Improving Online Labeling Compliance in the European Union

CLASP is seeking a contractor or a consortium to conduct activities on improving online labeling compliance in the European Union.




CLASP serves at the epicenter of collaborative, ambitious efforts to mitigate climate change and in the global movement for clean energy access, through appliance efficiency. Our mission is to improve the energy and environmental performance of the appliances & equipment we use every day, accelerating our transition to a more sustainable world. We work hand-in-hand with governments, experts, industry, consumers, donor organizations and others to propel policies and markets toward the highest quality, lowest resource-intensive appliances possible.

CLASP has worked in more than 100 countries since inception in 1999. CLASP is headquartered in Washington, DC, with teams in China, Europe and the United Kingdom, India, Indonesia, and Kenya. We are mission-driven and committed to a culture of diversity, transparency, collaboration, and impactful work. See our Team Page to learn more about us.

In Europe, CLASP plays a central role in advising and collaborating with the European Commission, member states, environmental NGOs, and industry partners in developing and promoting appliance energy efficiency policies that reduce greenhouse gas emissions across the common market. Working closely with our partners, CLASP identifies priority work areas and provides robust technical analysis to support best-in-class policies. Our ongoing work includes support for policymaking on computers and other electronic devices, lighting, the electrification of space heating, and online labeling compliance.


Energy labels engage retailers in promoting efficiency and influence consumers to choose more efficient products. To achieve this goal, labels need to be visible where product purchases are made. With the steady growth of e-commerce, displaying energy labels for appliances sold online has become increasingly important. Regulating and enforcing online efficiency labeling is therefore necessary to secure market transformation, emissions reduction, and energy conservation targets.

The European Union (EU) has one of the world’s most comprehensive energy standards and labelling programs, and since 2015, has required the display of energy labels for online appliance sales. In particular, the EU regulation requires the energy label and product information sheet to be displayed in “proximity” of the price tag for an individual product.

Experience and evidence from several market monitoring projects in the EU has shown there are significant gaps among internet-based retailers to properly comply with requirements for online energy label display. Inconsistencies between specific requirements in the EU labelling framework regulation and the individual product regulations possibly make it more challenging for online retailers to comply.

This project builds on CLASP’s 2021 Evaluation of Online Labelling Compliance in the EU, which evaluated labeling compliance on 72 online retail websites for 5 products in six member states and provided insights and recommendations for increasing compliance with online labeling regulations. The study identified unclear or ‘grey’ areas in the online labelling requirements that require clarification, so retailers and dealers better understand their responsibilities. It also identified some legal requirements that may have low impact on consumers’ choices, suggesting that legislation could be revised and simplified without reducing its impact.

As a next step, this project will implement CLASP’s 2021 study recommendations to improve online labelling compliance levels in the EU. In particular, the project aims to:

  1. Improve EU online labelling compliance with clearer and simplified legislation. This project will evaluate requirements in EU legislation that are confusing, or that increase burden on stakeholders, but have minimal impact and provide recommendations for the European Commission (EC) to clarify and simplify legislative requirements during the next revision cycle.
  2. Strengthen capacity of Market Surveillance Authorities (MSAs) to better implement and enforce online labelling regulatory requirements. The project will develop harmonized guidance on online labelling requirements and market monitoring for use by the MSAs and retailers.
  3. Provide online retailers clear guidance on how to properly and fully comply with EU online labelling requirements.

CLASP is seeking a Contractor or a Consortium to implement this project as outlined in the Scope of Work below. If applicants are well-positioned to undertake one but not all key tasks in the Scope of Work, they can instead submit a proposal for only Task 1, or only for Task 2.


Contract Timeframe: April through September 2022 (if necessary, we would consider a longer timeframe)

Deadline for Application: 19 March 2022

Application includes registering as a Consulting Partner and submitting the technical and financial proposals per the instructions below.

Deadline for Questions: 12 March 2022

All questions must be sent in English to Nicole Kearney at We request all inquiries be made to this e-mail address and not by phone.

Scope of Work

The Consultant (Contractor or Consortium) will be responsible for successfully executing the following activities and tasks as part of this project. Execution of all activities and tasks must be conducted in close consultation with CLASP and other relevant stakeholders including the European Commission, EU Market Surveillance Authorities, and others.

Meetings and consultative workshops should be organised in an online format unless there is a strong preference by the stakeholders to hold in-person meetings.

Task 1: Evaluate and Improve EU Online Labelling Requirements 

Certain (online) labelling requirements do not impact the consumers’ decision-making process but may be more burdensome or confusing for industry to comply with and for MSAs to monitor.  Under this task, Consultant will: 1) identify existing EU legislation provisions for online labelling that may increase burden on industry and the MSAs but add little or no value to informing consumer decision-making; 2) gather supporting data and information to justify why these should be revised; and 3) provide recommendations for their revision.

