Your Shop Floor Passes the Energy Label Inspection. Your Website Does Not.

You sell fridges. Or bulbs, or televisions, or a rack of tyres out the back, or, since last summer, phones.

Your shop floor is almost certainly fine. When SEAI last published the findings of its energy labelling inspection campaign, its market surveillance team had assessed more than 24,000 electrical products on display across 110 stores nationwide, and around 87% of what they looked at carried the label correctly. That was the highest recorded compliance rate since 2019, up roughly four points on the previous year. Credit where it is due: that is shop staff getting a fiddly job right, thousands of times over.

Then the same team reviewed 55 websites aimed at shoppers here, and rated 27% of them as having good levels of energy labelling compliance. Better than the 20% recorded the year before. Still three sites in four falling short, on a sample small enough that I would treat the exact percentage as indicative rather than precise.

Same products. Often the same businesses. One channel passes and the other does not.

I want to be straight about why, because it is not negligence. The shelf edge label is somebody's job on a Monday morning. A product template on a website is nobody's job at all, and in a great many shops nobody in the building can change it without raising a ticket with whoever built the site three years ago.

The inspection you never see happening

What catches owners out is the mechanics of it. A market surveillance review of your website does not involve anybody walking through your door.

SEAI is the Market Surveillance Authority for energy labelling and ecodesign in Ireland, and it says plainly that it examines products in store and online, and looks at advertising too. A website review is desk work. Someone opens your category page, checks whether the label and the product information sheet are where the regulations say they should be, and classifies the site. You find out afterwards, if at all.

Consider a typical case, and this is a composite rather than one business: a Monaghan electrical and appliance shop, forty years on the same street, decides during a quiet spell to put its stock online properly for the first time. Washing machines, a few televisions, and a dozen handsets, because phones now walk out the door faster than fridges. The shop floor has been inspected before and sailed through. Nobody connects that experience to the new listings, because the listings feel like marketing rather than retail.

They are not marketing. Under Irish law they are a point of sale, and the obligations follow.

The teeth are in S.I. No. 669 of 2022, the European Union (Energy Labelling) Regulations 2022. A breach is an offence, punishable on summary conviction by a class A fine, which currently tops out at €5,000, or on conviction on indictment by a fine of up to €250,000. Regulation 16 goes further and makes a director, manager or secretary personally liable where the offence is attributable to their neglect.

In fairness to SEAI, prosecution is the far end of a long road. Its stated approach runs through guidance, voluntary correction and compliance directions first, with prosecution reserved for serious breaches. But the exposure is real, it is written down, and it is a strange thing to be carrying because a product template has a missing field.

"Dealer" means you, and the list is longer than you think

The regulations do not talk about retailers or shops. They talk about dealers, and S.I. 669 defines a dealer as a retailer or other person who offers products for sale, hire or hire purchase, or displays them to customers or installers in the course of a commercial activity, whether or not in return for payment.

Read that once more. No turnover threshold. No exemption for a sole trader with four fridges on a website. If you offer the product, you are a dealer, and if a manufacturer sells directly from its own site, it is a dealer too.

The product groups on the European Commission's list are broader than most owners assume:

• Fridges, freezers, washing machines, washer dryers, tumble dryers and dishwashers
• Domestic ovens and range hoods
• Electronic displays, which means televisions and monitors
• Light sources, which means bulbs, including the ones you sell four at a time
• Space heaters, local space heaters, water heaters, solid fuel boilers, air conditioners and ventilation units
• Commercial and professional refrigeration, so a catering supplier is in scope as well
• Smartphones and slate tablets, since 20 June 2025
• Tyres, under a parallel regime in Regulation (EU) 2020/740

That phones entry is the one that changed the population of affected businesses. Delegated Regulation (EU) 2023/1669 brought smartphones with a screen between 4.0 and 7.0 inches, and tablets between 7.0 and 17.4 inches without an attached keyboard, into energy labelling from 20 June 2025. SEAI's own notice to retailers said it in as many words: for retailers who do not also sell goods within the scope of energy labelling legislation, that date may have been their first time having to comply with these types of requirements.

Phone shops. Repair shops that also sell new handsets. General electrical shops. A regime they had never met, landing on listings they had already published.

None of this is unfamiliar territory once you see the shape of it. Your product listing already carries the safety information the GPSR requires on an online offer, and if you sell drinks it already has to show the deposit as its own line rather than folded into the price. The energy label is another entry in the same ledger. Your product page has quietly become a compliance document that happens to sell things.

What actually has to appear on the page

This is where good intentions usually go wrong, because owners do the obvious thing and put the label somewhere sensible. Sensible is not the test.

The Commission's guidance for dealers is specific about distance selling. Both the energy label and the product information sheet must be displayed on screen in close proximity to the product's price. Font size matters too: the energy class indicator should match the price, which is a detail almost nobody implements. And it applies on every page where the product is shown, not just the main product page, so category listings, search results and the basket are all in scope.

There is a permitted shortcut, and you should use it. Rather than dropping a full label graphic next to every price, you can use a compacted energy class arrow as a nested display, which expands to the full label and product information sheet when the customer clicks or hovers. That is the mechanism nearly every compliant site uses, and it is what the EPREL database is built to feed.

For distance selling specifically, SEAI's notice puts the dealer duty in four parts: the label and product information sheet provided in electronic format for internet sales; the energy efficiency class and the range of classes available where the sale is paper or telephone based; the energy efficiency class and the range of classes in any visual advertisement or technical promotional material for a specific model, including on the internet; and printed copies of the label and sheet made available on request.

