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Ecodesign Directive 2009/125/EC of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products (1) Question on placing on the market and/or putting into service: Several stakeholders have inquired on the meaning of ''be placed on the market and/or put into service'', as used in Article 3 of the Ecodesign Directive and its implementing Regulations. Article 2 of the Directive defines ‘placing on the market’ as making a product available for the Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations Not legally binding. Last updated January 2023. This document will be regularly updated. 4 first time on the Community market with a view to its distribution or use within the Community, whether for reward or free of charge and irrespective of the selling technique and ‘putting into service’ as the first use of a product for its intended purpose by an end-user in the Community. While the term 'placing on the market' seems clear, the term 'putting into service' has led to confusing interpretations. (1) Answer on placing on the market and/or putting into service: The term "putting into service" is used, as the EU legislation also needs to cover products, which are "physically" never placed on the market, but installed directly at the end-user's place. The sentence "be placed on the market and/or put into service", creates the impression that placing on the market and putting into service are cumulative, i.e. that there are two different moments from when on a product has to comply, which is wrong. The way the concepts should be understood is that "placing on the market" (making a product available for the first time on the EU market) and "putting into service" (first use of a product for its intended purpose by an end-user in the EU) refer to two different 'moments' in the process of bringing a product to the market; compliance for the 'entry' into the market is required only once based either on the moment when the product is placed on the market or when it is put into service. Accordingly, the Article 3 of the Ecodesign Directive should be understood as ''products covered by implementing measures may be placed on the market or put into service, or both, only if they comply with those measures and bear the CE marking in accordance with Article 5.'' A product has to comply with the requirements for CE marking from the moment that it is placed on the market. Only where a product is "not placed on the market" in the literal meaning, the moment of compliance is the putting into service. Furthermore, the EU legislation is not retroactive. Products legally placed on the market can stay on the market (i.e. in the distribution chain) and still be sold even if the legislation changes in the meantime; products legally placed on the market can be sold to the end-user and can also be put into service even if the legislation has changed in the meantime. (2) Question on legal reference in EC declaration of conformity During inspection of declarations of conformity from various products that have to comply with the standby regulation No 1275/2008 the market surveillance authorities found that several of the producers outside the EU only declared conformity with the Directive 2005/32/EC or the recent version Directive 2009/125/EC. But the standby regulation 1275/2008 is not mentioned. Article 5 of Directive 2009/125/EC states: 1. Before a product covered by implementing measures is placed on the market/or put into service, a CE marking shall be affixed and a an EC declaration of conformity issued whereby the manufacturer or its authorized representative ensures and declares that the product complies with all relevant provisions of the applicable implementing measure. 2. The EC declaration of conformity shall contain the elements specified in Annex VI and shall refer to the appropriate implementing measure. Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations Not legally binding. Last updated January 2023. This document will be regularly updated. 5 Therefore the authority does not consider it sufficient just to declare that the product is in conformity with the Directive; the relevant implementing measures have to be specifically mentioned in the declaration. (2) Answer on legal reference in EC declaration of conformity The view is correct. Article 5 (3) of the Ecodesign Directive 2009/125/EC stipulates that the EC declaration of conformity shall refer to the appropriate implementing measure, in the present case to the Regulation No 1275/2008 on standby and off mode electric power consumption of electrical and electronic household and office equipment. (3) Question on due date of EC declaration of conformity From which point in time has the manufacturer the obligation to issue an EC declaration of conformity before placing a product on the market covered by an implementing measure? From the entry into force date or from the application date of the relevant implementing measure? (3) Answer on due date of EC declaration of conformity The manufacturer or his authorized representative has the obligation to issue an EC declaration of conformity (and providing the technical documentation and affixing a CE marking) before placing a product on the market and/or putting it into service from the first application date of the implementing measure that is relevant for the product. NB: For certain products (a) requirement(s) may only be set from the second or later application date of an implementing measure. In this case, the first application date is that second or later application date. NB: Other EU legislation may require EC declaration of conformity, technical documentation and affixing a CE marking for the same product. A common EC declaration of conformity and technical documentation is permissible.

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Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations




Frequently Asked Questions (FAQ) on the Ecodesign
Directive
2009/125/EC establishing a framework for the setting of
ecodesign requirements for energy-related products and
its Implementing Regulations

This Frequently Asked Questions (FAQ) document summarises questions and answers of
general interest regarding the Ecodesign Directive 2009/125/EC and its implementing
Regulations.

The answers provided reflect a common understanding between Commission services and the
Market Surveillance Authorities of Member States. The answers as such are not legally binding.
A binding interpretation of Community law is the sole competence of the European Court of
Justice.

These FAQ cannot go beyond or substitute for the requirements of the Ecodesign Directive or
its implementing Regulations. The Ecodesign Directive is addressed to the Member States and
must be transposed into national law according to Article 23. The Ecodesign Regulations
(implementing measures) are binding in their entirety and directly applicable in all Member
States.

