One of the hot topics at the Ecodesign session of Agoria's R&S event last week was the Energy labelling database (EPREL) for which an obligation to register applies from January 1st, 2019 onwards. Time to take a look at the latest developments with one of our guest speakers Bram Verckens (FOD Economy).

Bram Verckens is head of department at the office for 'Algemene Directie Energie' (red: General Management for Energy) of the FPS Economy. Since the beginning of 2013 he is responsible for the follow-up of the European Energy labelling regulation and the corresponding product inspections on behalf of Belgium. He is supported in these activities by colleagues Bram Soenen (Ecodesign) and Estelle Vercouter of the FPS Environment. The surveillance on product regulation compliance is a federal responsibility in Belgium.

Bram Verckens is head of department at the office for 'Algemene Directie Energie' (red: General Management for Energy) of the FPS Economy. Since the beginning of 2013 he is responsible for the follow-up of the European Energy labelling regulation and the corresponding product inspections on behalf of Belgium. He is supported in these activities by colleagues Bram Soenen (Ecodesign) and Estelle Vercouter of the FPS Environment. The surveillance on product regulation compliance is a federal responsibility in Belgium.

The most recent European stakeholder meeting on EPREL took place on October 16th. How did it go?

Quite well. No big surprises came up. There was a discussion on the further planning of the EPREL project and the ongoing Ecodesign and Energy labelling revisions.

During the year the planning of the EPREL database development did not always proceed as planned. Is there more information on the definitive planning? Will companies be able to start product registration on November 1st?

The European Commission has announced that the 'product registration database' (red: final EPREL database) will be available for the official registration of products from December 14th onwards. However, not all functionalities and product groups will be available. For example the implementation of the 'System-to-System' functionality, an automatic exchange between supplier and the EPREL database, has been delayed till February. Also the registration of complex products without a label will not be possible until the beginning of 2019.

Data that will be registered in the product registration database is final. It will therefore not be possible to just adjust or remove data once it is entered. We therefore strongly recommend companies to use the testing database to try the registration of product data a couple of times before entering the data in the final database. The testing database will continue to be available once the final EPREL database is put into operation. Don't test with real data though, because the EPREL testing environment is not secure.

This means that once the product database is launched on December 14th, companies will have 2 weeks to register the products that are placed on the market per January 1st.  That's rather short notice. Does this delay in the project have any consequences for the obligation to register?

The obligation to register of January 1st 2019 is legally defined in the Regulation on Energy labelling and will therefore remain unchanged. All products that will be placed on the market on January 1st 2019 will need to effectively be registered in the database on the 1st of January. Units that have been placed on the market between the 1st of August 2017 and 1st of January 2019 will still need to be added to the database before June 30th 2019. However, for market authorities it will only be possible to start inspections on the obligation to register from April 1st 2019 due to a delay in the development of the EPREL database access for authorities and the general public. The Commission has announced that during the course of the second half of 2019 Member States will be requested to actively check whether the obligation to register in EPREL has been met.

 "All Energy labelling products that are placed on the market from January 1st 2019 onwards, need to be registered in the Energy labelling database (EPREL) between the 14th  and 31st of December 2018. "

A number of product groups is currently under revision, which might lead to a change in the scope of the regulation. For example, in the product group for lighting the new proposal refers to 'light sources' without differentiating between street lighting and domestic lighting. Which consequences will this have for the obligation to register?

The current regulation will remain in force until 20 days after the official 'entry into force' date of the new regulation. The meeting on the new product regulation for lighting products and a number of other product groups has been announced for the second and third week of December. Given the duration of the procedure, these Energy labelling regulations could be effective in 2019 at the earliest. Once the regulation has been approved and enforced, a number of products could be subject to Energy labelling regulation as a result of the adjusted scope while they weren't before.

Suppliers of these products will therefore not have to worry about the deadline of January 1st, 2019. However, once the new regulation is in force these products will have to be registered in the EPREL database. It doesn't seem reasonable though to ask companies to register all these products within 20 days. Our proposal would therefore be to include a separate deadline in the Energy labelling regulation for meeting the obligation to register in EPREL. This will, however, still need to be discussed during the 'Expert Group' (red: discussion and voting by Member States) meetings in December.

A number of products, such as 'luminaires', will likely no longer be in scope of the new Energy labelling regulation once this new regulation is in force. Luminaires will then only be subject to the obligation to register in the EPREL database for a couple of months. Is it the intention to register these products in the database for just a couple of months?

The European Commission has indicated that no template or product group space for luminaires will be provided in the EPREL database. The registration of luminaires will therefore not be possible.

Why was there decided to create a European database for product registration?

The idea behind the database is to realise a fairer market through faster identification of products that do not meet demands. This will allow us to carry out more focused inspections of companies that are failing to comply with the rules. As a consequence companies that do invest to respect the quality requirements will be able to have a fairer competitive position. The data in the database will therefore most likely be used by us in risk analyses and in deciding on surveillance campaigns. It will allow us to carry out our work in a more focused manner, even just because we will have a direct view on the right contact person within a company. At the moment it can take us weeks to track down the right person.

Moreover, a database for product registration is nothing new. Australia and the United States, among other countries, already have similar databases in use.

 "The EPREL database will contribute to the creation of a fairer market by allowing for faster identification and contacting of companies that do not meet the quality standards".

How would you advise companies to prepare for the deadlines of January 1st and  June30th 2019?

It is certainly important to start collecting the necessary data as soon as possible in an (internal) database. Such a database can then be used to quickly upload the product data manually or to translate it into the standard zip-file for a serial uploads. From February 2019 an automatic exchange between a company's internal database and the EPREL database will also be possible through the 'System to System' functionality. For using this functionality the fields in the 'registration-data.xml' file will remain the basis for the structuring of the date. The exact fields are dependent on the Energy labelling demands per product group.

Where can a company find those fields exactly?

The European Commission has created a useful Excel-file in which all mandatory fields per productgroup are listed (red: the Excel file can be found on the 'EPREL Exchange Model Documentation v2.1.0' on the EPREL workspace: under the 5th heading from the top: 'Exchange model fields in Excel format'). From this list is should be possible to assess reasonably quickly which data and technical documentation is relevant per product group.

More information on the different registration options for the EPREL database can be found in this article:   

Do you have any specific advice for SMEs?

We acknowledge the difficulties that SMEs can experience with meeting the obligations. Last Tuesday we therefore asked the European Commission on behalf of Belgium to provide more communication for this specific target group. The European federations have also indicated that this group will have difficulty with following the developments and the investment of time that is required. The Commission has indicated that they certainly want to invest in the communication towards SMES, but that they need more information on what the exact needs are.

I would like to request SMEs to provide me with feedback on the difficulties that they encounter. In addition I would like to advise them to assess how many products actually need to be registered. In case it concerns a few dozen models it might be more interesting to use the manual registration option instead of investing time in the creation of an xml file necessary for a serial upload.

What message would you like to give to companies?

That the registration in the EPREL database should not be seen as a one-off effort; from January 1st 2019 product registration should be viewed as a permanent part of selling products. As soon as a product is placed on the market, it should be registered. As soon as a product is taken off the market, a 'date of end of placement on the market' should be entered. It should become an integral part of the sales mentality.

"Product registration is no one-off effort, but needs to become an integral part of the European sales mentality."

Feedback on specific needs or problems as a SME to meet the registration requirements? Please contact Charlotte van de Water (