How do I record the energy consumption of a device?

What you must concretely do

What is expected of you

Measure energy consumption according to the established method

The ESPR stipulates that product information, including energy consumption, is established using test, measurement and calculation methods that are reliable, accurate and reproducible (Article 39 ESPR). This means that a value is not simply adopted from a data sheet of a chip manufacturer or from an estimate, but that there is a method behind it that another company, with the same test setup, should arrive at the same result. For a company with 10 to 100 employees, this usually means that a test laboratory is engaged, or that reliance is placed on test results already delivered by a manufacturer elsewhere in the supply chain. Which method precisely applies varies by product group and is established in each delegated act — you can read more about this on the page on the method by which values for the passport must be measured.

Record energy consumption as part of the performance requirements

Articles 5 to 7 of the ESPR distinguish between ecodesign requirements (how a product is manufactured) and information requirements (what must be known about a product). Energy consumption can appear in both requirements: as a performance requirement (a maximum or a class) and as an information requirement (a value that becomes visible in the product passport). For a company, this means that energy consumption is not a single standalone figure, but a piece of data that can appear in two places — in the technical documentation demonstrating compliance with a requirement, and in the data going into the product passport. Which of the two, or both, apply depends on the product group and becomes clear once the delegated act for that group is published.

Record the test conditions, not only the result

A measured value without the conditions under which it was established is difficult to justify during an inspection. Test temperature, load profile, software version during the test, equipment used: this type of data belongs to the substantiation of the final value. For companies that do not test themselves but rely on a test report from a supplier or manufacturer, this means that the report itself — and not only the figure in it — must be retained and remain traceable.

Recognize when a value must be measured again

Energy consumption changes when modifications are made to a product: a different power supply, a firmware update that affects standby consumption, a different model within the same product line. This relates to the question of how frequently data in the product passport must remain current, which is addressed more broadly on the page on how current the data in the product passport must be. In practice, this means that a company needs a point at which it is determined whether a modification to the product also requires a new measurement.

Where things go wrong in practice

An importer adopts the energy consumption value from the documentation of the manufacturer in Asia, without knowing according to which test method that value was established. When asked about this, there is no underlying report, only a figure on a specification sheet.

A manufacturer tests a device once upon introduction, but subsequently releases a software version that affects energy consumption in standby. The original measured value remains in the product passport, while actual consumption has now changed.

A company places different variants of the same device (different colour, different power supply rating) under one and the same energy value, without checking whether the test method permits this or whether each variant requires its own measurement.

A test report is retained, but not linked to the specific model or specific production run for which it was prepared. During an inspection, it can then no longer be traced which report belongs to which device.

A company may assume that the energy consumption value is a fixed, non-confidential piece of data that can be published without further consideration, whereas the question of whether underlying test data should be public is a separate matter — see the page on this topic the page on business-sensitive data in the product passport.

What you can document

• The test report or calculation on which the energy consumption value is based, including test conditions and equipment used
• The name and version of the test method or standard applied, so that it is traceable which method was applicable at the time of testing
• The link between the test report and the specific model, type or production run to which it applies
• An overview of changes to the product (hardware or software) that may necessitate a new measurement
• The date of the measurement and the planned or performed re-measurement, if applicable
• The person or department responsible for assessing whether a product change requires a new measurement

This documentation does not need to be separate from the rest of the product documentation. It relates to the question which data exactly is included in the product passport for electronics, and to the question which properties are specific to the own product group, as described on the page on which properties are requested per product group. Once the delegated act for the relevant sub-category has been published, it will become concrete which test method and which energy consumption thresholds apply.