The free movement of electrical products within the European Union (EU) requires that
products comply with Union harmonisation legislation in a framework of healthy competition.

Regulation (EU) 2017/1369 regulates the registration of products subject to energy labelling in the European Register for Energy Labelling (EPREL), and Regulation (EU) 2019/1020 regulates market surveillance in the field of energy labelling.

In Spain, Royal Decree 1390/2011, of 14 October, which regulates the indication of the consumption of energy and other resources by energy-related products, by means of labelling and standardised information, includes the sanctioning regime, which refers to the regime of infringements and penalties provided for in Royal Legislative Decree 1/2007, of 16 November, approving the revised text of the General Law for the Defence of Consumers and Users and other complementary laws (TRLGDCyU).

The powers of inspection and sanction in Spain fall on the autonomous communities, while the Sub-Directorate General for Energy Efficiency and Access exercises the function of national coordinator. This sub-directorate general is part of the Secretary of State for Energy of the Ministry for the Ecological Transition and the Demographic Challenge.

The sanctioning regime for suppliers of products that can be registered with EPREL

Regulation (EU) 2017/2369 establishes a series of obligations for suppliers of electrical
products that can be registered with EPREL, and failure to comply with these obligations,
such as the incorrect use of the energy label, or the lack of veracity in the information
provided, may lead to different sanctions, which are different in each Member State.

In Spain, Royal Decree 1390/2011 sets out which are minor, serious and very serious infringements, referring to articles 51 and 52 of the TRLGDCyU for the applicable sanctions regime (today, articles 49 and 50 of the regulation), which regulates a series of economic fines that will always be higher than the illicit benefit obtained.

Other sanctions could include the immediate withdrawal of products from the market, blocking access to sales channels, the impossibility of registering, modifying or maintaining products in EPREL, preventing them from being placed on the market in the EU, and exclusion from public procurement procedures.

The latter measure can have a significant impact on those companies that rely on contracts with public entities for a significant part of their business activity.

Supervisory bodies can carry out inspections and audits, having access to the EPREL database to verify the conformity of products.

The importance of the entity seal in EPREL

To avoid the sanctioning regime for infringements in the EPREL registration process, it is important to follow a formal and rigorous procedure designed to establish the authenticity and attributability of the information relating to the products offered on the European Union market.

The security of this process rests largely on the use of robust identification and authentication mechanisms, with the qualified electronic signature and, in the case of companies, the qualified electronic seal, being a central and indispensable element.

One of the most critical steps in the EPREL registration process is the electronic seal of an official declaration. Through this declaration, the supplier certifies the veracity and accuracy of the information provided about its products, assuming legal responsibility for the data recorded.

In order for this declaration to have full legal validity and also comply with the requirements of Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions in the internal market (eIDAS Regulation), it must be signed using a qualified electronic seal.

The qualified electronic seal acts as a digital equivalent of a traditional company seal, but applied to the digital plane. It provides irrefutable proof of the identity of the company making the registration and ensures that the signed document has not been altered since the time of its signing.

NTR code requirement in the EPREL digital certificate

From May 2025, and under Implementing Regulation (EU) 2024/994, electronic seals used for entries in EPREL must include the NTR (National Trade Register) code, which is associated with the commercial register corresponding to the country of the company, with a harmonised EUID numbering system, which looks like this: NTRES-ES28065.080862918.

How to register a company with EPREL correctly?

In this increasingly demanding regulatory context, it is key to have a strategic partner who understands the complexities of registration in EPREL and the requirements of qualified electronic signature. EADTrust is that partner: a market-leading, trusted qualified service provider that makes it easy for its customers to register with EPREL.

• Issuance of the EPREL entity seal or certificate: EADTrust issues qualified electronic certificates that comply with EPREL requirements and the eIDAS Regulation. These certificates incorporate the national registration number (NTR) or the European unique identifier (EUID), as appropriate, ensuring the legal validity of the electronic signatures of the declarations submitted on the EPREL platform.
• Personalized advice in the registration process: EADTrust’s team of experts offers comprehensive and personalized advice throughout the entire registration process in EPREL. From the preparation of the necessary documentation to the correct application of the electronic signature, EADTrust guides companies through each step, ensuring that it is done efficiently and avoiding errors that can lead to
  delays or sanctions or blocking by the competent authorities.
• Ongoing technical support: EADTrust provides specialized and ongoing technical support to resolve any incident or doubt that may arise in relation to electronic signature or document validation on the EPREL platform. The aim is to ensure that companies can complete the registration process smoothly and keep their registrations up to date and in compliance with current regulations.

In a business environment where regulatory compliance is a fundamental pillar for competitiveness and reputation protection, relying on the experience and knowledge of a qualified trust service provider such as EADTrust is not simply an option, but a strategic necessity to ensure the correct marketing of products with energy labelling in the European Union and avoid the serious consequences of inadequate registration with EPREL.

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More about EADTrust

EADTrust is a qualified provider of electronic trust services in accordance with the eIDAS Regulation based in Madrid, included in the trusted list of the Ministry for Digital Transformation and Public Function, and in the ‘EU/EAA Trusted Service List‘ of the European Commission.