What Happens If You Do Not Display Energy Labels? EU Enforcement

Energy labelling is a legal requirement

The EU energy labelling framework is not voluntary. Under the Energy Labelling Framework Regulation (EU) 2017/1369, products covered by delegated regulations must carry an energy label. For online sales, the label and product information sheet must be accessible to customers before purchase.

This applies to any retailer selling covered products to EU customers, regardless of the seller's location. The framework covers over 30 product categories, with specific delegated regulations for each product type that detail exactly what must be displayed.

How is compliance enforced?

Enforcement of EU energy labelling regulations is carried out by market surveillance authorities in each EU member state. These national authorities are responsible for monitoring the market and taking action against non-compliant products and retailers.

Regulation (EU) 2017/1369 requires that member states establish market surveillance programmes and carry out checks. The regulation also established the EPREL database partly to support enforcement — it gives market surveillance authorities access to non-public product documentation and supplier contact information.

Under Regulation (EU) 2019/1020 on market surveillance, national authorities have the power to carry out checks on products offered for sale online, including checking that energy labels are correctly displayed and that the information matches what is registered in EPREL.

What penalties can apply?

Penalties for non-compliance with energy labelling regulations are determined by each EU member state individually. The Energy Labelling Framework Regulation (EU) 2017/1369 requires member states to lay down rules on "penalties applicable to infringements" and ensure they are "effective, proportionate and dissuasive."

The specific penalties vary by country and can include fines, orders to remove non-compliant products from sale, and requirements to correct labelling. The exact amounts and procedures depend on national legislation implementing the EU framework.

For online retailers, non-compliance means not displaying the energy label, displaying incorrect data, or failing to provide access to the product information sheet. Any of these can trigger enforcement action by the relevant national authority.

Cross-border enforcement

For online retailers based outside the EU, enforcement can occur when the products or services are directed at EU consumers. EU market surveillance authorities have been increasingly active in monitoring online marketplaces and cross-border e-commerce.

The Regulation (EU) 2019/1020 on market surveillance specifically addresses products sold online and provides authorities with tools to take action against non-compliant offerings, including requesting that online interfaces remove or disable access to non-compliant product listings.

Practical steps for compliance

The most reliable way to display accurate energy labelling data is to source it directly from the official EPREL database, which is operated by the European Commission. Since suppliers are required to register their products in EPREL before placing them on the EU market, the database should contain entries for all products that require energy labels.

• Identify which of your products fall under EU energy labelling regulations
• Find the corresponding EPREL entries for each product (by GTIN, model name, or EPREL ID)
• Display the energy label and product information sheet on your product pages
• Keep the displayed data in sync with what is registered in EPREL

Tools like EPREL Label Buddy can automate this process for Shopify merchants by connecting directly to the EPREL database and keeping data synchronised. However, merchants remain responsible for verifying that their stores display the correct information for their products.