The activities under this task include, but are not limited to:

  • Identifying EU legislation provisions to investigate potential for revisions.

As a starting point, Consultant will review CLASP’s (2021) “Study to evaluate online energy labelling compliance in the EU” to identify an initial list of provisions to consider (see Annex B for initial list). In addition, the Consultant will also investigate applicable legislation: a) the EU Labelling Framework regulation, b) Product specific regulations with “new” energy labels, and c) possibly any publicly available drafts within revised legislations, if available, to consider differences in the requirements and opportunities to unify and simplify them. The initial list of provisions should be prepared and consulted with CLASP.

For example, the requirement to display product information sheets (product fiche documents) next to the label should be examined, to understand whether consumers or other stakeholders actually reference them and what impact they might have, especially now that the EPREL database is in place.

  • Conducting data collection through desktop research, stakeholder interviews, surveys and/or consultative workshops.

The Consultant will identify key stakeholders including retailers and retailer associations, MSAs, consumer groups and consumers to gather robust evidence for recommended legislative revisions. The Consultant is welcome to suggest a combination of qualitative and quantitative data collection approaches to gather all necessary data for supporting recommendations.

  • Preparing a summary of findings and recommendations for revising EU legislation.

The Consultant will prepare a presentation/brief report that summarizes unclear or redundant provisions that should be revised in the EU labelling framework regulation and all individual product regulations; supporting findings from stakeholder outreach and data collection; and proposed recommendations for simplifying and clarifying legislative provisions.

  • Conducting stakeholder consultations and finalizing recommendations for revisions.

The Consultant in collaboration with CLASP will organize and host consultative meetings with the European Commission, EU Member States, MSAs, retailers, and consumer groups to present and solicit their feedback and input for the proposed revisions, before finalising and sharing recommendations with the European Commission.

Task 2: Prepare and Promote Online Labeling Compliance Guidelines for Market Surveillance Authorities and Retailers 

Under this task, Consultant will 1) research unclear online labelling regulatory requirements and online labelling market monitoring practices that lead to misalignment between MSAs, 2) seek stakeholder input, and 3) prepare two Guidelines documents – one for MSAs and one for retailers – to provide detailed guidance on complying with and enforcing the regulatory requirements. The guidance should be applicable to all countries in the EU.

Additionally, the Consultant in collaboration with CLASP will develop a Guidelines’ dissemination strategy and organize EU stakeholder webinars to introduce and promote the Guidelines. CLASP’s objective is to have all EU MSAs and retailers reference these Guidelines – that build on and include existing guidance, to ensure consistent and aligned online labelling display and enforcement practices across the EU.

The activities under this task include but are not limited to:

  • Identifying “grey” areas – or unclear requirements, – and how various retailers / MSAs understand and interpret them.

This should be done through:

Desktop research. Review and prepare a comprehensive list of requirements/definitions/text that is unclear and can be interpreted differently, – and tend to cause the most frequent cases of online labelling non-compliance. This research should include and build on: CLASP´s (2021) “Study to evaluate online energy labelling compliance in the EU”; the relevant EU legislation such as the labelling framework regulation, product specific regulations, and possibly any publicly available drafts of revised legislations; existing energy labelling guides including the ones developed under Label 2020.

Stakeholder outreach to investigate “grey” area requirements and their associated risks, and to collect inputs from various stakeholders on how they interpret or enforce them. The Consultant should consider consultative workshops with the following stakeholders – European Commission officers, ADCO/MSAs, retailer associations/retailers, supplier associations, consumer and environmental NGOs, experts and other interested professionals.

  • Preparing Harmonized Online Labelling Compliance Guidelines for MSAs.

The guidelines should outline relevant regulatory provisions along with guidance for complying with them. The Guidelines should address, clarify and answer “grey area” issues and frequently asked questions – if any changes to the regulations are recommended, the recommendations will feed into Task 1 of this project.  The Guidelines must be informed by the desktop research and stakeholder inputs, primarily MSAs.

These Guidelines will provide MSAs with a common understanding on how to interpret online labelling requirements and how to enforce online labelling in practice.

  • Consulting with Market Surveillance Authorities an finalizing the Guidelines.

The Consultant in collaboration with CLASP should seek early support and engagement from the EU ADCO and individual MSAs on the development and future use of the Guidelines. The Consultant will be expected to present the draft Guidelines to the ADCO and key MSAs, as well as relevant European Commission officials, before finalizing them. The Consultant in collaboration with CLASP will seek commitment from at least 10 MSAs and the ADCO Chair to adopt or endorse the Guidelines and apply them at the national level.

