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Great Britain energy labelling: suppliers’ and dealers’ duties, product scope, advertising/rescaling rules and enforcement under ELR 2017 and the Energy Information Regulations

Practice notes
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Practice Note

This Practice Note outlines the duties of suppliers and dealers in Great Britain (GB) under the ecodesign framework, with particular emphasis on product energy labelling. Dealers’ obligations within the ecodesign regime are largely confined to labelling, whereas suppliers face a broader set of requirements, briefly touched on below; however, the principal focus here is the supplier obligations concerning energy labels. Note that distinct obligations may apply in Northern Ireland.

The key point of reference for the labelling duties of suppliers and dealers is Assimilated Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 establishing the energy labelling framework and repealing Directive 2010/30/EU, known in GB as the Energy Labelling Regulation 2017 (ELR 2017).

  • Supplier: ELR 2017, article 2(14) defines this as a manufacturer established in GB, the authorised representative of a manufacturer not established in GB, or an importer, who places a product on the market.
  • Dealer: ELR 2017, article 2(13) defines this as a retailer or any other natural or legal person offering for sale, hire, or hire purchase, or displaying products to customers or installers in the course of a commercial activity, whether or not in...
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James Jolly
James Jolly

James Jolly is an associate in the Regulatory and Commercial Dispute Resolution team at Penningtons Manches Cooper LLP. He advises both UK and international clients on a range of issues including sustainability, product recalls, and product safety, marking and labelling. James also acts in commercial disputes and professional negligence claims.  Prior to qualifying as a solicitor, James worked in the Public Sector team at Thomson Reuters Practical Law, producing content relating to housing, education, procurement and environmental issues....

John Doherty
John Doherty

John Doherty is a Partner in the Regulatory and Commercial Dispute Resolution team at Penningtons Manches Cooper LLP. He advises UK and international clients on a range of issues, including: product safety / liability; product recalls; marking; labelling; environmental sustainability; product recalls and advertising.  He also acts in commercial disputes and counsels on: conflicts of laws / jurisdiction; Bribery and corruption; and contentious aspects of Competition law compliance. ...

Web page updated on 21/05/2026

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