Labeling the unlabelable: Energy efficiency for configurable computers

Peer-reviewed paper 3-144-26

Energy efficiency labelling has been a cornerstone of consumer information in the European Union since 1994, guiding environmentally responsible purchasing through reliable, comparative data. Over time, EU energy labels have expanded to cover diverse product groups and have evolved to reflect technological and regulatory progress. The upcoming introduction of an Energy Label for computers – products with extensive configurability – presents unique challenges, as variations in components such as CPU, memory, and graphics cards complicate standardized testing and labeling under the Energy Labelling Regulation (EU) 2017/1369.

Recent policy advances, notably the June 2025 adoption of EU Regulations (EU) 2023/1670 and 2023/1669 for smartphones and tablets, mark a pivotal shift toward sustainability by integrating repairability scores and reliability criteria with energy requirements. This framework serves as a blueprint for the Ecodesign for Sustainable Products Regulation (ESPR) and informs the ongoing revision of the outdated computer Ecodesign Regulation (EU No 617/2013). The forthcoming computer label, aligned with ESPR principles, will incorporate durability and reparability alongside energy performance.

This paper analyzes efficient strategies for representing entire computer product families, including the use of mean values, assessment of least efficient variants, and focus on best-selling configurations. Benchmarking of approximately 250 computers reveals deviations between configurations, with implications for label validity and reliability. The findings outline recommendations for optimizing the energy efficiency classes of the new EU Energy Label for computers, balancing accuracy, practicality, and market relevance to enhance its effectiveness in promoting sustainable choices and extending product lifetimes.