On 26 June 2026, the European Commission published an impact assessment accompanying a proposal to amend the Energy Labelling Regulation (ELR) and Tyre Labelling Regulation (TLR), aiming to simplify rules and expand digital options for labels. The changes would affect suppliers, dealers, and market surveillance authorities across the EU and EEA, reducing administrative burdens by leveraging the EPREL database's digital capabilities.
The proposal targets two main problems. First, suppliers face disproportionate obligations due to duplication between physical label delivery and EPREL registration: an estimated 375 million products (excluding light sources and tyres) required printed labels in 2023, many of which are never seen by customers before purchase. Second, current rules lack flexibility for diverse products and distribution chains, and the ELR cannot require labels or QR codes directly affixed to products, limiting paper waste reduction.
The EPREL database, containing approximately 2 million product models, already generates downloadable labels and product information sheets in all EU languages and provides open APIs for online retailers, but these digital features are underutilised. Stakeholder feedback from a December 2025 "reality check" meeting highlighted the need for more flexible label delivery and display rules.
The legal basis for the amendments is the fully harmonised single market provisions of the ELR (Regulation (EU) 2017/1369) and TLR (Regulation (EU) 2020/740). The Commission's bottom line is to reduce administrative burdens by eliminating redundant physical label requirements and introducing flexibility for product-specific labelling, while maintaining consumer access to energy efficiency information.
Stakeholder impact Suppliers would benefit from reduced compliance costs by avoiding printing and affixing physical labels for products where digital alternatives suffice. Dealers and online retailers would gain flexibility in displaying labels, potentially lowering operational costs. Market surveillance authorities would need to adapt to digital verification methods, requiring new skills and tools. Consumers would retain access to energy efficiency information via QR codes or digital labels, though those without internet access may face barriers.
Trade-offs The proposal balances administrative simplification against potential consumer access issues. While digital options reduce paper waste and costs, they risk excluding consumers with limited digital literacy or internet access. The Commission argues that physical labels remain available where necessary, but the shift to digital may disproportionately affect vulnerable groups.
Institutional follow-up The proposal now passes to the European Parliament and the Council for legislative scrutiny. The impact assessment will inform negotiations, with stakeholders expected to weigh in on the scope of digital mandates and consumer safeguards.