JBCE Position Paper on the Revision of the Energy Labelling Reguration
On 15 October 2026, JBCE submitted its position paper on the Revision of the Energy Labelling Reguration.
JBCE appreciates the opportunity to provide feedback on the European Commission’s proposal amending Regulation (EU) 2017/1369 and Regulation (EU) 2020/740 as regards simplification and better use of digital options for energy and tyre labelling.
JBCE welcomes the European Commission’s objective of simplifying existing requirements, reducing administrative burdens for businesses, and making better use of digital solutions such as the EPREL database. At the same time, the revised framework should provide sufficient legal certainty and practical implementation time for economic operators. In particular, new digital and labelling requirements should avoid duplication with other Union legislation, minimise unnecessary administrative burdens, and include appropriate procedural safeguards where measures may have significant commercial consequences.
Against this background, JBCE would like to highlight the following points and make recommendations on specific provisions concerning energy labelling.
- Avoiding proliferation of QR codes and clarifying implementation across product groups
Prevent confusion caused by multiple QR codes on products and clarify how and when the default printed-label requirement will be removed across product groups (Article 1(2)(a)).
- Providing greater flexibility regarding the language of authorised representative mandates
Allow authorised representative mandates to be uploaded in any official EU language to avoid unnecessary translation burdens (Article 1(3)(b)).
- Ensuring appropriate procedural safeguards before restricting product visibility in EPREL
Clarify that such measures should only be taken once non-compliance has been sufficiently established (Article 1(5))
- Providing sufficient preparation time for label rescaling
Extend the transition period for label rescaling from four to six months to provide sufficient preparation time for suppliers and dealers (Article 1(7)(b)).