  • Preparing Online Labelling Compliance Guidelines for Online Retailers.

The retailer guidelines should build on the MSA guidelines, with detailed guidance on where and how exactly the respective energy labelling information and documents should be made available to consumers on e-shops, as well as what the consequences of non-compliance will be. The Guidelines should be illustrative and provide easy-to-understand guidance on proper label display. They will detail roles, responsibilities and recommendations for the different categories of stakeholders involved.

Several other guidance documents have been developed under Label 2020 and other projects, and by several MSAs. This CLASP guidance, rather than present a summary of the regulations, will focus on aspects specific to online labelling and provide a detailed, illustrated explanation of what is acceptable or not for each aspect of the requirements. The Consultant must review existing materials to ensure the CLASP guidelines build on and fill gaps from what is already available, while preventing conflicts and duplications. Endorsement by the ADCO will be key to ensure that these guidelines constitute a suitable response to the issue of misalignment between MSAs that was reported in CLASP´s (2021) “Study to evaluate online energy labelling compliance in the EU”.

  • Preparing a brief dissemination and promotion strategy for the MSA and Retailer Guidelines in collaboration with CLASP.

This should outline key stakeholders and mechanisms for dissemination and promotion, to ensure use of the Guidelines across the EU.

  • Promoting Guidelines for Retailers and MSAs:

For the Retailer Guidelines, the Consultant will implement the dissemination and promotion strategy, in collaboration with CLASP. Initial ideas should be clarified in the technical proposal and reflected in the financial proposal.

Promote the Guidelines to MSAs and solicit their agreement to use the Guidelines in national market surveillance activities. The Consultant in collaboration with CLASP will work with the ADCO to distribute the Guidelines to all MSAs and secure commitments to use the Guidelines. The Consultant together with CLASP will host a webinar for EU policy makers, EU members’ national governments and MSAs´ representatives to introduce the Guidelines and solicit their commitment to reference the Guidelines in their market surveillance efforts. The Consultant should explore opportunities to partner with MSAs and other EU market surveillance projects to pilot the Guidelines. The Project Team will prepare the presentation, list of participants and invitations. CLASP will set up the webinar platform, send invitations and communicate the event.

We welcome the Consultant to submit the costs associated with translating the both, MSA and Retailer Guidelines into all EU languages.

Key Milestones and Deliverables

All materials must be prepared in English.

  1. Inception report for project, detailing initial progress on the project, issues identified (and plans for resolution) and next steps
  2. Task 1 draft and final documents for EU policy makers with identified provisions for revisions, supporting evidence for recommending revisions, and recommendations on clarifying and simplifying legislative requirements for online labelling
  3. Task 2 draft and final Online Energy Labelling Compliance Guidelines for the MSAs that include detailed guidance on how to comply with online labelling requirements and agreed-upon guidance to address non-compliance cases
  4. Task 2 draft and final Online Energy Labelling Compliance Guidelines for Retailers explaining how to comply with online labelling requirements
  5. Task 2 Dissemination/Communication strategy, strategy implementation, webinar presentation materials.

Key Qualifications

  • Knowledge of EU energy labeling legislation and understanding EU energy efficiency policymaking ecosystem
  • Experience and demonstrated ability to conduct stakeholder consultations and consumer surveys, especially for energy labeling (for Task 1)
  • Experience with and understanding of appliance and equipment standards and labeling policies and their implementation and enforcement 
  • Demonstrated success of working with retailers and consumer groups, as well as with European and National policy officials and market surveillance bodies  
  • Experience in communication and awareness creation among various stakeholder groups

Evaluation Procedure

A committee appointed by CLASP will evaluate proposals received. Selection of qualified companies or organizations will be based upon the following criteria:

  • Technical Evaluation Factors
  • Financial Evaluation Factors

All bids will be evaluated and ranked using Quality and Cost Based Selection (QCBS), with 80 percent of the score accorded to the technical proposal, and 20 percent to the financial proposal. The detailed evaluation criteria can be found in Annex A.


Register as a Consulting Partner

Interested parties must register as a CLASP Consulting Partner.

