaled label. In that case, the retailer can continue to sell those units exclusively with the non-rescaled label until 30 November 2021.

Online/distance selling

What are the specific requirements for internet and distance selling?

  • A coloured arrow representing a product's energy efficiency class - as well as the range of available energy efficiency classes for that product - must be placed next to the product model. The graphical specifications of the arrows are detailed in the energy labelling regulation for each product category.
  • Retailers can request printed product specification sheets from manufacturers/suppliers. Additional specifications on the rescaled energy label and product information sheet for internet and distance selling are detailed in the energy labelling regulation for each product category.
  • In the case of distance selling and telemarketing, customers can request a printed copy of the label and product information sheet from the retailer. In the case of telemarketing, the (oral) information provided to the customer must include the product energy efficiency class and the range of available energy efficiency classes.

Promotional and educational material concerning the new labels

What kind of promotional and educational material can be used before the application date of the new regulations?

  • Any visual advertisement for a specific rescaled product containing its new energy efficiency class, should not be made public before the 1 March 2021. Catalogues and other promotional materials can be prepared but not disseminated before this date.
  • General information campaigns on the rescaling of the energy labels accompanied by educational material can take place before the application dates of the new regulations.

Brexit, Great Britain and Northern Ireland

We have stores in both Great Britain and Northern Ireland. What is the process for rescaling the EU and GB versions of the labels?

  • The GB labels are for use in England, Wales and Scotland whilst the EU labels continue to be used in Northern Ireland and Republic of Ireland. In the Republic of Ireland and the European Single Market, the provision or display of the UK energy label to consumers in these areas is prohibited in accordance with Regulation (EU) 2017/1369. This includes the provision and/or display of UK energy labels in Irish stores, on websites directed to consumers in Ireland, or with the product when supplied to customers in Ireland. The provision or display of the UK energy label alongside the EU energy label is also prohibited. For requirements in other jurisdictions, the appropriate Market Surveillance Authority (MSA) should be consulted.

What is the timeline for replacing EU energy labels with GB labels for products that are not being rescaled?

  • There is currently no timescale for replacing EU energy labels for products that are not yet being rescaled. This should be done as soon as is practical.

Dual Labelling

Why are manufacturers including both the current and rescaled labels in product packaging?

  • Under the new legislation, manufacturers/suppliers are required must provide both versions of the label in product packaging from 1 November 2020 to 28 February 2021. This is to ensure that the consumer receives the same information as was advertised at point of sale.
  • This dual labelling period only applies to information provided in product packaging. Retailers must not do this in store or online.
  • You are welcome to download this leaflet for consumers (PDF, 155 kB) which explains why there may be two labels available in the product packaging. You can provide this leaflet to your customers at point of sale.

Light Sources

When do the old labels need to be replaced with the new labels for lighting products?

  • New products i.e. products place on the market after 1 October 2021, must be shown in store and online with the rescaled label from the 1 October 2021.
  • For products already in the dealer’s stock, dealers have until 1 April 2023 (18 months from 1 October 2021) to replace the existing label ensuring that the existing label is covered both when the label is printed on or attached to the packaging. 
  • You can find details of all the key legislation milestones here.

What kind of promotional and educational material can be used before the application date of the new regulations?

  • Any visual advertisement for a specific rescaled product containing its new energy efficiency class, should not be made public before the 1 October 2021. Catalogues and other promotional materials can be prepared but not disseminated before this date.
  • General information campaigns on the rescaling of the energy labels accompanied by educational material can take place before the application dates of the new regulations.
  • Any visual advertisement or technical promotion for a specific model of light source must show the energy efficiency class; and the range of energy efficiency classes available.

What do I need to do/what can I request?

  • Suppliers should print the rescaled labels on the packaging for products placed on the market from the 1 October 2021.
  • For light sources placed on the market before October 2021, you as a retailer or dealer have until 1 April 2023 to replace the old labels on light source products. In order to do this, you can request from the supplier, a rescaled energy label for the products in your stock. This should be in the form of a printed sticker of a size which permits it to cover existing labels.
  • You can also request from the supplier, a printed copy of the product information sheet or you can have access to this through a publicly accessible website, free of charge on a page of the website that does not contain other information.

What if the light source component of a lighting product cannot be removed for testing i.e. ‘contained light sources? Are there any special labelling considerations for these types of light sources?

  • If a product contains a light source that cannot be removed/replaced for testing, then the product as whole is considered a light source under the legislation. The type of light source contained (e.g. LED, R9) and the energy class of the contained light source(s) must be indicated.
  • Light fixtures and products with light sources that can be removed for verification are considered ‘containing products’ within the legislation. The product as a whole does not need an energy label on the packaging but an energy label and product information sheet for the contained light source must be provided with the product.
  • Suppliers of the contained light source have no obligation to show the QR code (pointing to further product information).

Are LED light strips considered light sources?

  • Yes and therefore may be included in the scope of the legislation.

We have stores in both Great Britain and Northern Ireland. What is the process for rescaling the EU and GB versions of the labels?

  • The GB labels are for use in England, Wales and Scotland whilst the EU labels continue to be used in Northern Ireland and Republic of Ireland.