Ecodesign Directive: An Essential Guide for EU Importers

The Ecodesign Directive and the Energy Labelling Regulation lay down the requirements for ecodesign, energy consumption, technical documentation, and energy labeling for electronics in the EU. These regulations mainly cover home appliances, but also computers, power supplies, and LED lighting products.

In this guide, we explain what EU importers and manufacturers must know about standards, CE marking, energy labeling, documentation, lab testing, and more.

Product Scope

Most energy-related products fall into the scope of the Ecodesign Directive and the Energy Labelling Regulation, including the following:

• Electrical lamps and luminaires, including LED lamps
• Electronic displays and televisions
• Vacuum cleaners
• Fans
• External power supplies
• Domestic ovens and range hoods
• Power transformers
• Residential ventilation units
• Air conditioners
• Heaters
• Household dishwashers
• Household refrigerating appliances
• Household washing machines
• Computers and computer servers
• Electrical motors

The European Commission provides a list of 28 energy-efficient product groups on its official website. Therefore, you can read the list to determine whether your products might fall into the scope of the Ecodesign Directive and the Energy Labelling Regulation.

Product Specific Regulations

The Eco Design Directive acts as a Framework Directive for energy-related products, setting out the product scope, conformity assessment procedure, administrative requirements, and other general requirements.

Specific product requirements, such as relevant EN harmonized standards and energy-saving specifications, are outlined in the specific regulations, that are based on different types of products such as dishwashers, lighting products, and power supplies. Importers can find more information on the EU official website.

Below, we list the general requirements for several categories of products covered by the Ecodesign Directive.

Lighting Products

Lighting products, including lamps and luminaires, are regulated by the Ecodesign Directive. Therefore, products such as light bulbs and household lamps shall satisfy its requirements before importing to the EU.

Additional Regulations

Besides the framework directive, several additional regulations apply to lighting products, including regulations concerning:

• Ecodesign requirements for non-directional household lamps
• Ecodesign requirements for fluorescent lamps
• Ecodesign requirements for directional lamps

These regulations provide the technical parameters (e.g Lamp Survival Factor and lamp lumen maintenance factor) for lighting ecodesign requirements.

EN Standards

The above-mentioned regulations also provide specific EN standards, such as:

a. EN 60357 – Tungsten halogen lamps (non-vehicle) – Performance specifications

b. EN 60064 – Tungsten filament lamps performance requirements

c. EN 60432 – Incandescent lamps safety specifications

d. EN 61000 – Electromagnetic compatibility

Electronic Displays & TV

The Ecodesign Directive covers television sets or television monitors to be sold in the EU. It sets out internal design control, a management system, and other relevant procedure for assessing conformity to follow.

Additional Regulations

There is an additional regulation with regard to ecodesign requirements for televisions or televisions monitors. This regulation covers specific ecodesign requirements that concern displays and tv such as:

• On/off mode power consumption requirement
• Peak luminance ratio
• Ecodesign measurement
• Test parameters to be provided by manufacturers
• Market surveillance procedure

EN Standards

a. EN 62301 – Household electrical appliances – Measurement of standby power

b. EN 62087 – Audio, video, and related equipment – Determination of power consumption. General

Air conditioners

The directive sets out requirements for mains-operated air conditioners with a rated capacity of ≤ 12kW for cooling, and comfort fans with power input ≤ 125W.

Additional Regulations

The European Commission also provides an additional regulation to facilitate the ecodesign aspect of air conditioners. The regulation provides further requirements for:

• Energy efficiency
• Sound power level
• Maximum power consumption

EN Standards

Here are some listed harmonized EN standards relevant for this category of products:

a. EN 12102 – Air conditioners measurement of airborne noise

b. EN 12900 – Refrigerant compressors

c. EN 15218 – Test methods and requirements for air conditioners and liquid chilling package

d. EN 12900 – Manufacturer’s performance data refrigerant compressors

Refrigerators

The Ecodesign Directive establishes requirements for household and professional refrigerators including storage cabinets, blast cabinets, condensing units, and process chillers.

Additional Regulations

The EU provides additional regulations to complement the Framework Directive, covering:

• Additional eco-design requirements
• Testing requirements
• Refrigerators classification
• Technical parameters
• Calculation of the energy efficiency index

EN Standards

The following EN standard specifies test methods for checking the characteristics such as forced air circulation, internal natural convection, and appliance performance:

a. EN 62552 – Household refrigerating appliances characteristics and test methods

Dishwashers

Household dishwashers fall into the scope of the Ecodesign Directive, excluding battery-operated dishwashers, which are not covered by the directive.

