Energy Labeling for Mobile Phones and Tablets EU 2026: What Manufacturers and Importers Must Review

Key data

If you market smartphones or tablets in the EU, you have a concrete task ahead: verify that the terminology of your energy labels and technical documentation matches the corrected version of the regulation in each language in which you operate. The Delegated Regulation (EU) 2026/879, published on 20 April 2026, corrects errors in certain language versions of Delegated Regulation (EU) 2023/1669.

The good news: there are no new substantive obligations. The bad news: energy labeling is a mandatory requirement to sell in the European single market, and any deviation from the current official version may result in penalties.

What does this regulation establish?

Delegated Regulation (EU) 2026/879 is a formal correction of certain language versions of the Delegated Regulation (EU) 2023/1669, which is the regulation governing energy labeling of smartphones and tablets in the European Union. This 2023 regulation complements, in turn, Regulation (EU) 2017/1369 of the European Parliament and of the Council, which is the general framework for energy labeling in the EU.

The corrections introduced are of a technical-linguistic nature: they affect the wording in certain official EU languages, but do not modify the substantive content or the substantive obligations that were already in force. In other words, what is required of companies does not change in essence, but the official terminology in the corrected languages is updated.

Economic and operational impact

The direct impact of this correction is not economic in terms of new fees or regulatory costs. However, the operational impact is real for any company marketing these devices in the EU:

• Review of physical and digital labels: If your product energy labels use terminology from a language version affected by the correction, they must be updated to reflect the current official terminology.
• Update of technical documentation: The technical documentation accompanying the products and presented to market surveillance authorities must also be adjusted.
• Risk of penalties: Energy labeling is mandatory for marketing in the European single market. Non-compliance can result in penalties, although the correction regulation does not specify specific amounts.
• Cost of internal review: The main cost for companies is the time and resources dedicated to auditing existing documentation and updating affected materials.

For companies with operations in multiple European markets, the review must be done language by language, identifying which language versions have been corrected and whether their current materials are aligned with the new official wording.

Who does it affect?

This regulation affects all companies involved in the marketing chain of smartphones and tablets in the European single market:

• Manufacturers of smartphones and tablets that distribute their products in the EU, regardless of where they are established.
• Importers who introduce these devices into the European market from third countries.
• Distributors who market smartphones and tablets in one or more EU markets.
• Compliance officers and legal teams of technology companies with a presence in Europe.
• Advisors and consultants who assist technology sector companies in European regulatory compliance.

Practical example

Imagine a Spanish importer that distributes an Asian smartphone brand in Spain, France and Poland. Until now, its energy labels and product sheets were generated from the original version of Delegated Regulation (EU) 2023/1669 in each language.

With the publication of Delegated Regulation (EU) 2026/879, it must do the following:

1. Identify whether the language versions in Spanish, French and Polish are among those corrected by the new regulation.
2. Compare the current terminology of its labels and technical documentation with the corrected official wording.
3. Update materials that are not aligned before the correction becomes enforceable.
4. Document the review process to be able to prove it to market surveillance authorities if necessary.

This process does not involve redesigning the product or changing its energy characteristics, but it does require a systematic review of all labeling and technical documentation materials in each relevant language.

What should companies do now?

1. Identify affected languages: Consult the full text of Delegated Regulation (EU) 2026/879 to determine which language versions have been corrected and whether they affect the markets where you operate.
2. Audit labels and technical documentation: Review all physical and digital energy labels, as well as the technical documentation of your products, in the affected languages.
3. Compare with corrected terminology: Contrast the current wording of your materials with the corrected official version of the regulation to detect terminological discrepancies.
4. Update non-compliant materials: Modify labels and documentation that do not conform to the current official terminology following the correction.
5. Review compliance processes: Update your internal regulatory compliance procedures to incorporate the corrected version as the official reference and prevent future materials from being generated with obsolete terminology.
6. Document the process: Keep evidence of the review carried out and the updates made, in case of inspections by market surveillance authorities.

Official source

Commission Delegated Regulation (EU) 2026/879 of 5 December 2025, published in the Official Journal of the European Union on 20 April 2026.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. The interpretation and application of EU regulations may vary depending on specific circumstances. Companies should consult with legal and compliance specialists to ensure full compliance with applicable regulations in their specific markets and operations.