Energy efficiency class in online advertising: state the label class and class range correctly

Article 6(a) of Regulation (EU) 2017/1369 requires suppliers and dealers to indicate the energy-efficiency class and the range of available classes on the label in visually perceptible advertising for a particular model. The duty is tied to advertising for the concrete model.

The release check must therefore match two statements: the class of the promoted model and the class range provided by the energy label applicable to that product. A class stated without its range, or a range taken from another product group, does not complete this check.

The provision names the class and the class range. The scale and further label details applicable to the product are determined by the relevant product-specific delegated act.

The first control point is the model identity. The advertisement must be assignable to a clear model name or model number. Where variants differ in equipment, size or energy label, approval should not be given to the product family as a whole without checking each model version.

The delegated act for the product group should then be recorded. It determines which label scheme and class range apply to the model. This comparison prevents editorial templates from carrying over an old scale or data from a related product.

As a starting file, record the model number, product group, current energy label and identified delegated act. The comparison starts again when the model changes.

Both statements belong in the visually perceptible advertising message. A reference placed only in a later file or in a document that is not readily available does not replace checking the advertising surface itself.

Banners, tiles, comparison feeds and dynamically served advertisements therefore require a check of the concrete presentation of each model. The release record should show where the class and class range appear and how the model reference is made.

If the class is shown in a graphic, the editorial team must compare the graphic version with the current label. A useful approval record identifies the advertisement, model reference, data status and source of the label information.

Article 6(a) covers technical promotional material as well as visually perceptible advertising. Documents that communicate technical parameters or performance features of the model should therefore undergo the same model and label check.

A data sheet, product comparison, dealer document and online advertising asset may be stored together in one campaign folder. Their different formats do not remove the need for a traceable model assignment and correct energy-label statements.

An internal note is not automatically promotional material. The release check should identify which document will be used externally and whether it promotes a particular model with technical or energy-related information.

The most reliable editorial control starts with a fixed data package: model number, current energy-efficiency class, available class range, product group and label reference. Compare this package with every advertising version before publication.

Automated feeds and several sales channels require a versioned data source. If the model, label or product-group assignment changes, existing advertising assets and templates must be checked again.

The approval record should identify the checked version. A screenshot or PDF, URL, time, model number and label source create a reliable fallback if another advertising version is served later.

A product family may include models with different classes. If the advertisement selects one model, its class and class range must belong to that model. A general family value is not sufficient documentation for that purpose.

Dynamic advertisements also require a check that the system changes model, image, price and energy information together. A technical error showing another model's class is not cured by a correct value in a central database when the advertising surface displays the wrong combination.

If the assignment is not clear, publication should wait until it is resolved. This matters especially where one template is reused for many models.

For every approved version, archive the visible advertising surface together with the related model data. Keep the concrete URL or channel, a screenshot or export, the review time, the model number, the label and the relevant delegated act.

The time is particularly important for personalised or short-lived advertisements. The record should show which version was checked and which data supported it. A later correction can then be tied to the version that was actually served.

Records do not replace legal review. They prevent a later check from having to rely only on a general product page or an outdated template.

Before publication, the responsible person should check five points in the same advertising version: Is a particular model promoted? Is its energy-efficiency class correct? Is the available class range of the relevant label stated? Are both statements visually perceptible? Are the model, label, delegated act and advertising version documented?

If one answer remains open, the advertisement is not ready for release. Where several variants are used, repeat the check for each model. A general family approval can be an internal organisational step only if the concrete assignment and every advertising version have still been checked and can be traced.

For the distinction from other environmental statements, see the related article on green claims. The energy-efficiency class check remains separate.