Additional Regulations

There is an additional regulation that provides more specific ecodesign requirements for dishwashers, including guidelines on the following:

• Conformity assessment
• Verification procedure for market surveillance
• Dishwashers capacity requirements
• Cleaning efficiency index
• Drying efficiency index

EN Standards

Here are some harmonized EN standards for dishwashers:

a. EN 50242 – Methods for measuring the performance for electric dishwashers

b. EN 60436 – Methods for measuring the performance for electric dishwashers

Vacuum Cleaners

The Ecodesign Directive covers most electric mains-operated vacuum cleaners. However, it doesn’t apply to outdoor vacuums, floor polishers, or industrial vacuum cleaners.

Additional Regulations

Additional regulations establish more technical requirements for vacuum cleaners such as:

• Carpet test requirements
• Annual energy consumption requirements
• Average specific energy consumption requirements
• The durability of the hose
• Operational motor life-time requirements

EN Standards

Here we list several harmonized EN standards relevant for vacuum cleaners:

a. EN 60312 – Methods for measuring the performance of household vacuum cleaners

b. EN 60335 – Particular requirements for vacuum cleaners and water suction cleaning appliances

c. EN 60704 – Test code for the determination of airborne acoustical noise (for vacuum cleaners)

Electrical Motors

The Ecodesign Directive is applicable to most electrical motors, including units integrated into other products. Note that the directive defines motors as an electric single-speed, three-phase 50Hz or 50/60 Hz, squirrel cage induction motor.

Additional Regulations

There is an additional regulation providing specific requirements for electrical motors, including:

• Motors efficiency
• Technical documentation
• Rated power outputs
• Rated input frequency
• Range of operating conditions
• Disassembly, recycling, or disposal wat end-of-life

EN Standards

Here some EN standards relevant for electrical motors

a. EN 60034-2-1 – Rotating electrical machines — Part 2-1: Standard methods for determining losses and efficiency from tests

b. EN 60034-30 – Rotating electrical machines — Part 30: Efficiency classes of single-speed, three-phase, cage-induction motors

Management System

Manufacturers must address environmental aspects related to product performance and energy consumption. This requires implementing specific measures during the design and manufacturing stage, which must be documented in a systematic way.

In Annex V, the directive points out that a management system can be used to show that the product complies with the requirements of the applicable implementing measure.

Management System Overview

Here is an overview of the elements that shall be included in the management system:

1. Environmental product performance objectives

2. Ecological profile of the product

3. Tests for product performance against environmental indicators

4. Relevant environmental assessment

5. Specifications that indicate the applicable standards

6. Procedures for manage documentations and kept up to date

7. A full internal audit of the management system

ISO 14006

Note that the directive doesn’t provide a specific management system that shall be followed. However, in order to fulfill the above-mentioned requirements, manufacturers often choose to implement the widely accepted management system such as ISO 14006 – Environmental management systems — Guidelines for incorporating ecodesign.

ISO 14006 provides guidelines to assist manufacturers with the establishment, documentation, implementation, and maintenance of the ecodesign management system.

Documentation

Under the Ecodesign Directive, importers or manufacturers are required to draft, the technical documentation. Also, they must keep such documentation up to date. Below, we list the key documents required by the directive.

Declaration of Conformity (DoC)

The DoC is a self-issued document prepared by either the importer or the manufacturer. It is the primary document to demonstrate compliance with all requirements listed under the Ecodesign Directive.

Here is an overview of the information that must be included in the DoC:

1. Product identification number and information

2. A description of the model sufficient for its unambiguous identification

3. Importers or manufacturers’ contact info

4. List of applicable directives and regulations

5. List of relevant harmonized standards

6. Place and date of issuing the DoC

Note that there could be more than one directives or regulations that apply to the same product, such as the Low Voltage Directive and the EMC directive. In that case, importers shall ensure other relevant regulations are listed on the DoC as well.

User Manual

A user manual is essential for electrical products covered by the Ecodesign Directive. Importers and manufacturers shall create the user manual and include information such as:

1. Product installation or initialization

2. Product and its component details

3. Safety instructions and potential hazards

4. Instructions on how to use the product

5. Instructions on how to recharge and/or refill the product (if any)

6. Instructions on how to correctly dispose of the devices

Note: It’s also a common practice to include all applicable compliance marks (e.g CE mark, WEEE mark, Energy label) on the user manual.