Attention: some of the regulations referred to in this document were repealed in 2021, following
new regulations adopted in 2019. See here for all details:
https://ec.europa.eu/energy/topics/energy-efficiency/energy-efficient-products/listregulations-
product-groups-energy-efficient-products_en?redir=1


Table of Contents

Ecodesign Directive 2009/125/EC of 21 October 2009 establishing a framework for the setting of ecodesign
requirements for energy-related products ............................................................................................................ ........ 4

Commission Regulation (EC) No 642/2009 of 22 July 2009 implementing Directive 2005/32/EC of the
European Parliament and of the Council with regard to ecodesign requirements for televisions.................... 18

Commission Regulation (EC) No 641/2009 of 22 July 2009 implementing Directive 2005/32/EC of the
European Parliament and of the Council with regard to ecodesign requirements for glandless standalone
circulators and glandless circulators integrated in products
................................................................................... 21

Commission Regulation (EU) No 622/2012 of 11 July 2012 amending Regulation (EC) No 641/2009 with regard to
ecodesign requirements for glandless standalone circulators and glandless circulators integrated in
products (1) ................................................................................................................ .....................................................
21

Commission Regulation (EC) No 640/2009 of 22 July 2009 implementing Directive 2005/32/EC of the
European Parliament and of the Council with regard to ecodesign requirements for electric motors ............ 25

Commission Regulation (EC) No 643/2009 of 22 July 2009 implementing Directive 2005/32/EC of the
European Parliament and of the Council with regard to ecodesign requirements for household refrigerating appliances
........................................................................................................................................................................ 31
Commission Regulation (EC) No 278/2009 of 06 April 2009 implementing Directive 2005/32/EC of the European


Not legally binding. Last updated January 2023. This document will be regularly updated. 1

,Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations


Parliament and of the Council with regard to ecodesign requirements for no-load condition electric power
consumption and average active efficiency of external power supplies .................................... 34

Commission Regulation (EU) 2016/2281 of 30 November 2016 implementing Directive 2009/125/EC of the
European Parliament and of the Council establishing a framework for the setting of ecodesign requirements
for energy-related products, with regard to ecodesign requirements for air heating products,
cooling products, high temperature process chillers and fan coil units ................................................................ 38

Commission Regulation (EC) No 1275/2008 of 17 December 2008 implementing Directive 2005/32/EC of
the European Parliament and of the Council with regard to ecodesign requirements for standby and off mode
electric power consumption of electrical and electronic household and office equipment .................... 40

Commission Regulation (EU) No 801/2013 of 22 August 2013 amending Regulation (EC) No 1275/2008 with
regard to ecodesign requirements for standby, off mode electric power consumption of electrical and electronic
household and office equipment, and amending Regulation (EC) No 642/2009 with regard to ecodesign
requirements for televisions ...................................................................................................................... 40

Commission Regulation (EU) No 1015/2010 of 10 November 2010 implementing Directive 2009/125/EC of
the European Parliament and of the Council with regard to ecodesign requirements for household washing
machines ........................................................................................................................................... ...............
58

Commission Regulation (EU) No 1016/2010 of 10 November 2010 implementing Directive 2009/125/EC of
the European Parliament and of the Council with regard to ecodesign requirements for household dishwashers
..................................................................................................................................................................... 61

Commission Regulation (EC) No 327/2011 of 30 March 2011 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for fans driven by motors with
an electric input power between 125 W and 500 kW ..................................................................................... 62

Commission Regulation (EC) No 547/2012 of 25 June 2012 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for water pumps ................ 65

COMMISSION REGULATION (EU) 932/2012 of 3 October 2012 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to eco-design requirements for household
tumble driers ............................................................................................................... ....................................................
66

Commission Regulation (EU) No 206/2012 of 6 March 2012 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for air conditioners and
comfort fans
.................................................................................................................................................................... 67

Commission Regulation (EU) No 617/2013 of 26 June 2013 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for computers and computer
servers
..............................................................................................................................................................................
69

Commission Regulation (EC) No 666/2013 of 8 July 2013 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for vacuum cleaners ......... 70

Commission Regulation (EU) No 813/2013 of 2 August 2013 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for space heaters and
combination heaters
....................................................................................................................................................... 71

Commission Regulation (EU) No 814/2013 of 2 August 2013 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for water heaters and hot water
storage tanks.........................................................................................................................................................
77

Commission Regulation (EC) No 66/2014 of 14 January 2014 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for domestic ovens, hobs and



Not legally binding. Last updated January 2023. This document will be regularly updated. 2

,Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations


range hoods
.............................................................................................................................................................. 79
Commission Regulation (EC) No 548/2014 of 21 May 2014 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for small, medium and large
power transformers
........................................................................................................................................................ 85

COMMISSION REGULATION (EU) No 1253/2014 of 7 July 2014 implementing Directive 2009/125/EC of
the European Parliament and of the Council with regard to ecodesign requirements for ventilation units

