## Background Under the framework of the EU Energy-related Products Directive (ErP), standby and off-mode power consumption requirements will enforce stricter limits on networked devices (smart appliances, smart speakers, routers, etc.) starting in 2026. According to public industry interpretations, the standby power limit has been further tightened from the original 0.5W to 0.3W (reference range), and products are required to have a "network wake-up" function in networked standby mode. This change directly affects electrical and electronic products sold on Amazon Europe (Germany, France, Italy, Spain, and other marketplaces). The Energy Label and Product Information Sheet are mandatory materials for platform review. Products lacking compliant labels or with measured standby power consumption exceeding the limit will be marked as "additional materials required" during Amazon's compliance document review, thereby triggering listing removal.
## Frontline Observations Recently, based on seller feedback and platform notifications, three types of issues have emerged prominently: 1. **Missing or outdated energy labels**: Some sellers are still using old-version energy labels (based on versions prior to the old regulation EU 2019/2020) and have not updated to the currently applicable label format. Amazon Europe requires that uploaded energy labels must match the actual energy efficiency class of the product, and the QR code on the label must be linkable to the EPREL database (European Product Registry for Energy Labelling). 2. **Measured standby power consumption does not match declared values**: During spot testing, partner laboratories found that some products claiming standby power consumption ≤0.3W had measured values in the 0.4–0.6W range (reference range). This typically stems from power management firmware not being optimized or auxiliary circuit power consumption not being accounted for. 3. **Missing energy efficiency test reports in technical documentation**: The ErP Directive requires manufacturers to maintain technical documentation, including energy efficiency test reports. Amazon may require sellers to provide this report during compliance review; if it cannot be provided, the product may be suspended from sale. During pre-review assistance to sellers, Shuwang Testing & Certification Platform found that most delisting cases were not due to the products themselves being non-compliant, but rather incomplete documentation or version errors. The platform can coordinate with partner laboratories (with CNAS/CMA accreditation) to complete standby power consumption testing and guide sellers through the technical documents required for EPREL registration.
## What Companies Should Do For EU Energy-related Products Directive (ErP) compliance, companies are advised to conduct self-checks according to the following steps: | Step | Action | Reference Timeline | Reference Cost | | --- | --- | --- | --- | | 1 | Verify whether the product falls within the scope of ErP implementing measures (e.g., standby power consumption, networked devices) | 1–2 business days | Free | | 2 | Conduct standby power consumption testing by a partner laboratory and issue a test report | 5–10 business days | 1,000–5,000 RMB | | 3 | Prepare technical documentation (including energy efficiency test reports and product information sheets) | 3–5 business days | 1,000–3,000 RMB | | 4 | Register in the EPREL database and obtain the energy label | 5–10 business days | 1,000–4,000 RMB | | 5 | Upload Amazon compliance documents and update the listing | 1–3 business days | Self-operated | Companies should first confirm whether their products are on the ErP implementing measures list and check whether existing energy labels are consistent with EPREL registration information. For products with standby power consumption close to the limit, it is recommended to allow time for firmware optimization.
## Notes The timelines and costs described in this article are public industry reference ranges; actual figures are subject to engineer assessment and institution scheduling. Energy efficiency limits and labeling requirements are subject to the official EU texts. Shuwang Testing & Certification Platform is an export certification solutions service provider and does not engage in testing activities, nor is it a certification body. The testing described on this page is completed by partner laboratories with CNAS/CMA or equivalent qualifications, and certificates are issued by EU Notified Bodies (NB) or institutions authorized by the standards bureau of the destination country. For further information on the CE-ERP certification process, visit https://www.shuwangtc.com to obtain the document checklist. **One-sentence conclusion**: After the EU ErP standby power limits are tightened, Amazon Europe sellers should prioritize verifying energy labels and EPREL registration information, and ensure that measured standby power consumption is below 0.3W (reference range).
), to avoid listing removal.