Technical File

The technical file is somehow similar to the product specification. It shall provide a detailed description of the product and demonstrate compliance with the relevant requirements.

Here is some information that shall be included in the technical file:

1. Bill of materials (including product components)

2. Design drawings

3. Label files

4. Packaging files

5. List of applied standards and directives (e.g. Ecodesign and RoHS)

6. Test reports

7. QC reports

8. Risk assessment

Lab Test Report

Importers and manufacturers must conduct relevant lab testing to demonstrate compliance with relevant energy efficiency requirements. Also, they shall attach the relevant test reports to the technical file.

Labeling Requirements

Energy Label

The Energy Labelling Regulation is complementary to the Ecodesign Directive, and, as for the Directive, is a general framework that includes several sub-regulation, each one focusing on a different category of regulated products.

As such, for most household energy-related products such as dishwashers, air conditioners, lamps, and refrigerators, importers and manufacturers must follow the relevant energy labeling regulations, and affix a compliant energy labeling on the products and/or its packaging.

Energy Label Generator

The EU provides an online tool called Energy Label Generator, which allows you to generate your own energy label after you enter the following information:

• Supplier information
• Energy efficiency class
• Energy consumption in kWh per year
• Other information that might be different according to the product category

Below we provide some examples of energy labels information.

Electrical lamps

There is a specific regulation that covers several types of lamps such as filament lamps, fluorescent lamps, LED lamps, and high-intensity discharge lamps. The energy label shall include the following information:

• Supplier’s name or trademark
• Supplier’s model identifier
• Energy efficiency class (A++ to E class)
• Weighted energy consumption

In the image, you can see an example of an energy label that contains the following information:

• Company name: ABC LTD
• SKU: A_547
• Energy efficiency class: A++
• Energy consumption: 100 kWh per 1,000 hours

Vacuum cleaners

Importers and manufacturers shall determine the energy efficiency class, cleaning performance class, dust re-emission of the vacuum cleaner. Then create an energy label include information such as:

• Supplier’s information
• Energy efficiency class (A+++ to G class)
• Dust re-emission class (A to G class)
• Cleaning performance class (A to G class)
• Average annual energy consumption
• Sound power levels

TVs

Manufacturers and importers shall also determine more index and include on the energy labeling.

Notice that the energy labeling requirement is applicable for television sets or television monitors. Here is an overview of the energy labeling requirements:

• Supplier’s name
• Supplier’s model identifier
• Energy efficiency class (A+++ to G class)
• Energy efficiency index
• Annual on-mode energy consumption
• Visible screen diagonal

CE Marking

The Ecodesign Directive is a CE marking directive and, as such, requires manufacturers or importers to affix the CE marking on the product, the packaging, and the user manual. The CE marking shall be visible and legible to declare that the products are compliant with all relevant requirements.

CE label file

It is important to instruct your manufacturers about the CE marking requirement before mass production. To ensure it’s in the correct format, we suggest that importers shall provide the CE marking file preferably in .ai or .eps, and provide the followings:

• Dimension (at least 5mm for height)
• Location
• Color
• Print type

Product Traceability

CE directives require product traceability in order to facilitate efficient market surveillance. Therefore, importers and manufacturers shall affix a permanent and visible code to the product and its packaging. The code might include information such as:

• Product SKU
• Manufacturers contact
• Manufacturing date and location

Lab Testing

Assessing the compliance of complex products such as energy-related products requires advanced equipment and knowledge. Therefore, we suggest you get in touch with a reliable lab testing to get a quotation for the relevant lab testing.

Here some labs that offer this service:

• Intertek
• Eurofins
• TÜV SÜD
• SGS

Compliance Risks

Home appliances, displays, LED lighting, and other electronic products are not by default designed to comply with Ecodesign Directive. Electrnics products manufactured for other markets, such as the United States or China, may not be compliant with the more stringent EU energy efficiency requirements. Further, there are plenty of non-compliant products being sold online.

This is partly because manufacturers consider it unnecessary to design products for other markets, according to stricter EU rules. That said, there are also plenty of manufacturers that don’t understand or are unaware of the Ecodesign Directive and relevant EN standards.

Likewise, don’t assume that a factory in Shenzhen or Ho Chi Miny City keeps tracking of the energy labeling either.

As an EU importers, it’s always up to you to verify that the product is designed for compliance, and provide the required label files. Luckily, that’s made simple thanks to the energy label creation tool.