Ecodesign is an approach to designing electric heaters products with special consideration for the environmental impacts of the product during its whole lifecycle.

1. Is voluntary application of the label before the official introduction admitted? How to ensure uniform application in the EU? 
Voluntary application of the label before the official implementation date is not allowed. Delegated acts specify the date from which a particular label shall be supplied. If it is supplied and subsequently displayed before that date the label is thus used in a manner not provided for in the delegated act.

2. Can the energy label be displayed before application at trade fairs, where products are not sold and end-users do not have access (the fairs are only for professional intermediates, such as installers)?

Regulation (EU) 2015/1186 specific for the energy labelling of local space heaters and the new energy labelling framework Regulation (EU) 2017/1369 establish that the dealer has to ensure that each local space heater bears the label at the point of sale. A trade fair, where products are not sold and end-users do not have access, is not a point of sale. Therefore, there is no obligation to display the label and at the same time information can be provided to professionals about the energy labelling class of the product. Even if no energy labelling legal requirements apply, common sense dictates that in order to provide accurate information, the labels displayed shall be in line with the relevant regulations.

3. Should the energy label be delivered together with the local space heater inside the box, or could it be provided for each local space heater by means of separate literature regarding the product, websites, brochures, evidence at sales point, etc.?

According to Article 3 of Regulation (EU) 2015/1186 and Article 3 of the new energy labelling framework regulation (EU) 2017/1369, the label shall be printed; there is no specific indication on where to provide it, but websites cannot be used to provide an alternative to “printed” labels. It is to be understood that the dealer has to be provided with correct and clear information on the energy performance of heaters. The label may be delivered together with supplementary material as long as labels are provided with each individual local space heater.

4. With regard to the obligation to communicate the efficiency class, the definitions of energy related information and technical parameters are unclear: for example, are dimensions technical parameters?

Dealers are obliged to provide information on the energy efficiency of the product together with any technical promotional material or together with information describing the technical parameters of the product. The technical parameters are laid down in Annex V of Regulation (EU) 2015/1186. Dimensions (i.e. regarding the size of the product) are not considered as technical parameters.

5. For products in scope of Regulation (EU) 2015/1186 for the energy labelling of local space heaters, is a price list of the supplier, which is used for dealers only, defined as technical promotional material?

Any visual advertisement relating to a specific product and containing price information has to include a reference to the energy efficiency class of the product and the range of efficiency classes. As price lists obviously include information on prices, they are covered by this obligation.

For price lists used in digital format, e.g. for a retailers’ database, a reference to the seasonal space heating energy efficiency class under average climate conditions for that model should be included.

6. Are units delivered to dealers before 1 January 2018 subject to the energy labelling requirement?

No. Regulation (EU) 2015/1186 for the energy labelling of local space heaters is only applicable to products that are placed on the market or put into service from 1 January 2018 onwards.

7. What happens if a label has not the exact dimensions as indicated in Regulation (EU) 2015/1186?

The format and dimensions of the label as laid down in Regulation (EU) 2015/1186 have to be respected. The Member States are responsible for assessing compliance with the requirements of Regulation (EU) 2015/1186, including the label format.

8. On the energy label, the direct heat output needs to be displayed: should this be the gross calorific value or the net calorific value?

The heat output is independent of net or gross calorific value. The difference between net and gross calorific value affects the fuel input (for example energy efficiency or emission requirements).

9. How shall the Energy Efficiency Index (EEI) be rounded for determination of the energy efficiency class?

The EEI value for the determination of the energy efficiency class shall be to the nearest one decimal place.


10. Clarify if the following assumption is correct: The energy labelling requirements apply also to the appliances that have been produced/imported before the entry into force of the regulation (1/1/2018 or 1/1/2022 depending on the product), but were stored at the retailers’ premises for the meantime.
Use and obligations regarding Ecodesign heaters energy labels