Logo

How to prepare your documents for market surveillance

Market surveillance authorities (MSA's) verify, whether products on the EU market comply (among others) with the ecodesign and energy labelling requirements. As far as the documentation is not available in EPREL, you have to make it available within 10 working days. 

MSA's will check the documentation and can enforce non-conformities. An MSA can demand an amendment of documentation, apply fines, remove products from the EU market etc. 

To verify the declared values, the MSA can also perform physical tests. 

You as a supplier are obliged to collaborate with the authorities by providing needed information and undertaking corrective action if needed.   

Product testing usually comprises two steps (although depending on national legislation and the product category or even on the product):

  • Single-test: One unit of a specific model is first selected for the test.
  • Triple-test: Three more units are tested in case the results of the single-test determined values exceed the tolerances ( i.e. for compliance verification only the average of the three triple test results is relevant).

Details can be found in the specific annex “Verification procedure for market surveillance purposes” of the respective ecodesign or energy labelling regulation. 

Some MSA's only conduct the triple test if the supplier disputes the results of the single test, while others always perform single and triple tests. This variation arises from differences in national legislation.

In case of non-compliance, the tumble dryer must not be sold on the EU market anymore. If only the declared values are outside the tolerance, a change of documentation (and potentially the energy label) should suffice. 

Whether you as a supplier are required to bear the costs of purchasing products and the tests, depends on the national legislation. 

The inspection procedures are the same for ecodesign and energy labelling regulations. 

Which documents and information sources have to be present resp. prepared? 

  • Label. 
  • Product Information Sheet/Product Fiche.
  • Energy labelling and ecodesign Technical documentation. 
  • Declaration of Conformity (DoC).
  • Test reports following all regulations mentioned in the DoC.
  • List of equivalent models. 
  • Details of the calculation steps for EEI and (if applicable) condensation efficiency. 
  • User manual. 
  • Supplier’s website. 
  • Repair instruction/repair and maintenance information. 
     

Typically common mistakes observed by market surveillance 

We have compiled the findings from previous market surveillance actions, where similar mistakes have been frequently detected across various product groups: 

Energy label 

  • Values on the label must not be more favourable than the values in the technical documentation. 
  • Energy label must be for the model it is attached to or an equivalent model; in the latter case, the equivalence must be stated in the concerned section in EPREL. 
     

Product Information Sheet (PIS) 

  • Values on the PIS must not be more favourable than the values in the technical documentation. 
  • All values applicable to the specific model must be present. 
  • PIS must be for the model it is attached to or an equivalent model; in the latter case, the equivalence must be stated in the concerned section in EPREL. 

 

Energy labelling technical documentation 

  • All values applicable to the specific model must be present. 
  • All values must be supported by a test report, i.e. they must also be part of a test report and the values must not be more favourable than stated in this report. 
  • If test reports are part of your documentation, make sure that it is clear, which values are the declared ones. They are not necessarily those stated in the test report. 

 

Details of the calculation steps for EEI and (if applicable) condensation efficiency 

  • Often the calculations are missing. Please explain, which values you inserted into the formulas given in the regulations:

 

List of equivalent models 

  • Especially if the energy label and the PIS are not issued for each model, but only for one of the equivalent models, make sure you list all models in the „Equivalent models“ section in EPREL. 

 

Declaration of Conformity (DoC)

  • All standards must be mentioned and linked to the relevant regulations. 
  • The mentioned date must be before or equal to the placing on the market of the investigated unit of a model, not the date of the request of the technical documentation by the MSA. 

 

Test reports following all regulations mentioned in the DoC 

  • The test reports must be sent to the MSA on request within a timeframe indicated by the MSA; therefore, make sure you have all reports available. 

 

User manual 

  • Make sure the user manual is available and complete and accessible in the languages relevant to the countries where the product is sold. 

 

Supplier’s website 

  • Make sure that for every model all information is present on a free access supplier’s website. 

Further information

You can find more information about how to prepare for inspections and more information about the Market Surveillance Authorities in the EU here.