Take that third one seriously for a moment. A visual advertisement for a specific model, including on the internet, covers more than your own site. A boosted post showing one named washing machine with a price on it sits inside that wording for the product groups whose delegated act carries the duty, and most of them do. Check the delegated act for the group you are advertising before you assume social is outside the net, because the drafting differs a little between them.

The consequence of getting this wrong is not dramatic. That is exactly what makes it persist. Nothing breaks, no customer complains, the orders keep coming, and the gap sits there through three years of trading until the morning an email arrives from an authority that has already looked at your site and formed a view.

Getting the label onto your listings in five steps

Identify. Go through your catalogue and mark every product that falls into one of the groups above, including the phones and the bulbs you do not think of as regulated goods.

Retrieve. Ask each supplier in writing for the energy label and the product information sheet. They are obliged to provide both within five working days of a request, and if they go quiet you can pull the label and sheet for any registered model from the EPREL database using the model identifier.

Place. Add the energy class arrow beside the price on the product page, the category listing and the basket, with the full label and product information sheet one click away.

Verify. Open your own site on a phone, as a customer, and confirm the arrow is visible without scrolling past the buy button. Then verify the class shown matches the label the supplier sent, because a copied template with last season's model data is a compliance problem wearing a compliant costume.

Re-check on restock. Build the label field into whatever routine you already use for adding a product, so the next model in gets it at creation rather than in a panic later.

Where your platform decides this for you

Every step above assumes something that is not true of every shop: that you can change your own product template.

This is the part I get exercised about, because it is where the platform choice a business made years ago quietly becomes a legal exposure. If your product page layout is fixed by a theme you cannot edit, if adding a field beside the price means a developer quote, if the app that would handle energy labels properly sits behind a higher plan tier, then a twenty minute job becomes a three week job with an invoice attached. Some owners simply decide not to bother, which is an understandable commercial decision and a poor legal one.

Full WordPress is the reason I am comfortable recommending it for regulated retail. The template is yours, the plugin and theme ecosystem is open rather than walled, and a field beside the price is a field beside the price rather than a support ticket. With Web60's €60 a year all-inclusive hosting, there are no per-feature charges sitting between you and a change you are legally obliged to make, which matters more the more of these duties land on your listings. Every one of them arrives the same way: a rule about what has to appear next to a price.

One honest concession. If appliances are your whole business and you are doing real volume across hundreds of models, a large hosted commerce platform with a maintained energy labelling app that syncs directly from EPREL will do this better than a manually maintained field ever will, and the subscription is worth it at that scale. That is a genuine fit. It is not the shop with ninety products and a Tuesday afternoon to spare.

What the label cannot do for you

A reality check, because I would rather you heard it here.

Putting the label on the page does not make the product compliant. The label is the supplier's output, generated from their EPREL registration, and if the underlying registration is wrong or missing then displaying it faithfully does not cure the underlying problem. This bites hardest on grey import stock and on models bought through a broker, where the EPREL entry can be thin or absent entirely. If you cannot find a model in EPREL and the supplier cannot produce a label within five working days, that tells you something about the stock, not just about your website.

Keep the paper trail either way. A documented request to a supplier, with a date on it, puts you in a materially better position than a silent gap on a listing.

Conclusion

The gap between 87% in a shop and 27% on a website is not a story about Irish retailers being careless. It is a story about which parts of a business have an owner. The shelf has one. Nobody was ever handed the product template.

So give it one. Take an hour this week, open your own site as a customer would, and look at what sits beside the price on the products you sell most of. If the arrow is there, you are ahead of three quarters of the sites SEAI reviewed. If it is not, you now know what goes there, where to get it, and how long your supplier has to send it.

Frequently Asked Questions

Do the energy label rules apply to my website if my shop is small?

Yes. The obligation attaches to the role, not the size of the business. S.I. No. 669 of 2022 defines a dealer as a retailer or other person who offers products for sale, hire or hire purchase, or displays them to customers in the course of a commercial activity. A sole trader listing four fridges is a dealer in exactly the same way a national chain is. There is no turnover threshold and no small retailer exemption in the energy labelling framework.

Which products need an energy label on the product page?

The Commission's product list currently covers fridges and freezers, washing machines, washer dryers, tumble dryers, dishwashers, domestic ovens, range hoods, electronic displays, light sources, air conditioners and comfort fans, space heaters, water heaters, solid fuel boilers, ventilation units, commercial and professional refrigeration, and, since 20 June 2025, smartphones and slate tablets. Tyres sit under a parallel regime in Regulation (EU) 2020/740. If you sell any of them to consumers online, the distance selling duties apply to those listings.

Can I just put the energy label somewhere on the page?

Not quite. The Commission's guidance for dealers says the label and the product information sheet must appear on screen in close proximity to the price, that the energy class indicator should match the price in font size, and that this holds on every page where the product appears, including category listings and the basket. A compacted arrow that expands to the full label on click or hover is permitted. A label behind a specifications tab is not what the rules describe.

What if my supplier has not sent me the label?

Ask in writing. Suppliers must provide the energy label and product information sheet to dealers within five working days of a request. If that goes nowhere, both can be retrieved from EPREL for any registered model by searching the model identifier. Keep the request and whatever came back, because an evidenced attempt to obtain the label is a far better position than an unexplained gap.

Do these rules reach my social media ads?

For smartphones and tablets, SEAI's notice states that any visual advertisement or technical promotional material for a specific model, including on the internet, must carry the energy efficiency class and the range of classes available on the label. Most other product groups carry an equivalent duty in their own delegated regulation. A boosted post showing one named model and a price is therefore worth checking against the delegated act for that group rather than assumed to be outside it.

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