What are the ecodesign rules?
The ecodesign rules require certain products that are placed on the market in the UK to adhere to specific energy-efficiency and related standards. The applicable standards vary by product, but often cover areas such as:
limits on energy use or efficiency
requirements that manufacturers make spare parts for appliances and facilitate repairs by, for example, providing these spare parts and repair information to professional repairers (ie the ‘Right to Repair rules’)
mandated design features to encourage and facilitate reduced energy usage
Overall, the rules aim to make the appliances within their scope longer-lasting and more environmentally friendly and resource-efficient.
It’s usually the manufacturer, an importer, or an authorised representative of a product that’s responsible for compliance with the ecodesign rules.
What do the ecodesign rules require?
The rules require that applicable products:
meet the relevant set of standards applicable to the type of product (ie those contained in the relevant ‘implementing measure’, which will be a specific piece of legislation)
have supporting technical documentation that demonstrates the product’s compliance with the relevant standards
have a Declaration of Conformity, and
display the correct conformity marking. For products placed on the market in:
Each of these requirements is explained in more detail below.
Which standards do the ecodesign rules require products to meet?
Exactly which set of standards is applicable to a particular type of product is set out in Schedule 1 of The Ecodesign for Energy-Related Products Regulations 2010, by reference to a relevant piece of legislation.
For example, a household dishwasher should meet the standards set out in The Ecodesign for Energy-Related Products and Energy Information Regulations 2021. These Regulations require that household dishwashers, for example, provide a specific ‘eco programme’; meet certain power consumption standards; have particular automatic switch-off features; and have a certain degree of availability of spare parts.
Repair standards often require that spare parts are made available to professional repairers, and repairs should generally be made via such professionals to avoid voiding warranties.
What technical documentation is required?
A product must have associated technical documentation. This documentation should demonstrate how the product complies with the relevant set of standards. It should cover, for example:
environmental design aspects of the product
descriptions of how standards have been met
measurements of and details of conformity to the relevant standards
This documentation should be kept for at least 10 years from the date the product was last manufactured.
What is a Declaration of Conformity?
A Declaration of Conformity is a written document that identifies a product and attests to its adherence to the relevant ecodesign standards.
What are conformity markings?
Conformity markings are icons placed on a product to enable it to be identified (eg by consumers) as adherent to certain standards - in this case, the relevant ecodesign standards.
The UK and the EU previously both used the CE marking to demonstrate compliance. Since Brexit, products sold in the UK necessitate a mixture of the CE marking or the equivalent new UKCA marking. The UKCA marking is being phased in as an alternative for some products, while others can still use the CE marking indefinitely.
Which products do the ecodesign rules apply to?
The rules apply to a wide range of products. Some of the key products include:
ovens and hobs
external power suppliers
electronic displays (eg TVs)
The rules often only apply to domestic versions of appliances, but some standards apply to commercial appliances too.
For a full list of applicable products, see Schedule 1 Chapter 4 of The Ecodesign for Energy-Related Products Regulations 2010.
Energy labelling requirements
Some products must also abide by the energy information requirements set by The Energy Information Regulations 2011.
Applicable products must have energy labels on (or supplied with) them and displayed when they’re sold. These should show the product’s energy efficiency rating, indicated by a letter (eg from A to G). This should be supported by additional information, like a product information sheet detailing energy use data.
These requirements apply to many common household products, such as dishwashers, space heaters, lighting devices, ovens, air conditioners and fans, refrigerators, and washing machines.
For more information, read the government’s guidance on the energy information regulations.
What’s next for ecodesign?
With climate change challenges compounding, the current ecodesign rules are unlikely to be adequate for long - it’s debatable whether they even are now. It’s very likely that the standards involved will be raised as both sustainability needs and technical capabilities expand.
If you manufacture a product that’s likely to be covered by the ecodesign rules, or you’re responsible for placing one on the market in the UK, you can Ask a lawyer if you have any questions or concerns about compliance.