Updating standards for local space heating products (accessible webpage)

Question 1

Executive summary

Accepted Answer

Introduction

Ecodesign regulations enable the government to set minimum energy performance standards (MEPS) to remove poorly performing products from the market - ensuring consumers benefit from lower energy costs by running efficient products and incentivising manufacturers to produce higher-efficiency products.

Ecodesign policies have contributed significantly to our energy security, reducing yearly electricity demand by an estimated 24.5TWh over the last decade, comparable to the 25TWh output of Sizewell C nuclear power plant. They have delivered 59 MtCO2e carbon savings since 2010 and are a highly cost-effective way to reduce emissions and bills and achieve our net zero goals in a way that benefits consumers and businesses.

This consultation concerns the current ecodesign regulations for electrically powered, gas and, liquid fuelled local space heater products, 2015/1188. We are proposing to repeal these regulations and replace them with a new statutory instrument, a proposed draft version of which is attached. We estimate that adopting these measures across Great Britain will facilitate energy demand reduction of around 6TWh (4TWh in electricity and 2TWh in gas) by 2050. This option would constitute a social-Net Present Value (NPV) of £470m to 2050. This figure will vary by the fuel type and method of operation of each product.

The main proposals in this consultation are:

Increasing scope and minimum product efficiency standards
Requirement for product controls, for products to provide heat
Circular economy and repair measures to increase product lifespan

The new proposed ecodesign requirements detailed in this document would align Great Britain with the European Union (EU) and Northern Ireland, providing equivalent standards to those set out in Regulation (EU) 2024/1103. We believe an aligned regulatory environment will reduce the compliance burden for manufacturers, improving product access for consumers. Related policies, on ecodesign for solid fuel local space heating products and regulations on labelling are not in the scope of this consultation and will be consulted on separately in due course.

We are considering combining ecodesign regulations for World Trade Organisation (WTO) notification purposes. We will submit a formal notification in due course, accompanying later regulations in this package.

Proposals

We are seeking feedback on our proposals to improve local space heating product standards through updated ecodesign legislation. In doing so we are seeking to avoid unnecessary barriers within the United Kingdom’s internal market and trade between Great Britain, Northern Ireland and key trading partners, including the EU. As such, the proposals set out in this consultation seek consistency with EU ecodesign regulations, which have applied since 1 July 2025. This would facilitate smoother trade relations, reduce administrative burdens for manufacturers, and ensure that consumers have access to more efficient products. We also propose enhancing the efficiency of new products, to ensure that energy is consumed effectively, and to promote circular economy aspects such as right to repair.

The policies we are proposing in this consultation are grouped into three sections. The first section concerns the performance of local space heating products: scope, performance evaluation and performance requirements of products. The second section concerns controlling the power output of products, through the use of controls on providing heat. The final section contains policies on right-to-repair, consumer information, and protection.

Enhancing efficiency of products (Part 1)

As the local space heating market innovates, regulation is an effective tool to remove outdated technology from the market. This can be achieved in two ways; broadening products’ regulatory scope and increasing performance requirements. The proposals outlined in this consultation broaden scope through:

the inclusion of externally driven supplementary heating units (also referred to commercially as slave heaters) in ecodesign requirements
requirement for a form of control (including ‘related’ controls for externally driven supplementary heating units) on a local space heating product to allow heat output
increasing minimum performance standards to reflect technological advances
separation of ‘towel rails’ from the ‘fixed electric’ product group
reduction of the Primary Energy Factor Conversion Coefficient (CC) to 1.9
changes of definitions of categories
changes to methodology of calculating MEPS
reduction of maximum nitrogen oxide emission limits

Encouraging effective energy consumption (Part 2)

Alongside minimum efficiencies outlined (Part 1) for each of the 15 product categories, we are proposing measures to ensure energy is consumed effectively. One principal method of driving this is using controls applied to local space heating devices. To ensure that the efficiency of controls is accurately accounted for, we are proposing to implement the following changes:

additional definition of a ‘related control’ by operability
requirements for use of a form of control to provide heat
requirement for each product to have an idle, low-power or off mode

Supporting a circular economy (Part 3)

The final aspect of our proposals relate to new requirements regarding product documentation. This includes the ability to be approved as a professional repairer and ensuring the ability to access spare parts and repair information. These measures will empower consumers to repair their appliances, extending their useful life and reducing the need to produce new products unnecessarily. The new requirements include:

process for approved installer status
access to repair information
providing certain spare parts
changes to required document and phrasing
a specific ban on circumvention and use of defeat devices.

Consultation Impact

We welcome your feedback on the proposals in this consultation document, the accompanying draft statutory instrument and options assessment. We will aim to publish a government response shortly after the closing date for responses to this consultation has passed, and after the feedback received has been considered.

A glossary of terms can be found in Annex A. The full list of the questions asked in this consultation is included in Annex B.

Question 2

General Information

Accepted Answer

Why we are consulting

Improving product standards can save consumers money by reducing their bills, whilst cutting carbon emissions and increasing energy security. Product regulations, such as those set out in ecodesign are an effective lever to help reduce greenhouse gas emissions to net zero by 2050.

We welcome views and evidence on the proposals set out in this consultation document, draft Statutory Instrument (SI) and options assessment.

Consultation details

Issued: 25 March 2026

Respond by: 11.55pm on 20 May 2026

Enquiries to:

Energy-Related Products Team
Department for Energy Security and Net Zero
3-8 Whitehall Place
London
SW1A 2EG

Email: localspaceheaters@energysecurity.gov.uk

Consultation reference: Raising standards for local space heating products

Audiences:

Manufacturers, manufacturers authorised representatives, retailers, importers, trade bodies, consumer groups, environmental organisations and other civil society organisations or individuals with an interest in local space heating products.

Territorial extent:

The proposed updates to ecodesign regulations set out in this consultation would apply to Great Britain. To facilitate dual access to both the UK Internal Market and the EU Single Market, Northern Ireland continues to apply EU ecodesign and energy labelling regulations in accordance with the Windsor Framework. As the UK Government is looking to align standards in Great Britain with those of the EU, goods compliant with these aligned standards will also be able to be placed on the market in Northern Ireland. At the same time, Northern Ireland businesses will continue to have unfettered access to the market in Great Britain. The proposals set out in this consultation facilitate smooth trade between Great Britain and Northern Ireland.

How to Respond

We strongly encourage responses via the online survey. Using the online survey greatly assists our analysis of the responses, enabling more efficient and effective consideration of the issues raised. If it is not possible for you to use the online survey, you can respond through email or a written response.

Respond online at: https://energygovuk.citizenspace.com/heat/ecodesign regulations-local-space-heating-products

or

Email to: localspaceheaters@energysecurity.gov.uk

Write to:

Energy-Related Products Team
Department for Energy Security and Net Zero
3-8 Whitehall Place
London
SW1A 2EG

When responding, please state whether you are responding as an individual or representing the views of an organisation. Your response will be most useful if it is framed in direct response to the questions posed, though further comments and evidence are also welcome.

Confidentiality and data protection

Information you provide in response to this consultation, including personal information, may be disclosed in accordance with UK legislation (the Freedom of Information Act 2000, the Data Protection Act 2018 and the Environmental Information Regulations 2004).

Please notify us if you wish for your information to remain confidential, noting that we cannot guarantee confidentiality in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not be regarded by us as a confidentiality request.

We will process your personal data in accordance with all applicable data protection laws. See our privacy policy.

We will summarise all responses and publish this summary on GOV.UK. The summary will include a list of names or organisations that responded, but not people’s personal names, addresses or other contact details.

Quality assurance

This consultation is being carried out in accordance with the government’s consultation principles. If you have any complaints about the way this consultation has been conducted, please email: bru@energysecurity.gov.uk.

