A spotlight on Energy-related Products – a continued focus

This article was co-authored by Miran Bahra, Trainee Solicitor, London.

The increased regulation of Energy-related Products (ErP), energy-using or energy-saving products that “have an impact on energy consumption during use”, continues to play a central role in supporting the UK’s commitment to reach its environmental targets, including its 2050 net zero target.

The aim of recent UK’s ErP policy, which comprises of both regulatory and voluntary elements, is to increase the uptake of energy and resource efficient products.

Ecodesign and energy labelling

Increased emphasis on ecodesign and energy labelling, to provide consumers information regarding a product’s energy efficiency or energy consumption performance, is an important part of the UK’s overarching ErP policy.

In June 2020, the Department for Business, Energy & Industrial Strategy (BEIS), as overseeing regulator for product safety, issued a call for evidence on the effectiveness of the UK’s ecodesign and energy labelling policies in achieving greater environmental savings. This call for evidence sought views on:

  • How to improve the efficacy of ecodesign and energy labelling policy to accomplish greater carbon, energy and resource savings.
  • Whether improved minimum energy performance standards and requirements could be established for certain products.
  • Whether there are any future policy measures that could support in increasing the uptake of energy efficient products.

The response to this call for evidence was published on 10 March 2021 and highlighted key themes amongst respondents. This included simplifying energy labelling, amplifying the product information required online to assist consumer choice, improving the effectiveness of market surveillance and implementing policy levers, such as fiscal incentives to increase the purchasing of energy efficient products. The response further announced that the UK’s policy framework for ErPs would be published in late 2021.

In conjunction with the call for evidence, in September 2020, BEIS also consulted on the draft Ecodesign and Energy Labelling Regulations 2021 to implement the changes agreed by the UK pre-Brexit. Initial changes to the legislation were made on 18 June 2021.

Initial changes

  • Update existing ecodesign requirements to increase the minimum energy performance and set the material efficiency of electric motors, household washing machines and washer-dryers, household dishwashers, household refrigeration and electronic displays.
  • Introduce ecodesign requirements that set minimum energy performance and material efficiency standards for welding equipment and commercial refrigeration for the first time.
  • Introduce energy labelling requirements for commercial refrigeration to enable consumers to discern the most energy efficient products on the market.

On 27 October 2021, further changes were introduced to the Ecodesign for Energy-related Products and Energy Information (Amendment) Regulations 2021 (the Regulations) to bring the UK’s legislation in line with the EU regime.

The Regulations amendments

  • Insofar as they apply, the Ecodesign for Energy-Related Products Regulations 2010 and the Energy Information Regulations 2011 to update the schedules which list energy product-specific measures to enable enforcement action by Market Surveillance Authorities, such as the Office for Public Safety and Standards.
  • Various ecodesign and energy labelling legislation to reflect the changes made by the European Commission on equivalent EU regulations. This will ensure consistency in standards and compliance procedures for manufacturers at both UK and EU level.

The government’s policy framework on ErP

On 5 November 2021, BEIS published their ErP policy framework, as announced in the response to the call for evidence, which sets out how the government will “drive products to use less energy, resources and materials, and how this will contribute to achieving net zero”. As part of this, BEIS established key objectives and principles which will drive future policy for ErPs.


  • Reducing in-use emissions across the product lifecycle: transforming how products use energy to reduce consumption in households and commercial outlets and the overall cost of decarbonisation – particularly with buildings being the UK’s second largest source of greenhouse emissions after transport.
  • Attaining benefits for consumers, companies and the public sector: exploiting the potential to reduce lifetime running costs through improved efficiency and extending the lifespan of products for the benefit of the end-user. As detailed in the Heat and Buildings Strategy, the government will also consider options to move energy levies away from electricity to gas.
  • Building a circular economy: a move towards products that are “more repairable, durable and recyclable” to reduce replacement rates and waste. Thus decreasing the environmental impact and maximising the retention of value in the economy.
  • Driving innovation: focusing on optimising smart technology and creating incentives for manufacturers to invest in the research and development of smarter products. Future ErP policy will bring attention to the savings potential and environmental benefits of purchasing energy efficient products.


  • Open and responsive policy: future policy will be developed in conjunction with consumer and industry stakeholders.
  • Building and preparing markets and infrastructure: in response to the government’s ambition to “double resource productivity by 2050”, manufacturers will need to review existing business models to meet consumers’ needs in the most environmentally friendly manner. In addition, the government will ensure that enough time is allowed for markets to adequately adapt to new regulatory and voluntary measures imposed by future ErP policy.
  • Enhancing consumer experience: supporting a positive consumer experience by minimising disruption in the consumer journey and improving product labelling to increase awareness of energy efficient products.
  • Better regulation: ensuring that regulatory measures are “proportionate, targeted, fair and transparent”. In particular, by only implementing regulation after having considered alternative measures and minimising unnecessary burdens on companies.

The above ErP policy framework will be set for consultation in 2022, with the eventual implementation of ErP policies from 2025. We will continue to monitor this position.


ErPs account for approximately 55% of the UK’s total energy (non-transport) use and 19% of the UK’s total greenhouse gas emissions. This paired with the government’s net zero target has brought the use of ErPs into even more focus.

Companies should be attuned to the current and future ErP policies which could transform how products are manufactured and brought onto the UK markets. In particular, companies should revise existing supply chains and business models to consider whether, for example, more robust and recyclable materials can be used in the production of products, how products can be created or altered to reduce energy consumption and how to increase the lifespan of products going forward.

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