A household tumble dryer enters the EU market in 2026 and remains on a retailer's website in 2027. Must its product page now show the energy label with an A–E repairability grade? The retail sale date alone does not answer that question. The relevant dividing line for the new label is when the individual product was placed on the market, alongside the label and product information for its particular model.
Under Commission Delegated Regulation (EU) 2025/1353, the revised label is required for covered household tumble dryers placed on the market from 1 January 2027. Suppliers could already use the revised label and accompanying information from 24 November 2025 through the end of 2026. Dealers may continue selling products that were previously placed on the market with the earlier label; the amendment does not impose a single sell-through deadline for those products. A 2027 listing may therefore require a new label, or legitimately retain an earlier one, depending on the unit's market placement and the corresponding model records. It would be equally mistaken to order every old unit relabelled or to use the old format for a newly placed unit.
The underlying Regulation (EU) 2023/2534 covers mains-operated and gas-fired household tumble dryers, including specified built-in and multi-drum products and mains products that can also run on batteries. Washer-dryers and spin extractors are outside this scope, as are the other products excluded in Article 1. The label timeline should not be applied to an excluded product without checking its own rules.
Two letters on one label answer two different questions
The revised label retains an A–G energy efficiency class and adds an A–E repairability class. An energy class of A does not imply a repairability class of A. Both entries must be checked against the exact model identifier rather than inferred from a family name or another variant.
The repairability class comes from an index, R. The legal thresholds are A when R is greater than 9; B when 7≤R≤9; C when 5≤R<7; D when 3≤R<5; and E when R<3. This is a defined calculation, not a general warranty of durability, low repair cost or easy repair of every component.
The calculation combines four types of score. Disassembly depth, fastener types and tool types are evaluated for the priority parts specified in the regulation; access to repair information is evaluated at product level. The priority parts are the drain pump, drum bearings, belt, door, motor, main circuit board, fan and motor capacitor. Where a priority part is absent, the method removes it and reallocates weight under the prescribed formula. Heat pumps are not currently one of these priority parts. The regulation calls for an assessment before 2030 of whether to add them, which is different from including them in today's grade.
Repair information also needs a careful reading. The relevant subscore concerns access for professional repairers: free access and access subject to a reasonable, proportionate fee produce different scores. A score relating to information does not establish that every consumer can obtain all professional material free of charge.
A grade is not a spare-part availability certificate
Spare parts are governed by a separate ecodesign timetable. Commission Regulation (EU) 2023/2533, as amended by Regulation (EU) 2025/2262, sets obligations for relevant models placed on the market from 1 July 2025. That date should not be confused with the 1 January 2027 starting point for mandatory repairability information on newly placed products' labels. The 2025 amendment aligned the wording of some spare parts with the priority parts used in the index, but the two lists and their legal functions are not identical.
The ecodesign rules identify a group of parts to be available at least to professional repairers, including the drain pump, drive components from motor to drum such as the belt, drum bearings and motor capacitor. Another group must be available at least to both end-users and professional repairers: the door, door seal, door handle, door lock and hinges; fluff and air filters; plastic peripherals; and the condensation tank. The professional group cannot be presented as a promise that every part is sold to any consumer. The listed parts are subject to replacement requirements allowing no tool or non-proprietary tools without permanent damage; that does not mean every replacement is tool-free or that unlisted parts are covered.
The supply periods start differently. The professional-repairer group must be available from the later of 1 July 2025 and two years after the first unit of the model is placed on the market, until at least ten years after the last unit of that model is placed on the market. The group for end-users and professionals is available from placement of the unit on the market until at least ten years after the model's last unit is placed on the market. During the applicable availability period, spare parts must be delivered within 15 working days of an order. This is a rule about delivery of parts, not a promise to finish a repair within 15 calendar days.
What the product information sheet can and cannot establish
Under the revised label rules, the product information sheet lists the model's repairability class, R and its four component scores. It also points to web information on spare parts available to professional repairers and end-users, end-user repair instructions and indicative pre-tax spare-part prices. The label is a concise result; the sheet and linked pages let a reader test what lies behind it. A link's presence does not prove that a particular part is in stock on a particular day, that it fits every variant, or that professional repair documentation is freely available to the public.
For a product page, a practical check is to connect four records for the same model: the individual unit's placing-on-the-market date, the label format and model identifier, the information sheet's class and index scores, and the applicable spare-part category and linked information. This is an editorial verification method, not an additional four-step procedure imposed by EU law. Regulation (EU) 2025/1353 also contains an energy-class disclosure obligation for certain visual advertisements and technical promotional material from 1 July 2025; it should not be rewritten as an obligation to display a repairability grade in every 2026 advertisement.
Without a named model's official product entry, supplier records and evidence of when the units were placed on the market, no conclusion about a specific product's compliance is possible. A properly supported claim can identify that model's A–E repairability class. Claims such as “the whole range is easy to repair”, “all parts are available to consumers” or “the lowest repair cost” require evidence beyond the label.
Primary sources: European Commission explanation, 21 November 2025; Delegated Regulation (EU) 2025/1353 amending Delegated Regulation (EU) 2023/2534; Ecodesign Regulation (EU) 2023/2533, Annex II, section 5, as amended by Regulation (EU) 2025/2262.
Prepared by 绿色方舟（深圳）认证有限公司.