Product coverage and extent of regulation

Local space heating relates to a broad category of products designed and marketed to provide thermal comfort to people. Typical products in scope of these regulations are electric radiators, storage heaters, and open fronted gas fires. Representative categories in scope of these proposals, sourced from GOV.UK are described using the WTO commodity codes in Table 1^{[footnote 1]}. This consultation does not address energy labelling, which is regulated separately for these product categories, currently by 2015/1186.

Furthermore, ecodesign measures for local space heating products which use a solid fuel are not in the scope of this regulation, with ecodesign requirements regulated by Commission Regulation (EU) 2015/1185^{[footnote 2]}. We will consult in due course on updated measures relating to this product type, and energy labelling.

Table 1: List of commodity codes and their definitions, covering products in scope for the ecodesign proposals outlined in this consultation

Code	Descriptor
732181	Stoves, heaters, grates, fires, wash boilers, braziers and similar appliances, of iron or steel, for gas fuel or for both gas and other fuels (excluding cooking appliances, whether or not with oven, separate ovens, plate warmers, central heating boilers.
732182	Stoves, heaters, grates, fires, wash boilers, braziers and similar appliances, of iron or steel, for liquid fuel (excluding cooking appliances, whether or not with oven, separate ovens, plate warmers, central heating boilers, geysers, hot water cylinders.
732189	Stoves, heaters, grates, fires, wash boilers, braziers and similar domestic appliances, of iron or steel, for solid fuel or other non-electric source of energy (excluding liquid or gaseous fuel, and cooking appliances, whether or not with oven, separate ovens, plate warmers, central heating boilers, hot water cylinders and large cooking appliances).
732190	Parts of domestic appliances non-electrically heated of heading 7321

Question 3

Part 1: Enhancing efficiency of products

Accepted Answer

Technological advances which have occurred since the last regulation (2015/1188)^{[footnote 3]} have led to a series of advanced heating controls, separately marketed and sold, entering the market. To ensure regulation remains relevant, the scope of ecodesign regulations should reflect these changes in usage. Proposed policy changes to scope and performance are outlined in this chapter, with those relating specifically to the use of controls outlined in Part 2.

Reflecting the change in technology mix across the local space heating product category, we are proposing changes to the methodology of calculating seasonal space heating efficiency. This would ensure that the relative energy consumption of products using gas, liquid, or electricity as the main power source are accurately reflected in primary terms. As outlined in this chapter, the proposed efficiency-based changes include:

an increase in scope to include ‘externally driven supplementary heating units, which have previously not been considered in scope of ecodesign regulation
changes to other product classifications for ecodesign evaluation purposes, separating significantly different technologies, such as towel rails, which were previously considered ‘fixed electric’ local space heaters
a reduction of maximum allowed nitrogen oxide emission limits to reflect an increase in efficiency of the market
changes to the methodology used to calculate Seasonal space heating efficiency
reduction of the Primary Energy CC from 2.5 to 1.9, to better reflect the efficiency of electric heat generation, relative to fossil fuel use

Chapter 1: Product scope and categorisation

Introduction

This consultation contains a diverse range of products and technology types, aimed at providing indoor thermal comfort. Ensuring that the category definitions accurately represent the technologies within this product space is therefore crucial. In this chapter, changes relative to the existing regulation (2015/1188) are proposed. Given the difference in technology and fuel consumption, we believe that 15 product categories best balances the broad range of technology types in scope for this regulation, while allowing ecodesign thresholds which accurately represent the technology available.

In existing regulation (2015/1188), there are 12 product categories. There is ambiguity over the inclusion of products such as towel rails, which has led to some products being considered out of scope, despite evidence that consumers may benefit from ecodesign regulation applying.

To better reflect the technology in the market, we are proposing changes to the scope and definitions of product categories used to set minimum energy performance standards. This will enable the use of appropriate minimum standards for each technology type. The changes to scope are broken down in this section, per product type.

Product category definitions

This consultation proposes definitions of 15 categories of local space heating products, with minimum energy performance standards set relative to the technical capabilities of products within that category. Draft SI Schedule 1 outlines the product definitions in full. Changes made to product categories are outlined in Table 2.

Table 2: Proposed changes to the product category definition of local space heating products, relative to existing regulation

Product type	Change to existing definition
Open fronted local space heaters and open to chimney local space heaters	No change to definition
Closed fronted open combustion local space heaters	No change to definition
Balanced flue local space heaters	New product category
Electric portable local space heaters	Minor scope change
Electric fixed local space heaters > 250W	Towel rails removed from category
Electric fixed local space heaters ≤ 250W	Towel rails removed from category
Electric storage local space heaters	No change to definition
Electric underfloor local space heaters	Minor scope change
Fixed electric visibly glowing radiant local space heaters > 1.2kW	No change to definition
Fixed electric visibly glowing radiant local space heaters ≤ 1.2kW	No change to definition
Electric visibly glowing radiant portable local space heaters	New product category
[electric] towel rails > 250W	Separated from fixed electric
[electric] towel rails > 60W and ≤ 250W	Separated from fixed electric
Luminous local space heaters	No change to definition
Tube local space heaters	No change to definition

Product categories without change

Relative to the existing definitions per 2015/1188, we are not proposing changes to the definitions of the following product categories:

closed fronted open combustion
electric local space heater
electric visibly glowing radiant local space heater
electric storage local space heaters
luminous local space heaters
open fronted local space heaters
tube local space heaters

Question 1

Do you believe that the product category definitions outlined above should be modified from their current state? Please provide evidence or reasoning to support your answer.

Heaters incapable of operation without control

A domestic ‘externally driven supplementary heating unit’ is defined as a heater not capable of operating without a form of control. Having previously been considered out of scope in the previous 2015/1188 regulation, we believe that there is sufficient market or consumer demand for inclusion. This would ensure that consumers can benefit from ecodesign measures, whilst having access to the diverse range of ‘related’ controls which are marketed and sold separately from local space heating products.

Question 2

Do you have views on the proposed change to include ‘externally driven supplementary heating units’ in the scope of ecodesign regulations? Please provide evidence or reasoning to support your answer.

Alongside the energy demand reduction achieved through more efficient products, we are proposing a requirement for heat output to be controlled for Local Space Heating products.

Question 3

Do you have a view on whether the requirement for a form of control, such as a timer, on a local space heating product represents a benefit to consumers? Please provide evidence or reasoning to support your answer.

Balanced flue

Balanced flue local space heaters use gas or liquid fuel and operate with a partitioned flue system that both supplies combustion air and expels exhaust gases externally. This differs from open combustion, as the products of combustion are sealed from the space to be heated. Previously in scope as part of the ‘closed combustion’ product definition, we have proposed in the draft SI that they have their own category, given their increasing market share.

Question 4

Do you agree to include a definition of balanced flue local space heating product category as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.

Electric portable

Previously, portable heaters were defined by excluding several types: storage, underfloor, radiant, visibly glowing, and externally driven supplementary heating units. Additional products which were covered under the scope, had ecodesign requirements incorporated into the categories of their fixed equivalents. The new proposed definition shifts to a positive description, requiring the heater to have a cord and plug, be movable between rooms, and not need fixing to a location. It also narrows exclusions to only visibly glowing radiant portable heaters.

Question 5

Do you agree to include a definition of electric portable local space heating product category as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.

Electric fixed

We are proposing to amend the definition of electric fixed local space heater to account for the product categories which now have separate ecodesign requirements. To account for this, towel rails, portable electric local space heaters, and electric underfloor local space heating products are now specifically excluded from the definition in this category, with their own category and performance requirements established.

Question 6

Do you agree to include a definition of electric fixed local space heating as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.

