Professional refrigerated storage cabinets (PRSCs) are in the  scope of the requirements covered by the Directive and where they are advertised or displayed on a website, they must have the energy label shown alongside it.  Showing any pre-2016 (and thus pre-Energy Labelling) product in a way suggesting it is for sale, is illegal. 

Under the regulations, manufacturers must design products that meet the requirements for MEPS (Minimum Energy Performance Standard), and they must provide an energy label showing how the product performs in the standard tests.  The label shows its performance, with the best being rated A and the worst G.  Meanwhile dealers have an obligation to display the product’s energy label.  The regulations stipulate that, where an appliance is offered on the internet, the full label must be accessible and shown with the product wherever displayed.

The government OPSS (Office for Product Safety and Standards) is the market surveillance authority and it has the government responsibility to monitor the market and enforce compliance.  “Any company that displays a relevant pre-2016 product on their website could be considered guilty of misrepresentation and will fall foul of the regulations,” warns Steve Hobbs, chair of FEA.  “They should only be showing products that comply with the 2016 Energy Labelling Directive.” 

The market surveillance authority can demand that manufacturers and importers of PRSCs show them the product’s Declaration of Conformity, its energy label and its specification sheet, along with its technical documentation file. 

“Refrigeration suppliers who have images of non-compliant products on their website or in their showroom or brochures should remove them immediately as this is illegal,” says Hobbs.  “Whether deliberately misleading their customers or not, they are opening themselves up to serious penalties.”