Submit Technical and Financial Proposals

Interested parties should submit separate technical and financial proposals electronically, in English, via this form link (preferably in PDF format). The files should be named as per the following example:

[CONTRACTOR_NAME] _Technical Proposal_ RFP 2022-03-19

[CONTRACTOR_NAME] _Financial Proposal_ RFP 2022-03-19

The length of the technical proposal should not exceed 20 pages and should include:

  • Detailed approach and methodology for the design, implementation, and management of the project
  • Detailed timeline for all project activities, tasks, milestones, and deliverables for the project within the time frame indicated above
  • Background and experience of conducting similar activities
  • A summary of qualifications and experience of key personnel that will execute the project

The financial proposal (in USD) should include a detailed budget with all direct and indirect cost estimates for executing the project, including a breakdown (in days) of the level of effort and costs associated with each team member that will be engaged in the project.

CVs and related summaries of experience and qualifications of proposed project team staff should be included in an Annex and should not exceed 10 pages.

CLASP looks forward to reviewing your responses and would like to thank you in advance for your participation in this Request for Proposals. CLASP will notify all respondents who submit proposals when a decision has been made.

Optional At This Stage – Fill Out Pre-Qualification Questionnaire (PQQ)

All contractors must fill out the PQQ before working with CLASP. This can be voluntarily completed at the RFP stage but will be mandatory if a contract is awarded.

The PQQ is a thorough due diligence screening aimed at gathering legal and financial information on prospective partners/vendors. Contract awards are conditional upon passing the due diligence screening. If questions are not applicable, please type “N/A” and go to the next question. While the form can be saved, we recommend completing it in one sitting to avoid potential complications. We will be notified once you submit the PQQ.

Organizations that have already completed the PQQ do not need to complete it again unless the structure of the business has changed. If you are unsure, please email Andrea Testa ( to determine next steps.


Technical Approach (40 points): The technical approach described in the proposals will be evaluated on:

  • The demonstrated understanding of the overall project context (15).
  • The detailed work plan and approach clearly defining the target objectives and the strategy to achieve the objectives as outlined in the scope of work (25). 

Management Structure and Staff Qualification (20 points): The proposed management structure and staff will be evaluated on:

  • The professional qualifications and the extent to which the requisite expertise and experience of the key personnel will directly contribute to the completion of the tasks (20).

Past Performance and Corporate Experience (20 points): The experience and capacities of the contractor will be evaluated based on:

  • The past performance, familiarity, and experience in understanding policies and program related to standards and labelling (10).
  • Extent of local expertise including experience, qualifications, and track record in implementation of similar programs (10).

Cost Evaluation Factors (20 points): While the overall Technical Evaluation is the key factor in reviewing the proposal, the cost evaluation will be an essential factor in determining the final contract award and ability to remain in the competitive range and will be evaluated for feasibility, completeness, and practicality.


This section provides some identifies examples of unclear or redundant regulatory requirements that will inform this project. The examples, which are adapted from the findings of the “Study to evaluate online energy labelling compliance in the EU”, commissioned and published by CLASP in June 2021, are as follows:

Energy label placement. The energy label should be placed “in the proximity to the price”, while some e-shops place the label to the product picture gallery, in product description, or other locations.

Specifying different types of pages for label display such as product specific pages, catalogue pages, comparison pages, and basket pages. The EC’s FAQ site provides the explanation, but labels missing in sites other than the product pages are a very common among e-shops.

Usage of the product information sheets, which are required to be displayed in all instances along energy labels. A proper display of product information sheets is a common non-compliance case among e-shops. However, how frequently these documents are used by the consumers and what is their value?

Regulating marketplaces. Marketplaces represent a growing segment of online sales, but currently, the marketplace organizers’ duty is to only provide the space for energy labels and inform their suppliers about such requirement (for some product categories). They are not being held responsible for online labeling non-compliance in their marketplaces.

Note that the project did not seek to establish an exhaustive list of all “grey areas” of the online labelling legislation but identified and discussed several cases for potentially clarifying or simplifying the requirements.


CLASP looks forward to reviewing your responses and would like to thank you in advance for your participation in this Request for Proposals. CLASP will notify all respondents who submit proposals when a decision has been made.


CLASP is an equal opportunity employer that celebrates diversity and are committed to creating an inclusive environment for all employees. CLASP’s goal is to be a diverse workforce that is representative, at all job levels, of the citizens we serve. CLASP complies with all federal, state and local employment law in the countries we operate and is committed to providing equal opportunity for all employees and applicants without regard to race, color, religion, national origin, sex, age, marital status, sexual orientation, gender identity or expression, pregnancy, disability, political affiliation, personal appearance, family responsibilities, matriculation, genetic information, military or protected veteran status, credit information or any other characteristic protected under federal, state or local law.

Each person is evaluated based on personal skill and merit. CLASP’s policy regarding equal employment opportunity applies to all aspects of employment, including recruitment, hiring, job assignments, promotions, working conditions, scheduling, benefits, wage and salary administration, disciplinary action, termination, and social, educational and recreational programs.


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