Electric underfloor

For avoidance of ambiguity, we are proposing that the phrasing ‘including self-regulating cables and mats’ be added to the existing definition of electric underfloor local space heating products.

Question 7

Do you have any views on the proposed change to the definition of Electric underfloor local space heating products as set out in attached draft SI Schedule 1? Please provide evidence or reasoning to support your answer.

Electric visibly glowing radiant portable

While the definition of electric visibly glowing radiant local space heaters is retained, a new category, accounting for their portable equivalent has been made.

Question 8

Do you agree to include a definition of electric visibly glowing radiant portable local space heating products as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.

Towel rails

To avoid misinterpretation, we propose that towel rails are newly defined and separated from the category ‘fixed local space heater’ in existing regulation. Further, we propose that towel rails are split by category by power consumption: < 60W, 60W < x ≤ 250W and >250W.

Question 9

Do you have views on the proposal to separate ecodesign performance of towel rails from fixed electric local space heaters? Please provide evidence or reasoning to support your answer.

Question 10

Do you have views on the proposal to categorise ecodesign performance of towel rails as equal to or below 60W, above 60W, and equal to or below 250 W, and above 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Power consumption

Applying to all products, we are proposing to increase the range of power consumption which the ecodesign regulations apply. If the proposals for power limits be adopted, the domestic local space heaters of 0W to 50kW which would be in scope are:

open fronted local space heaters and open to chimney local space heaters
closed fronted open combustion local space heaters
balanced flue local space heaters
electric portable local space heaters
electric fixed local space heaters >250W
electric fixed local space heaters ≤ 250W
electric storage local space heaters
electric underfloor local space heaters
fixed electric visibly glowing radiant local space heaters >1.2kW
fixed electric visibly glowing radiant local space heaters ≤ 1.2kW
electric visibly glowing radiant portable local space heaters
towel rails >250W
towel rails >60W and ≤ 250W

Question 11

Do you have views on the proposed increased scope set at 50kW or lower for domestic local space heating products as set out in paragraph 3a of the draft SI? Please provide evidence or reasoning to support your answer.

If the proposals for power limits be adopted, the commercial local space heaters of 0W to 300kW which would be in scope are:

luminous local space heaters
tube local space heaters (single tube power consumption)

Question 12

Do you have views on the proposed increased scope set at 300 kW or lower for commercial local space heating products as set out in paragraph 3b of the draft SI? Please provide evidence or reasoning to support your answer.

Question 13

Do you feel the product categories proposed in this consultation accurately reflect the distribution of products sold on the market in Great Britain? How do you view this changing in the next 5 to 10 years? Please provide evidence or reasoning to support your answer.

Speciality and multi-function products

We are proposing 15 product categories for the purpose of ecodesign evaluation, with the intention of each product within scope of this regulation fitting a single category. To avoid unintended consequences for products with multiple purposes, we have also provided exclusion criteria for such multi-functional products. We expect that cooking products, and those with outside applications in particular should be considered out of scope of this regulation.

Given the breadth of scope of this proposed regulation, we welcome the views of those who have identified any potential issues in complying with the ecodesign requirements proposed in this consultation, resulting from multi-functional applications or accidental inclusion in scope.

Question 14

Do you believe that the proposed regulatory changes, as set out in the attached draft SI, could restrict or affect the ability of manufacturers to bring multi-functional products to market? Please provide evidence or reasoning to support your answer.

Chapter 2: Calculating efficiency of products

Introduction

One measure of efficiency of a heat generating product such as those in the scope of this regulation is Seasonal Space Heating Efficiency (SSHE). This measure produces a single value drawn from a series of parameters relating to a local space heater, including heat output, energy consumption, and control functionality.

The current methodology used to calculate SSHE, in regulation 2015/1188 differs from current EU methodology, which we are proposing to align with. One factor driving a change to SSHE methodology is the need to reduce the Primary Energy Factor Conversion Coefficient. Under the methodology outlined in 2015/1188, we assess that a reduction of this value would unbalance the efficiency measures between fuel types, leading to misleading efficiency comparisons between products.

Efficiency calculation methodology

We are proposing for the methodology used to calculate SSHE to be updated, to accurately reflect the efficiency of products and their related controls and additionally provide a more effective balance between products of differing fuel types. Parameters currently used in the calculation of SSHE are set out in Annex C, with proposed formula changes in Annex D.

Question 15

Do you have a view on the testing methodologies currently used to calculate parameters used in seasonal space heating efficiency calculations? Please provide evidence or reasoning to support your answer.

Question 16

What innovation do you envisage in the local space heating product area will be driven by this proposed regulatory change? Please provide evidence or reasoning to support your answer.

Testing methods

Many parameters used to calculate SSHE require experimental determination, which is carried out using British Standard (BS) or European Norms (EN) testing methods. There are three categories of standards used to determine methods for product testing.

Harmonised standard: A standard developed specifically to facilitate compliance with an EU regulation (such as an ecodesign regulation), published by one of the approved EU standardisation bodies. It is a detailed description of the testing and calculation methods required to comply with the regulation. Application of the standard to a product creates a presumption of conformity with the ecodesign or energy labelling requirements of the regulation that it relates to.

Designated standard: Great Britain’s version of harmonised standards. Any harmonised standard can be made into a designated standard^{[footnote 4]}, and indeed most designated standards are also harmonised standards.

Transitional method: If harmonised standards are not available when a regulation is adopted by the EU, transitional methods are published, which set out the testing and calculation methods to be used until harmonised standard are available. Transitional methods are either an exhaustive description of the method or refer to existing standards developed for other purposes^{[footnote 5]}.

We are proposing to allow the use of transitional methods (annex F)^{[footnote 6]}, which will be replaced by designated standards once the harmonised standard is published and adopted by the EU in due course.

Question 17

Do you have any views on the proposal to include designated standards? Please provide evidence or reasoning to support your answer.

Question 18

Do you have any views on the validity and current day relevance of the ‘transitional’ testing methods, hosted on the designated standards website? Please provide evidence or reasoning to support your answer.

Primary energy factor

Primary energy is energy that has not undergone any conversion or transformation process, for example oil or gas. Secondary energy is generated by converting or transforming this primary energy, for example electricity generated by burning fossil fuels. The primary energy factor describes the efficiency of converting energy from primary sources (for example, renewables such as wind, solar hydropower or fossil fuels such as coal or crude oil) to a secondary energy carrier (for example, electricity, natural gas) that provides energy services delivered to end-users.

Less energy is lost when converting from renewables to electricity, than from burning fossil fuels to generate electricity. Therefore, as the electricity grid decarbonises, we can expect the primary energy factor for electricity to reduce. The Home Energy Model for the Future Homes Standard consultation proposed a primary energy factor for electricity of 1.969^{[footnote 7]} for England and Wales. The government response to this consultation is expected in due course. However, the proposed figure is similar to the updated figure proposed by the European Commission in 2023. In 2023, the European Commission updated the primary energy factor in the Energy Efficiency Directive to a conversion coefficient of 1.910, to better reflect the energy mix of electricity in the EU.

Lowering the primary energy factor conversion coefficient

To better reflect the energy mix across the UK, we are proposing to reduce the conversion coefficient to 1.9, from the current 2015/1188 value of 2.5. We feel that this change is necessary to ensure that the increased efficiency of using electrically powered local space heating products (owing to the greater fraction of renewable electricity generation sources compared to 2015) is accurately reflected. Whilst the proposed new value of 1.9 is slightly below the 1.969 reported for the UK in 2023, the current clean energy transition is expected to reduce the value further through the duration of this proposed SI. In matching the EU, we anticipate that ecodesign standards’ calculations will be simplified, supporting the internal market.

Question 19

Do you agree with lowering the primary energy factor for electricity to 1.9 as set out in draft SI schedule 1? Please provide evidence or reasoning to support your answer.

