Joint Industry Comments on the Database for Energy Labelling
The EU Product Database for Energy Labelling 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 welcome the opportunity to comment on the documents published by the European Commission on 19 December. The comments below follow on from our joint position paper of November 2017.