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Judgment of the Court of Justice of the European Union on the labelling of vacuum cleaners
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The Court of Justice of the European Union (CJEU) addressed the question of whether the energy label for vacuum cleaners must additionally include information on the test conditions under which the values relevant for the label were determined. The subject matter of the proceedings was therefore the scope of the information obligations arising from the relevant EU law requirements on energy consumption labelling.
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Background to the proceedings
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Subject of the dispute: Scope of the mandatory information on the energy label
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At its core, the issue was whether the performance parameters shown on the energy label—such as those relating to energy efficiency—must be supplemented by references explaining the comparability of the information on the basis of the measurement or test conditions. The focus was therefore on the distinction between information that must be placed on the label and product information to be provided elsewhere.
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Legal framework: Energy labelling in the European Union
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Under EU law, energy consumption labelling pursues the objective of enabling consumers to have uniform and comparable guidance. The relevant requirements for this are specified by EU provisions that determine which information must be stated on labels and in product documentation and in what form this must be done.
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Key statements of the decision
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No obligation to include test conditions on the label
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According to the CJEU’s decision, there is no obligation to state information about the test conditions on the energy label of vacuum cleaners. The Court thereby clarified that the EU law requirements do not demand that additional explanations of the framework conditions of the measurement appear on the label itself.
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Decisive is the content of the relevant provisions
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The CJEU based its assessment on the specific statutory provisions that define the scope of information on the energy label. To the extent that no corresponding indication of test conditions is provided for there, such a requirement cannot be demanded as mandatory label information beyond the wording and the regulatory system.
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Significance for market participants
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Classification for manufacturers and distribution
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The decision concerns in particular the practical implementation of labelling obligations by manufacturers and companies involved in distribution. It underscores that the design of the energy label remains bound to the prescribed mandatory information and that additional content is not owed solely because it could contribute to the classification of the values.
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Distinction between the label and other product information
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The decision also makes clear that the energy label has a clearly defined information function. Which supplementary information may need to be made available elsewhere depends on the respective EU law provisions, without this automatically resulting in an expansion of the label.
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Source and notice
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The above explanations are based on reporting on the CJEU decision in case C‑632/16 (source of the report: urteile.news, article dated 27/07/2018: “No information about test conditions needs to be stated on the energy label of vacuum cleaners”). No further presentation beyond the content stated is associated with this.
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Points of reference for commercial-law issues
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Labelling and information obligations can be of considerable relevance in trade—especially in the interaction of manufacturer information, distribution channels and promotional presentation. To the extent that questions arise in this regard in the context of product labelling, marketing or contract drafting, an assessment in the course of legal advice on commercial law by MTR Legal Rechtsanwälte may be considered.
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