Chapter 3: performance thresholds

Introduction

The proposed changes to MEPS are set out as minimum SSHE thresholds for each of the 15 product categories defined in Chapter 1, alongside 4 additional ecodesign requirements.

Given the need to rebalance the formula used to calculate SSHE, the thresholds required for each product must also be altered. The differences between calculations mean that direct comparison between numerical values of the existing 2015/1188 regulations and differences in magnitude of SSHE threshold do not necessarily indicate a change in MEPS threshold. From an efficiency requirement perspective, thresholds proposed in the SI are kept broadly similar to existing levels, with less than 36% of products expected to be excluded on efficiency grounds compared to 2015 standards thresholds. Most of the estimated 6,119GWh energy savings are associated with the increase in scope, meaning local space heating products which previously had no ecodesign regulations would be required to meet these proposals.

Product efficiency thresholds

Question 20

We propose that the seasonal space heating energy efficiency of open fronted local space heaters and open to chimney local space heaters must not be less than 40.3%.

Do you agree with the proposed threshold for open fronted and open to chimney local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 21

We propose that the seasonal space heating energy efficiency of closed fronted open combustion local space heaters must not be less than 63.6%.

Do you agree with the proposed threshold for closed fronted open combustion local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 22

We propose that the seasonal space heating energy efficiency of balanced flue local space heaters must not be less than 63.6%.

Do you agree with the proposed threshold for balanced flue local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 23

We propose that the seasonal space heating energy efficiency of electric portable local space heaters must not be less than 44.7%.

Do you agree with the proposed threshold for electric portable local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 24

We propose the seasonal space heating energy efficiency of electric fixed local space heaters with a nominal heat output above 250 W, except towel rails, must not be less than 47.5%.

Do you agree with the proposed threshold for electric fixed local space heating products of nominal output above 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 25

We propose that the seasonal space heating energy efficiency of electric fixed local space heaters with a nominal heat output equal or below 250W, except towel rails, must not be less than 43.1%.

Do you agree with the proposed threshold for electric fixed local space heating products of nominal output equal to or below 250 W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 26

We propose that the seasonal space heating energy efficiency of electric storage local space heaters must not be less than 47.3%.

Do you agree with the proposed threshold for electric storage local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 27

We propose that the seasonal space heating energy efficiency of electric underfloor local space heaters must not be less than 47.5%. 27.

Do you agree with the proposed threshold for electric underfloor local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 28

We propose that the seasonal space heating energy efficiency of electric visibly glowing radiant local space heaters with a nominal heat output above 1.2kW, except electric visibly glowing radiant portable local space heaters, must not be less than 46.8%.

Do you agree with the proposed threshold for electric visibly glowing radiant local space heaters with a nominal heat output above 1.2kW, except electric visibly glowing radiant portable local space heaters local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 29

We propose that the seasonal space heating energy efficiency of electric visibly glowing radiant local space heaters with a nominal heat output equal or below 1.2kW, except electric visibly glowing radiant portable local space heaters, must not be less than 40.5%.

Do you agree with the proposed threshold for electric visibly glowing radiant local space heaters with a nominal heat output equal or below 1.2kW, except electric visibly glowing radiant portable local space heaters local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 30

We propose that the seasonal space heating energy efficiency of electric visibly glowing radiant portable local space heaters must not be less than 39.5%.

Do you agree with the proposed threshold for electric visibly glowing radiant portable local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 31

We propose that the seasonal space heating energy efficiency of luminous local space heaters must not be less than 90.0%.

Do you agree with the proposed threshold for luminous local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 32

We propose that the seasonal space heating energy efficiency of tube local space heaters must not be less than 80.0%.

Do you agree with the proposed threshold for tube local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 33

We propose that the seasonal space heating energy efficiency of towel rails with a nominal heat output above 250W must not be less than 46.0%.

Do you agree with the proposed threshold for towel rails with a nominal heat output above 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 34

We propose that the seasonal space heating energy efficiency of towel rails with a nominal heat output above 60W and equal or below 250W must not be less than 42.1%.

Do you agree with the proposed threshold for towel rails with a nominal heat output above 60W and equal or below 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.

Question 35

We are proposing that the thresholds for performance defined in this section will apply at the point at which the product is placed on the market^{[footnote 8]}. As a result, manufacturers will be required to demonstrate that a product is compliant at this point, rather than alternative points, such as the point when a product is ‘put into service’^{[footnote 9]}.

Do you have a view on whether the requirements should apply at the point of being ’placed on the market’, or at point of ‘coming into service’. Please provide evidence or reasoning to support your answer.

Question 36

Aside from costs associated with complying with new minimum performance standards, do you expect there to be any additional costs associated with aligning Great Britain’s regulatory standards with the EU? Please provide evidence or reasoning to support your answer.

Nitrogen oxide emission limits

Nitrogen oxide is a by-product of combustion of gas and liquid fuels, associated with negative health outcomes in local areas. For product categories which produce nitrogen oxide, new thresholds are proposed in Table 3.

Table 3: Maximum nitrogen oxide emissions in milligrams per kilowatt hour energy (mg/kWh) input in existing Great Britain regulations and proposed new emissions limits

Local space heater type	Previous threshold	Proposed threshold
Closed fronted open combustion	130	120
Max nitrogen oxide emissions	130	120
Proposed threshold	130	120
Open fronted	130	120
Balanced flue	130	120
Flueless	130	120
Open to Chimney	200	180
Luminous Tube	200	180

Question 37

Do you have views on the new proposed nitrogen oxide limits as set out in the SI draft Schedule 1 part 7? Please provide evidence or reasoning to support your answer.

Question 38

Do you foresee any technical feasibility issues with complying with the proposed nitrogen oxide emission limits? Please provide evidence or reasoning to support your answer.

Question 4

Part 2: Encouraging effective energy consumption

Accepted Answer

Improving product efficiency alone is not enough to deliver the full benefits of ecodesign regulation. Products must also operate in a way that avoids unnecessary energy use. This section sets out proposals to ensure local space heaters only provide heat when required, through appropriate controls and low-power modes. These measures complement the minimum efficiency requirements in Part 1 and aim to reduce wasted energy, lower bills, and cut emissions.

Product lifetimes for controls are significantly shorter than the lifetime of local space heating products, at 4 to 5 years, compared to 14 years for a local space heating product. In regulating the use of separately related controls, it is expected that controllers can be replaced by more functional and efficient ones, reducing the need for scrappage of older products with inefficient control.

The proposals in this section account for the change in use of controls, ensuring their use is appropriately regulated. Additional efficiency measures, aimed to avoid a local space heater running indefinitely can additionally contribute meaningful energy demand reduction.

Chapter 4: Regulating delivery of heat

Introduction

Existing regulations on local space heating products do not include requirements on the use of a related control, including ecodesign and minimum requirements. The proposals in this chapter outline their use, and minimum requirements required to enable output from a local space heater.

Products without a form of control have historically been excluded from the ecodesign regulation in Great Britain, leading to a large number of products on the market not being subject to the regulations. This has allowed inefficient products to enter the market, requiring more energy to provide heating, and increasing household bills unnecessarily.

A second issue with the existing regulation is that technological developments of controls systems, including networked controllers are not accounted for. To maximise the benefits for consumers, we are proposing an approach for Great Britain which is aligned with the EU and accurately reflects the efficiency benefits which a related control can provide.

