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 all product groups and it takes into account their various characteristics.

To achieve these goals and to ensure a proper functioning of the Database by January 2019, the industry signatories of this joint paper would like to highlight the following specific needs.