Ecodesign and Energy Labeling: More Stringent Rules with Electronics

by Elise Saade 08 Jul. 2020

More stringent ecodesign and energy labeling rules will apply to electronics as of next year in the European Union and we can expect similar rules for other products in a near future.

Europe is continuing its efforts in embracing principles of sustainability and recently announced that it will propose a new Ecodesign framework that would be applicable to the broadest possible range of products. These rules will emphasize the recyclability of products and the availability of spare parts on the market awhile impacting companies through the entire product life-cycle from the design phase until the end of life. Awaiting such rules to develop for textiles, furniture and chemicals, the European Commission has adopted more stringent labeling and ecodesign requirements for electronics that will enter into force in a staged approach beginning next year. Companies can learn from these new rules and start implementing strategies for compliance and future product design.

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A NEW ecodesign FRAMEWORK IN europe

EU’s legislative framework including sustainability currently consists of the Ecodesign Framework Directive, the Energy Labeling Framework Directive and implementing regulations on ecodesign and ecolabeling.

The Ecodesign Framework Directive sets a framework requiring manufacturers of energy-related products to improve the environmental performance of their products. Whereas, the Energy Labeling Framework Regulation compliments the ecodesign framework directive by enabling end-consumers to identify the better-performing energy-related products. The Ecodesign and Energy Labeling Package was adopted in 2019 to modernize the framework and ensure it continues to deliver.


THE Ecodesign package: 10 implementing regulationS

Recently, 10 ecodesign implementing regulations, setting out resource and energy efficiency requirements (Ecodesign Package), were published in the official journal. The Ecodesign Package covers the following product groups:

  • Dishwashers (revised);
  • Washing machines; (revised);
  • Refrigerators (revised);
  • Electronic displays (including televisions) (revised);
  • Light sources and separate control gears (revised);
  • External power suppliers (revised);
  • Electric motors (revised);
  • Refrigerators with a direct sales function (e.g. fridges in supermarkets, vending machines for cold drinks) (new);
  • Power transformers (revised); and
  • Welding equipment (new).

It should be noted that 8 of these product groups are getting revised requirements, whereas refrigerators with a direct sales function and welding equipment are being regulated for the first time.

Resource Efficiency Requirements

Resource efficiency requirements will make it easier for consumers to have certain products repaired instead of having to buy new ones and would therefore reduce waste. The availability of spare parts, that can be easily replaced, and access to repair and maintenance information for professional repairers are introduced for several product-types including dishwashers, electronic displays, light sources and separate control gears. The goal is to:

  • improve the design of certain products, so that key components can be easily repaired or replaced,
  • make spare parts available to consumers, retailers and repairers for 7 to 10 years,
  • and give independent repairers access to technical information such as the wiring diagrams.


Regulation pertaining to ecodesign requirements for dishwashers focuses on recyclebility by introducing requirements for dismantling operations at the end of the product’s life cycle. As such, manufacturers will have to ensure that household washing machines and household washer-dryers are designed in such a way that the materials and components referred to in Annex VII to Directive 2012/19/EU can be removed without the use of any tool which is not readily available for purchase.

Light sources and separate control gears

The Regulation pertaining to ecodesign requirements for light sources and separate control gears mandates that removal of these appliances occur without causing permanent damage, such that Member State market surveillance authorities can verify authenticity of these products.

For light source containing products, instructions must be available on request for how light sources and separate control gears can be removed for verification without permanent damage.

Electronic displays

Repair and re-use information and documentation.

According to the Regulation pertaining to ecodesign requirements for electronic displays, the process for professional repairers to register for access to information must be indicated on the manufacturer's or importer's website or any other equivalent means of information.

Professional repairers will also be required to demonstrate that they:

  • comply with the applicable regulations for repairers of electrical and electronic equipment (EEE) in the Member State where they operate;
  • are covered by relevant insurance, covering liabilities resulting from their activity.

Halogenated flame retardants

In addition, the regulation prohibits the use of halogenated flame retardants in the enclosures and stands of electronic displays.


Even though the use of cadmium in EEE is restricted under Directive 2011/65/EU, RoHS 2, its use in electronic displays remains exempted from this restriction for a limited time. However, the regulation requires that manufacturers provide a specific marking on displays that contain cadmium.

Energy Efficiency Requirements

Commercial refrigeration

According to the Regulation pertaining to eco-design requirements for refrigerating appliances with a direct sales function, the energy efficiency index (EEI) of supermarket fridges and freezers will have to stay below:

  • 80% (as of 21 March 2021) and 50% (as of 1 September 2023) for ice-cream freezers;
  • or 100% (as of 21 March 2021) and 80% (as of 1 September 2023) for all other refrigerating appliances.

Electronic displays

According to the Regulation pertaining to eco-design requirements for electronic displays, the EEI for electronic displays will have to stay below:

  • 0,09: (as of 1 March 2021) for electronics with resolution up to 2 138 400 pixels and as of 1 March 2023 for electronics with resolution above 2 138 400 pixels and up to 8 294 400 pixels and electronics with resolution above 8 294 400 pixels;
  • 1,10: (as of 1 March 2021) for electronics with resolution above 2 138 400 pixels and up to 8 294 400 pixels;
  • 0,75: (as of 1 March 2023) for electronics with resolution up to 2 138 400 pixels.

Household dishwashers

According to the Regulation pertaining to ecodesign requirements for household dishwashers, the EEI for household dishwashers will have to stay below:

  • 63: (as of 1 March 2021);
  • 56: (as of 1 March 2024).

External powers supplies (EPS)

The Regulation pertaining to eco-design requirements for EPS covers a larger range of adapters, improves their efficiency when charging, and reduces their power demand when they are plugged in but not charging.

Welding equipment

According to the Regulation pertaining to ecodesign requirements for welding equipment, the power source efficiency must not be lower than the values set out in Table 1 of its Annex starting from 1 January 2023.


The energy performance of power transformers is being also improved under the Regulation laying down ecodesign requirements for transformers. Similar energy performance requirements will also apply to other product-types such as light sources and separate control gears.

Energy Labeling Package

On 11 March 2019, Europe adopted a final format and visual identity of the new energy efficiency labels for 6 product groups (Energy labeling Package).

According to the Energy labeling Package, "resealed" labels will be visible for European consumers in physical stores and on-line as of 1 March 2021 and will apply to the following product groups:

  • dishwashers;
  • washing machines and washer-driers;
  • refrigerators, including wine storage fridges;
  • lamps;
  • and electronic displays, including televisions monitors and digital signage displays.

A new label would be visible on commercial refrigerating appliances as well. Depending on the product, the energy labels will display electricity consumption, along with other energy and non-energy information. The labels will include intuitive pictograms and detailed information such as water used per washing cycle, storage capacity and noise emissions.


WaSTING LESS ENERGY AND WATER thanks to ecodesign and energy LABELING

The European Commission estimates that this package of measures will deliver 167 TWh of final energy savings per year by 2030. These savings correspond to a reduction of over 46 million tonnes of CO2 equivalent and an average savings of 150 EUR per households each year.

European manufacturers and companies producing electronic products destined for the European market will have to produce electrical goods that do the same job while wasting less energy and water. In addition, manufacturers will have to make products more easily repairable and recyclable by design and ensure that spare parts are made available within 15 working days for years after the product was sold.


Are you planning for your next-generation waste policy? Or simply implementing circular economy into your business?

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These new requirements are a forerunner and we can expect similar requirements for other product categories in Europe, as well as around the world. If you are interested in a helping hand to track such new developments and receive easy-to-understand information on upcoming changes worldwide, please contact us to inquire about our Product Regulatory Forecaster services.