Definition of a control

A ‘control’ in the context of this consultation is a device which regulates the ability of a local space heating product to provide heat to an area. We are proposing 17 definitions of a related control, based on function, which are accounted for during evaluation of SSHE. The controls defined in this regulation are:

adaptive start control
black bulb sensor
control accuracy
distance control option
electronic room temperature control
electronic room temperature control plus day timer
electronic room temperature control plus week timer
mechanic thermostat room temperature control
idle mode
network
networked standby
off mode
self-learning
single stage heat output, no temperature control
standby mode
2 or more manual stages, no room temperature control
working time limitation

Question 39

Do you have views on the categorisation of control functions which can be provided to local space heaters as set out in paragraph 2 of the draft SI? Please provide evidence or reasoning to support your answer.

Minimum requirements on heat control

In addition to SSHE requirements to assess the efficiency of a product, we are proposing 3 criteria for ecodesign requirements of local space heating products.

Criteria 1: Electric storage local space heaters shall be equipped with electronic heat charge control with room and outdoor temperature feedback and fan assisted heat output.

Criteria 2: Towel rails with a nominal heat output equal or below 60W shall only be operable through a working time limitation with a maximum pre-set period of time no longer than 6 hours.

Criteria 3: Electric local space heaters placed on the market without control shall not be able to provide heat output without control.

Question 40

Do you have views on the proposal to require electronic heat charge control with temperature feedback, and fan-assisted heat output as set out in draft SI Schedule 1? Please provide evidence or reasoning to support your answer.

Question 41

Do you have views on the proposed time limitation of towel rails of ≤60W heat output as set out in the draft SI Schedule 1? Please provide evidence or reasoning to support your answer.

Question 42

Do you have views on the proposed requirement for all local space heating products to require control to provide heat output as set out in draft SI Schedule 1? Please provide evidence or reasoning to support your answer.

Power consumption whilst not in active use

Alongside ecodesign requirements, we are proposing that the power consumptions of the product be limited whilst not actively providing heat. These measures, outlined per mode in tables 4 to 6 intend to align with the EU regulation 2023/826, which we intend to consult on separately in due course.

Proposed power consumption requirements

Table 4: Proposed maximum permitted power consumption of local space heaters with inbuilt control by mode

Proposed requirements	Proposed maximum power consumption (W)
Off mode	0.3
Standby mode	Related to functionality, see standby mode table 5
Idle mode	Related to functionality, see idle mode table 6

Proposed standby mode

Table 5: Proposed maximum permitted power consumption of local space heating products in standby mode

Standby mode type	Proposed power consumption (W)
Display information or status	1
Provides a networked standby mode	2
Wireless communication between heat generator and control	3
All other cases	0.5

Proposed idle mode table

Table 6: Proposed maximum permitted power consumption of local space heating products in idle mode

Idle mode type	Proposed power consumption (W)
If local space heaters require input form a network	3
All other cases	1

Question 43

Do you agree with the proposed power consumption thresholds in off, idle mode or standby mode as set out in Schedule 2 of the draft SI? Please provide evidence or reasoning to support your answer.

Question 5

Part 3: Supporting a circular economy

Accepted Answer

Alongside energy demand during operation, another key contributor to emissions from local space heating products are associated with production and disposal of the products. There are clear benefits to introducing circularity measures to local space heating for consumers and wider society, with reduced environmental damage from materials’ extraction. In allowing access to spare parts and repair information, we expect to promote longer product lives and greater resource efficiency, disincentivising the need for product replacement at the first instance of an operating fault.

In this part of the consultation, we are proposing a series of measures, to support repair in Great Britain. In doing this, we hope to promote a culture of repair in relation to energy-related products.

Chapter 5: Right to repair

Introduction

This section contains proposals to support circular economy measures, listing specific spare parts and durations for which a manufacturer should supply them.

In ensuring the provision of spare parts, it is possible to repair local space heating products which would otherwise be disposed of. Whilst difficult to quantify the impacts of these measures, the savings associated with right to repair are widely understood to be positive.

Spare part availability

Spare part supply is a crucial aspect of promoting the right to repair. The full proposed list of spare parts required to be provided by suppliers of LSH products is outlined in Annex E, encompassing parts such as controls, circuit boards, sensors and switches.

We are proposing that manufacturers should ship these parts within 10 working days, allowing approved installers to conduct timely repair of products.

Question 44

Do you have views on how the proposed requirement to provide spare parts as set out in Schedule 1 of the draft SI may impact the amount of raw materials used to produce local space heating products? Please provide evidence or reasoning to support your answer.

Question 45

Do you have views on the proposed requirement for manufacturers to make available spare parts for local space heating products (see Annex E), and how this compares to current stock strategy? Please provide evidence or reasoning to support your answer.

Question 46

Do you have views on the proposed required time scale of 10 working days to ship these parts as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.

Access to information on repair for installers

While we are advocating for the provision of spare parts to enable repair of local space heating products, we are aware that some appliances, especially gas powered ones, should only be maintained by a professional repairer. A balance of ensuring repair information is accessible, but only to approved repairers is therefore likely to be important.

To enable this, we propose that manufacturers, importers or approved representatives must set out a process, described on their website, for access to repair information for supported local space heater products. Before granting access to repair information, manufacturers must require the repairer to demonstrate sufficient technical competence (for example, Gas Safe registration) and insurance for liabilities.

Question 47

Do agree with the proposed requirement for manufacturers to provide information to professional repairers, contingent on suitability checks as set out in Schedule 1 of the draft SI ? Please provide evidence or reasoning to support your answer.

Question 48

Do you have views on how the suitability check of a professional repairer should be conducted? Please provide evidence or reasoning to support your answer.

Question 49

To facilitate timely access to repair information, we are proposing that the manufacturer, importer, or approved representative evaluate this information within 5 working days, approving or rejecting the request. Once approved, we propose that repair information should be available within 1 working day.

Do you have views on the proposed requirement and timelines for registering a ‘professional repairer’, or providing repair information as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.

Question 50

What impact (if any) do you feel that these proposals (or others in this document, please state) will have on small and medium businesses? Please provide evidence or reasoning to support your answer.

Chapter 6: Consumer protection

Introduction

We wish to ensure that consumers are provided with adequate information to make informed choices on operation of local space heating products. On this basis, we are proposing to ensure that phrasing and performance documentation are adequately signposted for consumers.

Circumvention refers to the intentional changes in performance characteristics of a local space heating product under test. Using defeat devices, software, or firmware updates, manufacturers can set a product to obtain a more favourable result for standards testing than it would under normal operation.

The use of such methods increase emissions of more carbon and other greenhouse than estimated, resulting in greater fuel consumption and increased bills for consumers.

Circumvention

We propose that manufacturers should be prohibited from circumventing testing of energy-related products. Examples of such circumvention include changes to firmware to artificially run a ‘test’ programme, changing parameters used to calculate SSHEE, or ‘defeat devices’ which recognise that they are under test, and modify behaviour in a related way^{[footnote 10]}.

Question 51

Do you have views on the proposed inclusion of a provision banning the use of circumvention measures, such as firmware or software updates as set out in the paragraph 8 of the draft SI? Please provide evidence or reasoning to support your answer.

Documentation and mandatory phrasing

To ensure the local space heating products are used as intended, we are proposing a series of mandatory requirements on the packaging and marketing. This will include both operational controls, indicating control requirements, and phrasing for marketing and on safe usage.

Control functions

As outlined in the draft SI, Schedule 1, Part 5, we are proposing a requirement that manufacturers include information on the type of temperature control that a ‘related control’ can provide.

We are proposing that the control be split into two sections, firstly the type of temperature control, function numbers, based on the type of control which it can provide. The full table is set out in the draft SI, Table 6. 52.

Question 52

Do you have views on the proposed mandatory phrasing for products which require a separate related control as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.

‘Flueless’ and ‘Open to chimney’ local space heaters

In addition to the phrasing around the use of a control function, we are proposing to retain existing mandatory phrasing from the existing regulation of flueless and open to chimney local space heaters. We are proposing that the phrasing ‘This product is not suitable for primary heating purposes’ be featured prominently, on the product packaging, on the front cover of the manual of the product, and with the characterisation of the product on free access manufacturer websites.

