Mag. Balazs Esztegar LL.M.
Attorney-at-law Vienna

Piaristengasse 41/10
1080 Vienna, Austria
Tel. +43 1 997 4102
Fax +43 1 997 4102-99

New labeling requirements for webshop operators

From 01.01.2015 of new labeling requirements for webshop operators will be in force. Dealers who sell products from the affected product groups in their online stores have to present the energy-efficiency label right on the product site.

Commission Delegated Regulation (EU) No 518/2014 establishes new obligations for producers and distributors that manufacture or distribute products of the following groups:

  • household dishwashers
  • household refrigerators
  • household washing machines
  • televisions
  • air conditioners
  • household laundry dryers
  • electric lamps and lighting
  • vacuum cleaner
  • space heaters (and similar)
  • water heaters and boilers

For new models and updated existing models, which are brought in traffic with a new model identifier after 1st January 2015, suppliers must provide an electronic label  and an electronic product data sheet, whose content and layout is regulated for each product category. This can be done by offering a download possibility on the website.

Retailers selling one of the above products on the Internet have to use this electronic label and place it "near the product price" on the website. A link to the label is permitted, the link must however be presented in the form of an arrow in the color of the product's energy efficiency class. In addition, the arrow has to indicate the energy efficiency class as well. In a so-called "nested display" there are even more aspects to consider.

Similarly, the electronic product data sheet has to be provided near the price of the product in the online shop.

Failure to implement these rules can be considered as distorting competition by competitors and opens up the possibility of a demand letter.