Energy Labels in Your Shop: Getting the Mandatory Data Right

Anyone selling household appliances, light sources or electronic displays online is not only selling a product but also a set of mandatory disclosures. The energy label is part of that package, and it belongs visibly with the offer rather than buried in a document folder at the bottom of the page. Regulation (EU) 2017/1369 on energy labelling has been in force since 1 August 2017 (EUR-Lex) and asks retailers for more than uploading a graphic: the label and the product information sheet have to appear with the product, the efficiency class belongs in every advert that shows a price, and the data has to match the registration the supplier filed in the European product database. This article shows how to present these disclosures cleanly in an online shop, which fields your product data management needs for it, and where the typical gaps appear.

What energy labelling asks of retailers

The legal basis is Regulation (EU) 2017/1369, amended by Regulation (EU) 2020/740; the consolidated version is dated 1 May 2021 (EUR-Lex). It applies directly in all member states and draws a clear line between two roles. Suppliers - manufacturers, authorised representatives and importers - produce the label and the product information sheet, are responsible for the measured values and register both. Dealers, and that includes every shop operator, pass these details on. Anyone selling at a distance cannot fall back on not having measured the values themselves: the duty to present them correctly in the offer sits with whoever publishes that offer (EUR-Lex).

Articles 5 and 6 of the regulation summarise dealer obligations in four points: display the label provided by the supplier visibly with the product, make the product information sheet accessible, request missing documents from the supplier - a missing product information sheet may alternatively be taken from the product database where its print and download function is available for the product - and cooperate with market surveillance authorities (EUR-Lex). For online retail this means one thing in practice: the label belongs where the buying decision is made, close to the price and the add-to-cart button. A link in the page footer or a central collection page holding every information sheet does not meet the requirement, because the disclosure no longer belongs to the specific offer.

The A to G scale and the effects of rescaling

Until 2021 the scale was inflated by plus grades: A+++, A++ and A+ sat above an A that almost no appliance carried any more. Since 1 March 2021 dishwashers, washing machines, washer-dryers, refrigerating appliances and electronic displays have used the clear A to G scale again, and light sources have done so since 1 September 2021 (European Commission). Rescaling was not a simple swap of stickers but a tightening of the assessment: an appliance that previously carried A+++ now sits in class B, C or lower depending on the product group. The top classes deliberately remain largely unoccupied at first so that the scale keeps headroom for years and technical progress stays visible (German Environment Agency).

That has two consequences for shops. First, any legacy record still showing a plus class is outdated and vulnerable in advertising - such remnants usually sit in description texts, old graphics and product feeds rather than in the actual data field. Second, customers expect context: a refrigerating appliance in class D looks worse than its supposed A+++ predecessor even though it can be more economical. A short explanatory note next to the label that puts the new scale in context prevents service enquiries and reduces returns driven by disappointment. Missing or hard-to-find product details are among the frequent causes of purchase abandonment on product pages (Baymard Institute).

Presenting label and information sheet on the product page

Three elements belong together on the product detail page: the efficiency class as a stated value, the label as a graphic and the link to the product information sheet. How these elements may be shown at a distance is set out in the delegated acts for the individual product groups, as a rule in Annex VIII (European Commission). The core of the rule is a simple principle: the details have to be perceptible without an extra search, and the link to the information sheet has to carry the clearly legible wording Product Information Sheet. A caption such as More Information, Downloads or Documents does not satisfy this, because it hides the mandatory character of the disclosure.

• Efficiency class in view: the class and the range of available classes sit close to the price and the cart button, not in a tab far below the middle of the page.
• Label at full resolution: the arrow diagram is stored as its own graphic and can be enlarged; a heavily scaled thumbnail leaves the consumption values unreadable.
• Information sheet clearly named: the link is called Product Information Sheet and leads straight to the document for the specific model, not to a general download page.
• In lists and filters too: in category lists, search results and comparison views the class belongs on the product tile as soon as the offer appears there together with a price.
• Treat language versions equally: if you sell in several languages, carry class, range and information sheet in every language version - the article on quality control in multilingual shops describes what to watch for.

Technically, most errors originate in data management rather than in the template. When the efficiency class and the information sheet are maintained as free text inside the product description, they drift apart with every change to the range: the class sits in body text, the label lies in the image gallery, the sheet hangs off a tab. A dedicated, typed field per disclosure - class as a select list, range as a derived value, label and information sheet as media references - makes template output trivial and checking automatable. How such mandatory details fit into the upper part of the page without disturbing the buying impulse is covered in the article on designing the visible page area.

Nested display: when a link is enough

For distance selling the regulation permits what is known as nested display: instead of the complete label, an arrow carrying the efficiency class may appear first, opening the full label on click or tap (European Commission). On small screens that is a sensible compromise, because the portrait-format label takes a lot of room and would push the price out of view. The implementation, however, comes with conditions that are frequently overlooked in practice.

Three patterns dominate enforcement practice: the label is missing from the list view even though the offer is already advertised with a price there; the link to the information sheet is captioned as a generic download; and the class statement in an advert names the class but not the range of available classes (IT-Recht Kanzlei). All three can be solved with a single template component that pulls the details from one record and renders them identically at every output point. The effort is spent once, the benefit returns with every new product group.

EPREL: where the data comes from and how it reaches the shop

Since 1 January 2019 suppliers have had to register labelled models in the European product database EPREL before placing them on the market (European Commission). The database has two parts: a public section holding the label and the product information sheet, and a compliance section holding the technical documentation. For retailers the public part is the reliable source when a supplier does not deliver documents at all or only partially - and Article 5 of the regulation explicitly provides for this route as a dealer option (EUR-Lex).