Question 53

Do you have views on the proposed mandatory phrasing for flueless and open to chimney local space heaters as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.

Review

Should the proposals in the consultation be implemented, we will ensure that a review of their impact is completed. This will include assessment of the benefits and impact to consumers and business across the UK, and whether the scope of products included should be modified. We will also assess whether the thresholds remain suitable, with reference to technological developments. To allow sufficient time for policy impact review, we are proposing that a policy review be conducted after implementation on or before 9 May 2031.

Question 54

In the absence of regulatory changes in Great Britain, to what extent would industry voluntarily observe EU regulation? Please provide evidence or reasoning to support your answer.

Question 55

Do you have views on the proposed date for review of local space heating regulations as proposed? Please provide evidence or reasoning to support your answer.

Question 6

Alignment with the EU regulation

Accepted Answer

We are aware that the EU has recently published draft amendments^{[footnote 11]} to the existing text of 2024/1103. We are proposing to align with these draft amendments and this intention should be reflected in our draft SI. The only caveat is that we are proposing to retain article 6. Our approach to the changes in the amendment are as follows:

changes to tables - we are intending to align the updates to tables with the EU amendment
changes to technical definitions- we are intending to align our definitions with the amended EU regulations
circumvention - we are intending to retain the ban on circumvention, aligned with the current text of article 6 of 2024/1103, although the EU is removing this in favour of cross cutting regulation
designated standards - we are intending to align the definitions in designated standards

Question 56

Do you have any views on the proposals to adopt the text amended by the EU? Please provide evidence or reasoning to support your answer.

Question 7

Equality Act 2010

Accepted Answer

Under the Public Sector Equality Duty, the government must take steps to understand how policies will affect different groups in society in different ways, with a particular focus on removing or minimising disadvantages suffered by people due to the following protected characteristics: age; gender reassignment; being married or in a civil partnership; being pregnant or on maternity leave; disability; race including colour, nationality, ethnic or national origin; religion or belief; sex; and sexual orientation. Warm homes and thermal comfort play a crucial role in maintaining our health and wellbeing. Evidence suggests that in homes with a lower level of thermal comfort, elderly, pregnant and disabled groups may be particularly affected and at an elevated risk of negative health outcomes.

Question 57

Do you have views on the extent to which this policy may affect people with protected characteristics under the 2010 Equality Act? Please provide evidence or reasoning to support your answer.

Question 8

Annex A: glossary

Accepted Answer

This annex defines technical references and phrases used throughout this public consultation document.

CE marking: the Conformité Européenne (CE) mark is the conformity mark used in the EU showing that a product meets all the relevant EU requirements and has been assessed as such.

Commodity codes: an internationally recognised method for defining types of goods for customs purposes as they are traded between countries. When a product is imported or exported across a border, a commodity code must be provided so the correct customs measures are applied.

Ecodesign: the legislative framework for setting the MEPS for energy-related products, including for space heating appliances. Ecodesign aims to phase out the least efficient energy-related products from the market through these standards and other measures.

Externally driven supplementary heating units: product marketed for the purpose of providing thermal comfort to humans in an indoor space which cannot operate without an input from an external control. These products are also referred to as ‘slave’ heating units.

Local space heater: a local space heating product is designed and marketed specifically to provide thermal comfort in an enclosed area.

Mandatory phrasing: specific requirements to include detail or wording relating to the use case or specifics of a product.

Minimum Energy Performance Standards (MEPS): minimum requirements set out in ecodesign legislation. Factors such as energy efficiency, fuel type, and control functions are accounted for to produce a single figure, used to evaluate each product within a category.

Related control: a device which is both marketed and sold separately from a local space heating product, which is capable of regulating its ability to provide and moderate its operation.

Right to repair: a series of measures designed to ensure that customers are able to repair their products, extending their usable lifespan.

Statutory Instrument: Statutory Instruments are the most common form of secondary (or delegated) legislation. The power to make a statutory instrument is set out in legislation and nearly always conferred on a Minister of the Crown.

UKCA marking: the United Kingdom Conformity Assessment (UKCA) mark is the conformity mark used in the UK. It shows that a product meets all the relevant EU requirements and has been assessed as such.

Windsor Framework: an agreement between the EU and the UK, aimed to ease the supply of goods between Great Britain, Northern Ireland and the Republic of Ireland.

Question 9

Annex B: list of consultation questions

Accepted Answer

This public consultation contains 57 questions, which will help government to assess the viability of the proposed SI. Questions contained in the public consultation are as follows:

Do you believe that the product category definitions outlined above should be modified from their current state? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed change to include ‘externally driven supplementary heating units’ in the scope of ecodesign regulations? Please provide evidence or reasoning to support your answer.
Do you have a view on whether the requirement for a form of control, such as a timer, on a local space heating product represents a benefit to consumers? Please provide evidence or reasoning to support your answer.
Do you agree to include a definition of balanced flue local space heating product category as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.
Do you agree to include a definition of electric portable local space heating product category as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.
Do you agree to include a definition of electric fixed local space heating as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.
Do you have any views on the proposed change to the definition of electric underfloor local space heating products as set out in attached draft SI Schedule 1? Please provide evidence or reasoning to support your answer.
Do you agree to include a definition of electric visibly glowing radiant portable local space heating products as set out in the attached draft SI, Schedule 1? Please provide evidence or reasoning to support your answer.
Do you have views on the proposal to separate ecodesign performance of towel rails from fixed electric local space heaters? Please provide evidence or reasoning to support your answer.
Do you have views on the proposal to categorise ecodesign performance of towel rails as equal to or below 60W, above 60, and equal to or below 250W, and above 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed increased scope set at 50kW or lower for domestic local space heating products as set out in paragraph 3a of the draft SI? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed increased scope set at 300kW or lower for commercial local space heating products as set out in paragraph 3b of the draft SI? Please provide evidence or reasoning to support your answer.
Do you feel the product categories proposed in this consultation accurately reflect the distribution of products sold on the market in Great Britain? How do you view this changing in the next 5 to 10 years? Please provide evidence or reasoning to support your answer.
Do you believe that the proposed regulatory changes, as set out in the attached draft SI, could restrict or affect the ability of manufacturers to bring multi-functional products to market? Please provide evidence or reasoning to support your answer.
Do you have a view on the testing methodologies currently used to calculate parameters used in seasonal space heating efficiency calculations? Please provide evidence or reasoning to support your answer.
What innovation do you envisage in the local space heating product area will be driven by this proposed regulatory change? Please provide evidence or reasoning to support your answer.
Do you have any views on the proposal to include designated standards? Please provide evidence or reasoning to support your answer.
Do you have any views on the validity and current day relevance of the ‘transitional’ testing methods, hosted on the designated standards website? Please provide evidence or reasoning to support your answer.
Do you agree with lowering the Primary Energy Factor for electricity to 1.9 as set out in draft SI schedule 1? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for open fronted and open to chimney local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for closed fronted open combustion local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for balanced flue local space heating products as set out in the draft SI Schedule 1 Part 2 ? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric portable local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric fixed local space heating products of nominal output above 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric fixed local space heating products of nominal output equal to or below 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric storage local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric underfloor local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric visibly glowing radiant local space heaters with a nominal heat output above 1.2kW, except electric visibly glowing radiant portable local space heaters local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric visibly glowing radiant local space heaters with a nominal heat output equal or below 1.2kW, except electric visibly glowing radiant portable local space heaters local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for electric visibly glowing radiant portable local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for luminous local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for tube local space heating products as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for towel rails with a nominal heat output above 250W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed threshold for towel rails with a nominal heat output above 60W and equal or below 25W as set out in the draft SI Schedule 1 Part 2? Please provide evidence or reasoning to support your answer.
Do you have a view on whether the requirements should apply at the point of being ’placed on the market’, or at point of ‘coming into service’. Please provide evidence or reasoning to support your answer.
Aside from costs associated with complying with new minimum performance standards, do you expect there to be any additional costs associated with aligning Great Britain’s regulatory standards with the EU? Please provide evidence or reasoning to support your answer.
Do you have views on the new proposed nitrogen oxide limits as set out in the draft SI Schedule 1 part 7? Please provide evidence or reasoning to support your answer.
Do you foresee any technical feasibility issues with complying with the proposed nitrogen oxide emission limits? Please provide evidence or reasoning to support your answer.
Do you have views on the categorisation of control functions which can be provided to local space heaters as set out in Paragraph 2 of the draft SI? Please provide evidence or reasoning to support your answer.
Do you have views on the proposal to require electronic heat charge control with temperature feedback, and fan-assisted heat output as set out in the draft SI Schedule 1? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed time limitation of towel rails of ≤60W heat output as set out in the draft SI Schedule 1? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed requirement for all local space heating products to require control to provide heat output as set out in the draft SI Schedule 1? Please provide evidence or reasoning to support your answer.
Do you agree with the proposed power consumption thresholds in off, idle mode or standby mode as set out in Schedule 2 of the draft SI? Please provide evidence or reasoning to support your answer.
Do you have views on how the proposed requirement to provide spare parts as set out in Schedule 1 of the draft SI may impact the amount of raw materials used to produce local space heating products? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed requirement for manufacturers to make available spare parts for local space heating products (see Annex E), and how this compares to current stock strategy? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed required time scale of 10 working days to ship these parts as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.
Do agree with the proposed requirement for manufacturers to provide information to professional repairers, contingent on suitability checks as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.
Do you have views on how the suitability check of a professional repairer should be conducted? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed requirement and timelines for registering a ‘professional repairer’, or providing repair information as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.
What impact (If any) do you feel that these proposals (or others in this document, please state) will have on small and medium businesses? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed inclusion of a provision banning the use of circumvention measures, such as firmware or software updates as set out in the paragraph 8 of the draft SI? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed mandatory phrasing for products which require a separate related control as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed mandatory phrasing for flueless and open to chimney local space heaters as set out in Schedule 1 of the draft SI? Please provide evidence or reasoning to support your answer.
In the absence of regulatory changes in Great Britain, to what extent would industry voluntarily observe EU regulation? Please provide evidence or reasoning to support your answer.
Do you have views on the proposed date for review of local space heating regulations as proposed? Please provide evidence or reasoning to support your answer.
Do you have any views on the proposals to adopt the text amended by the EU? Please provide evidence or reasoning to support your answer.
Do you have views on the extent to which this policy may affect people with protected characteristics under the 2010 Equality Act? Please provide evidence or reasoning to support your answer.

