The recast Energy Labelling Directive was transposed into UK law in 2011. One of the aspects that had not previously been addressed by earlier Directives was the growth of internet sales.

The new Framework Directive stated that energy labelling information should be made available to online customers as well as displayed on appliances in shops so that all consumers would have access to the same information when choosing an appliance.

Online retail sites now include the energy rating (A+ etc.) in their comparison tables but they do not necessarily show an image of the label itself.  And while the product information on manufacturers’ websites may link to an instruction booklet containing all the supplementary label information, this is not necessarily what the consumer looks at when comparing products.

The European Commission is now considering a Regulation to set consistent requirements for all energy labelled products displayed for sale online.

It is proposed that suppliers should have to provide the label image and the supplementary information electronically.  This could be done using direct e-mail, uploads from the manufacturer’s website or by the physical transfer of data storage devices inside the packaging. There would also be accessibility requirements for people with visual impairment.

The Regulation would also specify how the retailer should display the label image and information.  This would have to allow for consumers viewing images on smartphones and tablets etc.  It is suggested that the appropriate sizing and aspect ratios would be in line with existing conventions for nested displays and magnification.

The proposal is that the energy rating would be displayed as an arrow in the same colour as the energy efficiency class for that product. Clicking on this image or touching it on a screen would bring up the whole energy label. A link from the bottom of the label image would then take you to the supplementary information. 

An EU study into internet shopping found that some 70% of items  are now "pre-searched" online even if the purchase is eventually made in a shop. The study also showed that for Europeans with an internet connection, 90% of white goods are pre-searched even though only about 4% are bought online. 

The concern is that shoppers who do not see the energy label information online do not choose the most energy efficient products.  Even if they subsequently buy in a shop they may have already made up their minds which product they want and will not be swayed by the label information on display.

So the theory is that requiring the labelling information to be displayed in a similar format across all purchasing channels will ensure that all consumers make comparisons based on the energy efficiency rating of the products that they are considering.

However, there are different views on the efficacy of displaying the actual label online.  It can be argued that it is the information that is the key element so the consumer needs to read the information rather than see the image.  It is also the case that they can already see the different ratings in the comparison tables, so the next question is how much more information they need.

Retailing websites offer the selection parameters that they believe the consumer finds most useful, and obviously size, cost and brand are are always going to be the key choices.  Indeed it could be argued that the key driver for comparing products online is to find the cheapest price.

AMDEA has argued that retailers should be free to choose how they display the label information.  Requiring images and links to operate in a specific way will add to the complexity and costs of websites. 

In addition, it is the availability of information and advice in shops that enables retailers to offer the customer a different shopping experience from that of the online purchaser.  Perhaps it is always going to be the face-to-face sales that really encourage consumers to think about the energy efficiency of the appliances they buy.

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