The EPREL database must contain complete technical documentation for the product. This mainly includes the product information sheet, the energy label, and laboratory test reports. In addition, the declared parameters must be based on tests carried out in accordance with applicable standards and must include a description of the measurement and calculation methods used. It is also necessary to confirm compliance with ecodesign requirements. All data should be consistent, as market surveillance authorities use it to verify compliance with European Union regulations.
What is EPREL?
EPREL (European Product Database for Energy Labelling) is an EU database of products covered by energy labelling, managed by the European Commission.
It is a public register containing data on household appliances, light sources, air conditioners, and other devices. It has been operating since 1 January 2019. Registration in EPREL is mandatory for manufacturers and importers placing products on the EU market.
The database allows consumers to access energy labels and product information sheets. It also includes a closed section for market surveillance authorities.
Currently, several hundred thousand LED light sources are registered in EPREL, with most of them in energy classes F, G, and E.
Obligation to submit technical documentation
According to Commission Regulation (EU) 2019/2015, every manufacturer or importer placing a light source on the market, either as a standalone product or as part of another product, must upload complete technical documentation to EPREL. Therefore, already at the product preparation stage, all required data and documents should be properly collected.
In practice, documentation is often incomplete or contains errors. This is usually not due to bad intentions, but to organizational and technical problems and incorrect interpretation of regulations. In addition, the lack of proper internal procedures increases the risk of mistakes during EPREL registration.
Most common causes of documentation errors
1. Lack of verification at the registration stage
EPREL works on a self-declaration basis. It checks whether fields are filled in, but does not verify the accuracy of the data. Verification takes place only during market surveillance activities or laboratory tests.
2. Copying marketing data
Information is often copied from catalogues, websites, or sales presentations instead of test reports. Such data usually does not meet legal requirements.
3. Time pressure
Products must be registered before being placed on the market. In practice, companies often do this without full documentation.
4. Lack of knowledge or incorrect interpretation of regulations
Not all businesses correctly understand the requirements for testing, standards, and calculation methods.
5. Incomplete documentation from non-EU suppliers
Manufacturers often receive only shortened reports that do not meet European requirements.
Deliberate underreporting or overreporting of parameters
There are cases of intentional manipulation of technical data to obtain a better energy class or meet minimum market requirements.
Such actions violate EU law and may result in:
- financial penalties,
- withdrawal of the product from the market,
- obligation to correct data in EPREL.
Requirements for testing and documentation
Regulation 2019/2015, Annex VI, specifies in detail the scope of technical documentation that must be submitted to EPREL.
Declared product parameters must be based on real laboratory tests carried out in accordance with applicable standards. They must not be based on a single sample. Tests must cover a representative product sample to obtain reliable average results.
In practice, different production batches, and even individual units within one batch, may show significant differences in parameters. This highlights the importance of proper testing and complete technical documentation.
What documentation should be included in the EPREL database?
Before entering data into EPREL, the manufacturer or importer should have the following documents and information prepared:
- Full product information sheet (Product Information Sheet)
- Laboratory test reports prepared according to applicable standards
- Test results based on a representative sample, not a single unit
- Description of measurement and calculation methods
- Documentation confirming compliance with ecodesign requirements
- Full product identification, including model, variants, and batch numbers
Having this documentation before registration significantly reduces the risk of errors, data corrections, and problems during inspections.
Problems with one-page documentation
A common practice is the use of so-called one-page documents that contain only basic measurement results, often obtained using an integrating sphere.
Such documents usually do not include:
- full product identification,
- description of test conditions,
- calculation methods,
- complete set of required parameters.
They are not sufficient for market surveillance authorities.
Relying on incomplete reports may lead to incorrect data in EPREL and registration of products that do not meet EU legal requirements.
Do you need support with EPREL registration?
If you are not sure whether your documentation meets all requirements, it is worth using professional verification before submitting your product. This allows for detailed analysis of test reports, verification of calculations, and assessment of compliance with ecodesign requirements. Preparing a complete EPREL documentation set significantly reduces the risk of corrections, delays, and possible sanctions.
The RCC team supports manufacturers and importers at every stage, from documentation verification and parameter assessment to product preparation and registration in EPREL. This ensures that the entire process runs more smoothly and in an organized way.
If you want to check your product before registration or need full support throughout the process, we invite you to review our offer and contact RCC experts.