Question 10

Annex C: parameters used for SSHE calculations

Accepted Answer

Parameter	Name	Description
η_s	SSHE	The ratio between the space heating demand, supplied by a local space heater and the annual energy consumption required to meet this demand, expressed in %.
η_S,RF		The emission efficiency, expressed in %.
η_S,th		The weighted thermal efficiency, expressed in %.
η_th,nom		The useful efficiency at nominal heat output, expressed in %.
η_s,on		Seasonal space heating in active mode.
CC	Primary Energy Factor Conversion Coefficient	(CC) means the default coefficient for primary energy per kWh.
RF_S		Radiant factor of the commercial local space heater, expressed in %.
F(1)	Correction factor 1	A correction factor accounting for a negative contribution to seasonal space heating efficiency due to adjusted contributions for options for the heat output, expressed in %.
F(2)	Correction factor 2	A correction factor accounting for a positive contribution to the seasonal space heating energy efficiency due to adjusted contributions of controls of indoor heating comfort, the values of which are mutually exclusive, cannot be added to each other.
F(3)	Correction factor 3	A correction factor accounting for a positive contribution to the seasonal space heating energy efficiency due to adjusted contributions of controls for indoor heating comfort, the values of which can be added to each other.
F(4)	Correction factor 4	A correction factor accounting for a negative contribution to the seasonal space heating energy efficiency by auxiliary electricity consumption, expressed in %.
F(5)	Correction factor 5	A correction factor accounting for a negative contribution to the seasonal space heating energy efficiency by energy consumption of a permanent pilot flame, expressed in %.
F_env		The envelope losses of the heat generator, expressed in %.

Question 11

Annex D: proposed formula changes

Accepted Answer

The table in this annex details key formula used to calculate efficiency in the proposed SI. (We’ve converted the table to text for accessibility).

For clarity, the equivalent formula in the existing Great Britain regulations is provided. Parameter definitions are in included in the SI.

Seasonal space heating efficiency η_S

Existing formula (GB 2015/1188)

Commercial:

η_S,on – 10% F(1) – F(4) – F(5)

Non-commercial:

η_S,on – 10% F(1) + F(2) + F(3) – F(4) – F(5)

Proposed formula (SI draft)

Commercial:

η_S,on – F(1) – F(4) – F(5)

Liquid and gas (non-commercial):

η_s,on

Electric:

η_S,on

Existing formula (GB 2015/1188)

All parameters, except electric and commercial:

η_th,nom

Electric:

Commercial:

η_S,th x η_S,RF

Proposed formula (SI draft)

Non-commercial:

η_th,nom x (0.75 + F(2) + F(3) x F(4) X F(5)

Commercial:

η_S,th

Proposed formula (SI draft)

Tube:

(0.15 x η_th,nom + 0.85 η_th,min – F_env

Emission efficiency η_S,RF

Proposed formula (SI draft)

Commercial:

Radiant factor RF_s

Proposed formula (SI draft)

All commercial (except tube):

0.15 RF_nom + 0.85 RF_min

Tube:

F(1), F(2) and F(3)

There are no changes proposed to these formulae. You can find out more in the draft SI.

F(4)

Existing formula (GB 2015/1188)

Electric:

Gas or liquid:

Commercial:

Proposed formula (SI draft)

Electric:

= 1

Gas or liquid:

Commercial:

F(5)

Existing formula (GB 2015/1188)

Gas or liquid:

Commercial:

Proposed formula (SI draft)

Electric:

= 1

Gas or liquid:

Commercial:

Question 12

Annex E: spare part requirements

Accepted Answer

As part of this proposal to raise ecodesign standards, we are advocating for a requirement to provide a range of spare parts, giving consumers the ‘right to repair’ their products through the use of an approved installer. The spare part requirements in the proposed SI are dependent on the type of local space heater, listed below.

For electric portable local space heaters and electric visibly glowing radiant portable local space heaters:

control
ambient thermostat (only for electric portable local space heaters)
motor for heaters equipped with a fan (only for electric portable local space heaters)
printed circuit boards
display or status indicators
impellers
control sensors
buttons and switches
remote control sensors

For electric fixed local space heaters, towel rails and electric underfloor local space heaters:

control
ambient thermostat
floor sensor (only for electric underfloor local space heaters)
repair kit for heating cables (only for electric underfloor local space heaters)
fixation brackets (if needed)
printed circuit boards
display or status indicators
impellers
control sensors
buttons and switches
remote control sensors

For electric storage local space heaters:

heating elements
control
safety switches
connection cables
housing for mechanical parts
fixation brackets
fans and impellers
printed circuit boards
display or status indicators
control sensors
buttons and switches
remote control sensors

For electric visibly glowing radiant local space heaters, except electric visibly glowing radiant portable local space heaters:

control
heating elements
connection cables
fixation brackets
printed circuit boards
display or status indicators
impellers
control sensors
buttons and switches

Question 13

Annex F: transitional methods

Accepted Answer

Transitional methods used to calculate efficiency of local space heaters are listed below.