In practice this means that every labelled article in the shop needs a registration number or an unambiguous model reference through which the label and the information sheet can be retrieved at any time. Without that reference every update turns into a manual search that may well find the wrong model year. With it, the reconciliation can be scheduled: a recurring run that checks whether each labelled article has a registration number, a label, an information sheet and a valid class, and that feeds deviations back to the editorial team as a task. Such runs belong in the same chain as the rest of your data management via PIM integrations.

{
  "sku": "WM-8000-WS",
  "energy_label": {
    "eprel_id": "<registration-number>",
    "class": "C",
    "scale": "A-G",
    "label_image": "/media/label/wm-8000-en.png",
    "information_sheet": "/media/sheet/wm-8000-en.pdf",
    "legal_act": "EU 2019/2014",
    "as_of": "2026-08-14"
  }
}

The record is deliberately narrow. It carries exactly the fields the surface needs plus a date recording when reconciliation last ran. That date creates the actual control: anything older than the most recent supplier import automatically lands on a list and is refreshed. The legal act stored in the record additionally helps to derive the correct range, because not every product group uses the full span from A to G. How to build a chain of import, enrichment and control is described in the article on automated product data enrichment.

Advertising, category lists and product feeds

The mandatory disclosures do not stop at the product detail page. As soon as an offer is advertised with a price, the efficiency class and the range of available classes belong with it: on the category page, in search results, in the newsletter, in the advert and in the product feed (European Commission). The range is the part that goes missing most often. Stating class C on its own is not enough; what is required is the classification, for example class C on a scale from A to G (IT-Recht Kanzlei).

• Category and search result pages: class and range on the product tile as soon as a price is shown there - this also applies to promotional sliders on the home page.
• Product feeds: fill the attributes for efficiency class and range; the article on product feed optimisation shows how to set feeds up in a structured way.
• Email and adverts: promotional material outside the shop carries the details too when it names the model and the price.
• Discount presentation: a price reduction changes nothing about the mandatory disclosures; the rules on presenting strikethrough prices apply on top.
• Bundles and sets: if a set contains a labelled appliance, its details belong in the set offer, not only in the individual articles.

Implementation in Shopware: fields, maintenance and output

In Shopware 6 the requirement can be mapped without third-party logic. The Community Edition ships custom fields, media management and templating - everything a clean output needs. The effort does not sit in the frontend but in the question of where the data comes from and who keeps it current. In Shopware development we typically set such pipelines up in four steps that can be accepted independently of one another.

1. Define the field model: a custom field set with class as a select list, range as a derived value, registration number, label as a media field and information sheet as a media field. The set is attached to the product groups that are actually subject to labelling, not to the entire catalogue.
2. Wire up the import: the supplier or database import writes the fields, not the editorial team. Manual entries stay the exception, are logged and are not silently overwritten by the next import.
3. Centralise the output: one template component renders class, range, label preview and information sheet link. Detail page, category tile, comparison view and feed all draw on the same component so that no view diverges.
4. Schedule the control run: a recurring job reports articles without a class, without a label, without an information sheet or with a plus class from legacy data. The list goes to product data maintenance as a task, not into the log as an error message.

The difference between the second and the fourth route shows up not on implementation day but at the first larger change of range. Anyone taking on 800 new articles does not want to assign 800 labels by hand and then hope on the basis of spot checks. The same logic applies to further mandatory data sets: the structures created for the energy label also carry the disclosures under the product safety regulation and battery labelling. The field model does not have to be invented a second time.

Ecodesign regulation and the road to the product passport

The energy label is the oldest building block of a framework that is currently being extended considerably. Ecodesign Regulation (EU) 2024/1781 has been in force since 18 July 2024 (European Commission) and provides for a central register by 19 July 2026 (EUR-Lex). It widens the requirements from pure energy efficiency to durability, repairability, recycled content and resource use. The digital product passport becomes the carrier of these details - technically nothing more than a structured record with an unambiguous reference, often through a code on the product or the packaging. What follows from this for shops is described in detail in the article on the digital product passport.

In parallel, member states apply the national transposition of Repair Directive (EU) 2024/1799 from 31 July 2026, which alongside the repair obligation also covers spare parts and repair information (EUR-Lex). For shop operators a recurring pattern emerges: mandatory details will increasingly arrive as records rather than body text, they point to an external registration, and they surface at several output points at once. If you build your field model today so that class, registration number and document reference are kept separate, you can hook the product passport into the same place later. How to structure repair and spare part details is shown in the articles on the right to repair and on the spare parts catalogue in a B2B shop.

Anchoring mandatory disclosures in product data maintenance

Energy label compliance is not a project with an end date but a property of product data maintenance. It holds as long as three things are true: a field model that keeps the details typed; an import that refreshes them from a reliable source; and a control run that reports gaps before customers or a competitor find them. The effort for these three building blocks is manageable - considerably more manageable, at any rate, than cleaning up several thousand articles retrospectively under time pressure.

Appliances with an energy label often bring a second topic with them: washing machines, refrigerating appliances and large displays are bulky, and shipping runs through a freight carrier with its own delivery rules. Thinking about both together - complete mandatory disclosures and an honest presentation of delivery conditions - noticeably reduces enquiries and returns; the article on freight shipping for bulky goods describes the fields needed for it. If you would like your product pages checked against the energy labelling requirements: we review the field model, the output and the maintenance route with you and estimate the rebuild effort realistically - discuss your project.