1、 Core regulatory basis
Car refrigerators entering the EU market are mainly subject to the following regulations for energy efficiency compliance:
The Energy Efficiency Labeling Regulation (EU) 2017/1369 establishes the A-G seven level energy efficiency rating system, which is the top-level
framework of the labeling system.
Ecological Design Regulation (EU) 2019/2019: Specific energy efficiency limits and testing methods for refrigeration equipment have been fully
implemented since March 2021, and regulation will continue to tighten in 2026.
Energy Efficiency Labeling Regulation (EU) 2019/2015: specifies the requirements for new label styles and QR codes.
The Sustainable Product Eco Design Regulations (ESPR) will gradually be implemented after 2025, with refrigeration equipment included in key
regulatory categories and new requirements for circular economy attributes such as repairability and recyclability.
2、 Scope of application and exemption determination
Not all car refrigerators require ERP energy efficiency registration, and product forms need to be distinguished:
Mandatory scope: Refrigeration equipment with a capacity greater than 10L and less than or equal to 1500L, powered by the power grid. Products
that support dual mode power supply of 12V/24V car power supply and 220V household power supply must be tested and registered according to
household refrigeration equipment standards.
Possible exemption: Mobile refrigeration products powered by pure DC direct current (12V/24V) without AC adapters theoretically have exemption
space, but must be confirmed by EPREL official judgment and cannot be self determined, otherwise there is still a risk of customs return.
3、 Testing standards and key indicators
The laboratory testing is mainly carried out according to the following standards:
EN 62552: Characteristics and testing methods for household refrigeration appliances, is the core standard for determining volume, energy consumption,
and energy efficiency index (EEI).
EN 50564: Measurement of power consumption in standby and shutdown modes of electrical and electronic equipment.
The core indicators to be measured include:
Energy Efficiency Index (EEI): The core parameter that determines the energy efficiency level. EEI ≤ 25% is classified as Grade A, 26% -55% as Grade B,
and gradually increasing to Grade G.
Annual power consumption: calculated at an ambient temperature of 24 ° C.
Storage capacity: The deviation between the measured value and the nominal value must comply with regulatory tolerance requirements.
Noise emissions: Car refrigerators need to pay attention to this indicator.
Standby/shutdown power consumption: Must meet the limit requirements in ecological design regulations.
4、 Four step authentication process
Step 1: Product energy efficiency testing
Prepare 1-2 samples that are identical to the mass-produced model and send them to a third-party laboratory with CNAS accreditation qualifications.
The testing cycle is about 5-7 working days, covering energy stability testing, volume measurement, and noise testing.
Step 2: Technical Document Preparation (TDF)
After passing the test, prepare a complete technical document package, including: test report, English manual, circuit diagram, BOM (Bill of Materials),
risk assessment report, and Declaration of Conformity (DoC). Non EU manufacturers must include EU authorized representative (EU representative)
information in their documents.
Step 3: EPREL database registration
Create an account in the official European Energy Label Product Registration (EPREL) system by the service agency or European representative, enter
product information, and upload test reports. After approval, the system generates a formal energy efficiency label with a unique QR code.
Step 4: Labeling and Listing
Download the generated label, print it according to regulatory requirements (usually not less than 36mm × 72mm, recommended 66mm × 72mm,
font height ≥ 3mm), and paste it on the product body and outer packaging. When selling online, tags need to be displayed synchronously on the
product details page.
5、 EPREL registration mandatory requirements
Subject restrictions: EPREL registration cannot be carried out by individuals and must be initiated by a corporate organization with an entity or authorized
representative within the European Economic Area.
Account prerequisite: An EU LOGIN account must be created before entering the EPREL system for operations.
One type, one number: Each registered model can only correspond to one energy efficiency label, and each label has an independent registration number.
Information consistency: The energy efficiency level, power consumption, and other data on the label must be completely consistent with the test report.
6、 Information that must be included in energy efficiency labels
Supplier name or trademark
Product Model
Energy Efficiency Rating (A-G)
Annual electricity consumption (kWh/year)
Storage capacity (L)
Noise level (dB)
QR code (link to EPREL database detailed page)
Corresponding regulation number
7、 Cycle and Cost Reference
Overall cycle: Assuming complete documentation and smooth testing, it usually takes 2-4 weeks.
Laboratory testing: approximately 5-7 working days
Document review and EPREL registration: approximately 3-5 working days
If the initial EEI test does not meet the standard or the volume deviation is too large, the rectification and retesting time will be calculated separately.
Cost composition: It mainly consists of testing fees and registration service fees, with a total cost usually in the range of several thousand RMB. Dual
mode power supply (AC/DC) products typically have higher testing complexity and are more expensive than pure DC products. Be alert to the low price
traps of "testing without registration" or "false registration" in the market.
8、 Common risks and precautions
Essential for European agents: Non EU companies must designate an EU authorized representative, which is a prerequisite for EPREL registration and a
key focus of customs and platform inspections.
ERP ≠ EPR: ERP is an energy efficiency certification for "energy related products"; EPR is an extension of producer responsibility (packaging law, WEEE,
etc.), which is completely different and should not be confused.
Continuous compliance: During the product sales period, it is necessary to ensure that the energy efficiency parameters at the time of registration are
always met, and software or firmware updates must not cause energy consumption deterioration.
Market inspection: EU market regulatory agencies will conduct random inspections, and products that are not labeled or have labeling information that
does not match will face bans, fines, or even recalls.
9、 Changes in new regulations from 2025 to 2026
Re calibration of energy efficiency levels: We have fully switched from the old version A+++/A++/A+to the A-G seven level system, with more intuitive labels.
QR code as standard: New labels must come with a QR code, and consumers can scan the code to obtain complete energy efficiency information of the product.
Key supervision of refrigeration equipment: The EU Joint Work Plan for 2025-2030 clearly lists refrigerators and other refrigeration equipment as key targets,
and compliance reviews are becoming increasingly strict.
ESPR circular economy requirements: In addition to energy efficiency, requirements for product repairability, spare parts availability, recyclability, etc. will
gradually be included in the evaluation framework.
