EU Product Database for Energy Labelling (EPREL) Implementing Act

Read the joint industry statement of nine industry associations impacted by the foreseen Implementing Act for the EU Product Database for Energy Labelling (EPREL).   

Dear Mr Hodson,

APPLiA has coordinated a joint industry statement with regard to the foreseen Implementing Act for the EU Product Database for Energy Labelling (EPREL) as specified in in Regulation 2017/1369. The nine signatories cover the range of product groups impacted by the introduction of the database in January 2019. This strong support gives the concerns much emphasis.

The EU Product Database for Energy Labelling (EPREL) needs to meet the objectives stated in Regulation 2017/1369. It has to be set up so that the burden for suppliers is minimised (Art 12.7a), data security is ensured (Art 12.9), terms and conditions - including the scope - are known in advance, and a fair and level playing field is safeguarded by identifying free-riders (Recital 6). In addition, it has to ensure that it is fit for purpose for all product groups and it takes into account their various characteristics.

The industries concerned by the product groups to be registered in the EPREL Database would like to reiterate their concerns regarding the setup of the Database and the need to ensure operational and technical certainty for industry.

As we already mentioned in the Joint Industry position papers of November 2017 and February 2018, the deadline for the Database to be operational, while meeting its objectives of security and practicality, is short.
Running the Database according to the legal requirements from January 2019 onwards, is a major technical challenge. It needs the agreed definition of an interface between suppliers (the data source) and the Commission (responsible for the Database and its operational details). This interface definition includes several operational aspects, including the “data exchange model” (currently called EPREL 1.01), the transfer protocol, the encryption standard, the registration process, etc. We have been actively working to support the Commission experts on the development of these activities.
Due to the mass of models and data involved, it is not feasible for most producers to handle the data upload manually (this database is not similar to the e.g. EU F-gas portal in that respect). Producers need to set up and change their IT systems, which takes time and resources. Thus, many operational issues need to be fixed as soon as possible, pilot testing and practice may show that minor technical adaptions might be necessary, possibly even after November 2018.

In this tight timescale situation, industry fears that the envisaged Implementing Act1 endangers the functioning of the Database, particularly if the Act is scheduled for publication already in November 2018.

Keeping in mind that the framework legislation 2017/1369 does not specify that the Implementing Act enters into force before the Database is operational, industry calls for the Commission to focus on operational and technical certainty and therefore proposes, to ensure the effectiveness of any Implementing Act, that it is delayed until the Database is running sufficiently. Industry would appreciate if these calls for operations and technical certainty are taken into account and if the respective timing issues are clarified soon. All sectors are committed to work together with the Commission to have EPREL working with the necessary practicality and security level by the end
of 2018. In the same token, we are committed to have, at a later stage, an Implementing Act that will really bring additional benefits to the process. We would like to emphasise that close collaboration and open information exchange is a necessary precondition to meet this objective.

We remain at your disposal should you have any questions and would like to request a meeting to discuss this issue further at your convenience.

Yours sincerely, 

Paolo Falcioni, Director General
APPLiA – Home Appliance Europe

Cecilia Bonefeld-Dahl, Director General

Federica Sabbati, Secretary General
European Heating Industry (EHI)

Thomas Nowak, Secretary General
European Heat Pump Association (EHPA)

Andrea Voigt, Director General
European Partnership for Energy
and the Environment (EPEE)

Dr. Peter Hug, Managing Director
EUnited Cleaning

Felix Van Eyken, Secretary General
Eurovent Association

Russell Patten, Secretary General
European Ventilation Industry Association

Ourania Georgoutsakou, Secretary-General
Lighting Europe

Download the joint letter from here