Supplier FAQs

We'll update these questions and answers on a regular basis. 

Last updated: 04 April 2022

• Appliances and TVs/electronic displays
• Light sources

Appliances and TVs/electronic displays

What information do I need to supply to a dealer/can a dealer request?

• Printed energy labels (with accurate information) need to be provided with each unit/product. You should aim to provide this to the dealer within 5 working day s of the request.
• A printed product information sheet for rescaled products should be supplied to the dealer if requested
• Electronic labels and product information sheets should be made available to dealers for each product

What about advertisements?

• Suppliers must provide the energy efficiency class and range of available classes alongside or within any advertisement or technical promotion

How do I create a GB label?

• You can create the label at www.gov.uk/guidance/create-an-energy-label

When do I need to use an EU label?

• An EU label will need to be used when placing products on the EU and NI market. You can create your own labels using the EPREL database.
• Although the UK government are not opposed to showing the EU and GB labels together, this is not the case in the EU. Please see the following statement on the provision and display of UK Energy Labels in Ireland from SEAI. 

How large does the energy label need to be?

• The size of the energy label is regulated in the specific energy label regulation for each product group. Links to the regulations can be found here

Light sources

What information do I need to supply to dealer/can a dealer request?

• For light source products placed on the market from 1 October 2021, suppliers will be required to print rescaled labels on the packaging.
• For light sources placed on the market before October 2021, dealers have until 1 April 2023 to replace the old labels on light source products. In order to do this, you must provide a rescaled energy label, if requested to do so by the dealer, so they can replace existing labels of products in their stock. This should be in the form of a printed sticker of a size which permits it to cover existing labels. 
• If specifically requested by the dealer, you should either provide a printed copy of the product information sheet to them or ensure that the product information sheet is made available on a publicly accessible website, free of charge and on a page of the website that does not contain any other information.

Where can I find the definition of a light source?

• Part 2, Chapter 1 of The Ecodesign for Energy-Related Products and Energy Information (Lighting Products) Regulations 2021.

Where can I find the Obligations of suppliers in the regulations?

• Part 2, Chapter 3 of the The Ecodesign for Energy-Related Products and Energy Information (Lighting Products) Regulations 2021.

Are products that contain a light sources covered under the new regulations?

• 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 and must be tested. For example, a completely sealed luminaire in a wet room where no components can be removed for testing. The energy label must be printed on the packaging. The type of light source contained (e.g. LED, R9) and the energy class of the contained light source(s) must be indicated. This obligation applies from 1 March 2022 (following the Omnibus amendment). Suppliers of the contained light source have no obligation to show the QR code (pointing to further product information).
• 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.

I am a supplier of a containing product, what must I do?

• Provide a statement of the energy efficiency class of the light source: Suppliers of containing products must provide information on the contained light source within the user manual or instruction booklet. This should be in the form of the statement below (replacing X with the energy efficiency class of the contained light source. The statement can be pluralised, or repeated for each light source, if multiple light sources are present. 

“This product contains a light source of energy efficiency class X.

• As a supplier you may also be required to provide information on on how the light source can be removed for verification without permanent damage to the light source, upon request by the market surveillance authority. 

Do the regulations apply to light sources with a luminous flux under 60 lumen?

• No, the regulations apply to light sources with a luminous flux of over 60 lumen.

Are light chains considered a light source within the regulations?

• Yes an LED light chain, no matter the length, is defined as a light source (as long at the luminous flux is over 60 lumens) so therefore may be included in the scope of the legislation.

 What products are not considered a light source?

• LED dies 
• LED chips
• LED packages 
• A product containing a light source from which the light source can be removed (the removable light source is considered a light source rather than the WHOLE product).
• Light-emitting parts contained in a light source from which these parts cannot be removed for verification as alight source (the WHOLE product is instead considered a light source).