Energy Label Update: China Requires Energy Labels on 10 More Product Categories — Key Takeaways

China has expanded its mandatory energy label (能效标识, Energy Label, néngxiào biāoshí) requirements to include 10 new product categories, effective March 1, 2025, expanding the total number of regulated product types to 58. This expansion, jointly announced by the National Development and Reform Commission (NDRC) and the State Administration for Market Regulation (SAMR), targets products ranging from commercial refrigeration equipment to network standby devices, with compliance deadlines staggered through late 2025.

This update marks the most significant expansion of China’s energy labeling program since its inception in 2005. Foreign manufacturers exporting to China must now assess whether their products fall under the new categories and prepare for testing, registration, and labeling requirements. Non-compliance can result in fines of up to RMB 100,000 (approximately USD 14,000) per product model, as well as restrictions on market access.

Contextual numbers: The 10 new categories add to the existing 48 regulated product categories, representing a 20.8% increase in coverage. The expansion is projected to save 12 million tonnes of coal equivalent annually by 2030, reducing CO2 emissions by approximately 30 million tonnes. China’s energy label system now covers over 50% of residential energy consumption and 40% of commercial energy use.

Background of China’s Energy Label System

China introduced its mandatory energy label system in 2005 under the Energy Conservation Law (中华人民共和国节约能源法, Zhōnghuá Rénmín Gònghéguó Jiéyuē Néngyuán Fǎ). The system is administered by the China National Institute of Standardization (CNIS) under the supervision of SAMR and NDRC. Initially covering only 4 product categories — refrigerators, air conditioners, washing machines, and electric water heaters — the system has grown steadily over two decades.

The energy label itself displays a color-coded rating from Grade 1 (most efficient) to Grade 5 (least efficient), along with specific energy consumption data for each model. Products must be tested at CNAS-accredited laboratories in China or recognized overseas facilities, and the label must be registered with the CNIS Energy Label Database before products can be sold in China.

The driving force behind this latest expansion is China’s “dual carbon” goals of peaking CO2 emissions by 2030 and achieving carbon neutrality by 2060. By mandating energy labels on more product types, regulators aim to push manufacturers toward higher efficiency standards and help consumers make informed purchasing decisions.

The 10 New Product Categories

The 10 new categories span residential, commercial, and industrial applications. Below is the full list of affected products along with their mandatory implementation dates:

Products manufactured before the effective date have a 6-month transition period to sell existing inventory without labels, but all new production must comply from the effective date onward. Foreign manufacturers should note that products imported into China after the effective date must have the energy label affixed prior to customs clearance.

Compliance Requirements and Timeline

To comply with the updated regulation, manufacturers and importers must follow a multi-step process:

1. Product Assessment: Determine if your product falls under any of the 10 new categories. Products that straddle multiple categories should consult with a certification expert.
2. Laboratory Testing: Have the product tested at a CNAS-accredited laboratory. Testing can be conducted in China or at recognized labs in the EU, US, Japan, or South Korea, though in-country testing is recommended for faster turnaround.
3. Registration: Submit test reports and product data to the CNIS Energy Label Database (www.energylabel.gov.cn) for registration. A unique energy label number will be issued upon approval.
4. Label Printing and Affixing: The label must be printed according to GB standards and affixed to the product in a visible location. Labels must include the product model, energy efficiency grade, and annual energy consumption.
5. Annual Reporting: Manufacturers must report annual production volumes and energy consumption data to CNIS for continued compliance.

The total cost of compliance per product model typically ranges from RMB 30,000 to RMB 100,000 for testing and registration, depending on the product complexity and number of variants. For foreign manufacturers, additional costs may include translation, legal representation, and logistics for sample shipping.

Implications for Foreign Manufacturers

Foreign manufacturers exporting to China face several specific challenges under this expanded system. First, testing must be conducted on products that represent “typical” Chinese market configurations, which may differ from products sold in other markets. Second, the label itself must be in Chinese, including all technical terms and energy data. Third, foreign companies must designate a Chinese legal representative (境内代理人, jìngnèi dàilǐrén) to handle registration and ongoing compliance reporting.

The timeline is particularly pressing for categories effective March 1, 2025 — commercial refrigeration, network standby devices, and indoor unit heaters. Manufacturers of these products should begin testing immediately to allow for the 12-16 week turnaround time for laboratory testing and registration. Products that miss the deadline may be held at customs or face market withdrawal orders.

For servers and data storage equipment (effective June 1, 2025), this is the first time China has required energy labels for IT infrastructure equipment. Global server manufacturers should pay close attention to the specific PUE calculation methodology required by CNIS, which may differ from international standards such as ISO 15005 or the Green Grid’s PUE framework.

Three Common Pitfalls for Foreign Manufacturers