.........................................................................................................................................................................................
.. 90

COMMISSION REGULATION (EU) 2015/1185 of 24 April 2015 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for solid fuel local space
heaters
............................................................................................................................................................................ .. 99

COMMISSION REGULATION (EU) 2015/1189 of 28 April 2015 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for solid fuel boilers 100

COMMISSION REGULATION (EU) 2015/1095 of 5 May 2015 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for professional refrigerated
storage cabinets, blast cabinets, condensing units and process chillers ........................................102

COMMISSION REGULATION (EU) 2015/1188 of 28 April 2015 implementing Directive 2009/125/EC of the
European Parliament and of the Council with regard to ecodesign requirements for local space heaters

....................................................................................................................................................................................... ..
104

COMMISSION REGULATION (EU) 2016/2281 of 30 November 2016 implementing Directive
2009/125/EC of the European Parliament and of the Council establishing a framework for the setting of
ecodesign requirements for energy-related products, with regard to ecodesign requirements for air heating
products, cooling products, high temperature process chillers and fan coil
units.............................................110

COMMISSION REGULATION (EU) 2019/424 of 15 March 2019 laying down ecodesign requirements for
servers and data storage products pursuant to Directive 2009/125/EC of the European Parliament and of the
Council and amending Commission Regulation (EU) No 617/2013
..................................................................113

COMMISSION REGULATION (EU) 2019/1782 of 1 October 2019 laying down ecodesign requirements for
external power supplies pursuant to Directive 2009/125/EC of the European Parliament and of the
Council and repealing Commission Regulation (EC) No 278/2009 ...................................................................115

COMMISSION REGULATION (EU) 2019/2020 of 1 October 2019 laying down ecodesign requirements for
light sources and separate control gears pursuant to Directive 2009/125/EC of the European Parliament and
of the Council and repealing Commission Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU)
No 1194/2012
...............................................................................................................................................................118



Ecodesign Directive 2009/125/EC of 21 October 2009 establishing a
framework for the setting of ecodesign requirements for energy-related
products

(1) Question on placing on the market and/or putting into service:

Several stakeholders have inquired on the meaning of ''be placed on the market and/or put into
service'', as used in Article 3 of the Ecodesign Directive and its implementing Regulations.
Article 2 of the Directive defines ‘placing on the market’ as making a product available for the


Not legally binding. Last updated January 2023. This document will be regularly updated. 3

, Frequently Asked Questions (FAQ) on the Ecodesign Directive and its Implementing Regulations


first time on the Community market with a view to its distribution or use within the
Community, whether for reward or free of charge and irrespective of the selling technique and
‘putting into service’ as the first use of a product for its intended purpose by an end-user in the
Community.

While the term 'placing on the market' seems clear, the term 'putting into service' has led to confusing
interpretations.

(1) Answer on placing on the market and/or putting into service:

The term "putting into service" is used, as the EU legislation also needs to cover products,
which are "physically" never placed on the market, but installed directly at the end-user's
place. The sentence "be placed on the market and/or put into service", creates the impression
that placing on the market and putting into service are cumulative, i.e. that there are two
different moments from when on a product has to comply, which is wrong.

The way the concepts should be understood is that "placing on the market" (making a product
available for the first time on the EU market) and "putting into service" (first use of a product
for its intended purpose by an end-user in the EU) refer to two different 'moments' in the
process of bringing a product to the market; compliance for the 'entry' into the market is
required only once based either on the moment when the product is placed on the market or
when it is put into service. Accordingly, the Article 3 of the Ecodesign Directive should be
understood as ''products covered by implementing measures may be placed on the market or
put into service, or both, only if they comply with those measures and bear the CE marking in
accordance with Article 5.''

A product has to comply with the requirements for CE marking from the moment that it is
placed on the market. Only where a product is "not placed on the market" in the literal
meaning, the moment of compliance is the putting into service.

Furthermore, the EU legislation is not retroactive. Products legally placed on the market can
stay on the market (i.e. in the distribution chain) and still be sold even if the legislation
changes in the meantime; products legally placed on the market can be sold to the end-user
and can also be put into service even if the legislation has changed in the meantime.

(2) Question on legal reference in EC declaration of conformity

During inspection of declarations of conformity from various products that have to comply
with the standby regulation No 1275/2008 the market surveillance authorities found that
several of the producers outside the EU only declared conformity with the Directive
2005/32/EC or the recent version Directive 2009/125/EC. But the standby regulation
1275/2008 is not mentioned.

Article 5 of Directive 2009/125/EC states:
1. Before a product covered by implementing measures is placed on the market/or put
into service, a CE marking shall be affixed and a an EC declaration of conformity issued
whereby the manufacturer or its authorized representative ensures and declares that the
product complies with all relevant provisions of the applicable implementing measure.
2. The EC declaration of conformity shall contain the elements specified in Annex VI
and shall refer to the appropriate implementing measure.




Not legally binding. Last updated January 2023. This document will be regularly updated. 4

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