Gaseous fuel local space heaters

Transitional methods for parameter calculation, relating to gaseous fuel local space heaters, except luminous heaters and tube heaters.

Direct heat output

Reference: EN 613:2021 §7:11

Heat output to the space in which the product is installed. Calculated using the formula:

Direct heat output = Q_n * η

Where Q_n is nominal heat output, and η is the nominal efficiency. Direct heat output shall be calculated as Gross Calorific Value.

Indirect heat output

For the purpose of declaration and verification the principles as applied in EN16510-1 maybe used.

Useful efficiency at nominal heat output

Parameters:

η_{th, nom} , η_{th, min}

References:

EN 613:2021 § 7.11.2
EN 1266:2002 § 6.12 & § 7.12.2
EN 13278:2013 § 6.12 & § 7.12.2

In EN 613, η_{th, nom} , η_{th, min} shall be calculated as η in conditions applicable to the nominal and minimum heat output, if relevant.

In EN 1266 and EN 13278, η_{th, nom} corresponds to η if determined with nominal heat input. η_{th, min} corresponds to η if determined with minimum heat input.

All values shall be based on net calorific value.

Nominal heat output, minimum heat output

Parameters:

P_nom, P_min

References:

EN 613:2021
EN 1266:2002 § 6.3.1 & § 6.3.3 & § 7.3.1 & § 7.3.5 § 6.12 & § 7.12
EN 13278:2013 § 6.3.1 & § 6.3.3 & § 7.3.1 & § 7.3.5 & § 6.12 & § 7.12.2
EN 449:2002+A1:2007 § 5.15.1 & § 5.15.2 & § 6.15.1 & § 6.15.2

In EN 613 P_nom shall be determined as P_nom = Q_n * η, applicable to nominal output conditions.

For Q_n * η see § 7.3.1.

P_min shall be determined as P_min = minimum heat output * η.

For minimum heat output see § 7.3.5.

In EN 1266, EN 13278:2013 and EN 449, P_nom shall be determined by P_nom = Q_n * η_{th, nom}

P_{th, min} shall be determined by P_min = Q_n * η_{th, min}

Electrical power consumption at nominal heat output

Parameter:

el _max

Reference:

EN 15456:2008: § 5.1.3.1

Where el _max corresponds to P_aux,100 measured at nominal load operation.

Electrical power consumption at minimal heat output

Parameter:

el _min

Reference:

EN 15456:2008: § 5.1.3.2

Where el _min corresponds to P_aux,30 measured at part load operation.

Electrical power consumption on standby

Parameter:

el _sm

Reference:

EN 15456:2008: § 5.1.3.3
EN 50564:2011 § 5.3

Where el _sm corresponds to either P_aux,sb (EN 15456:2008) or the term ‘power consumption in standby mode’ (EN 50564:2011)

Emissions of nitrogen oxide

References:

EN 613:2021 § 7.7.4
EN 1266:2002 § 7.7.4 & Annex G
EN 13278:2013 § 7.7.4 & Annex H
EN 14829:2007 § 7.9.4 (for flueless heaters)

For EN 613, EN 1266, and EN 13278, emissions are established as weighted values over the full-modulating minimum load conditions.

EN 14829 provides a test method for flueless heaters.

Permanent pilot flame power

Parameter:

P_pilot

Reference:

EN 1266:2002 § 7.3.4

EN613 and EN13278 are omitted as they do not describe how to calculate the heat input of the ignition burner.

Control accuracy and control setpoint deviation

The control accuracy for gaseous fuel local space heaters is not described in EN standards. For the purpose of declaration and verification the principles as applied in EN 15500-1 shall be used.

Liquid fuel local space heaters

Transitional methods for parameter calculation, relating to liquid fuel local space heaters, except luminous heaters and tube heaters.

Direct heat output

Reference: EN 613:2021 §7:11

Heat output to the space in which the product is installed. Calculated using the formula:

Direct heat output = Q_n * η

Where Q_n is nominal heat output, and η is the nominal efficiency. Direct heat output shall be calculated as gross calorific value.

Indirect heat output

The indirect heat output of liquid fuel local space heaters is not described in EN standards. For the purpose of declaration and verification the principles as applied in EN 16510-1 shall be used.

Useful efficiency at nominal and minimum heat output

Parameters:

η_{th, nom} , η_{th, min}

References:

EN 1:1998 § 6.6.1.2
EN 13842:2004 § 6.5.6

For EN 1, η_{th, nom} corresponds to η at maximum flow rate, and η_{th, min} shall be determined as η at minimum oil flow rate.

For EN 13842, is calculated as η_{th, nom} = 1 - q_A , where q_A is measured at nominal/minimum heat output.

All values shall be based on net calorific value.

Nominal heat output, minimum heat output

Parameters:

P_nom, P_min

References:

EN 1:1998/A1:2007 § 6.5.2.1
EN 13842:2004: § 6.3

EN 1: Parameter corresponds to P at maximum ( P_nom ) and minimum ( P_min ) oil flow rate.

EN 13842: For nominal and minimum conditions, heat output can be calculated as:

Q_o * ( 1 - q_a )

Electrical power consumption at nominal heat output

Parameter:

el _max

Reference:

EN 15456:2008: § 5.1.3.1

Parameter el _max corresponds to P_aux,100 in EN 15456.

Electrical power consumption at minimal heat output

Parameter:

el _min

Reference:

EN 15456:2008: § 5.1.3.2

Parameter el _min corresponds to P_aux,100 in EN 15456.

Standby power mode power consumption

Parameter:

P_sm

Reference:

EN 15456:2008: § 5.1.3.3
EN 50564:2011 § 5.3

EN15456: Corresponds to P_aux,sb

EN 50564: Corresponds to the power consumption in standby mode

Emissions of nitrogen oxides

References:

EN 1:1998/A1:2007 § 6.6.4
EN 13842 Annex C7

For declaration and verification the method according to EN 1 shall be used.

Permanent pilot flame power

Parameter:

P_pilot

Reference:

EN 1266:2002 § 7.3.4

For declaration and verification of such a power requirement the method as in EN1266:2002, § 7.3.4 shall be used.

Control accuracy and control setpoint deviation

The control accuracy of liquid fuel local space heaters is not described in EN standards.

For the purpose of declaration and verification the principles as applied in EN 15500-1 shall be used.

Electric local space heaters

Transitional methods for parameter calculation, relating to electric local space heaters.

Nominal heat output

Parameter:

P_nom

Reference:

EN 60675:1995/A11:2019 Clause 16C (for electric portable, fixed heaters and underfloor heaters)
EN 60531:2000/A11:2019 § 9.3 (or electric storage heaters)

Following EN 60675:1995/A11:2019 if there is no indirect heat output the maximum continuous heat output (clause 16A) will be equal to the nominal heat output.

‘nom’ corresponds to the following applicable standards:

IEC/EN 60335-1: Household and similar electrical appliances rated voltage of 250V for single phase appliances, up to 480 V for others, not intended for appliances for domestic use as usual
IEC/EN 60335-2-30: Household and similar electrical appliances, particular requirements for room heaters
IEC/EN 60335-2-43: Household and similar electrical appliances - part 2-43 give particular requirements for clothes dryers and towel rails
IEC/EN 60335-2-61: Household and similar electrical appliances, particular requirements for thermal storage room heaters
IEC/EN 60335-2-96: Household and similar electrical appliances, particular requirements for flexible sheet heating elements for room heating
IEC/EN 60335-2-106: Household and similar electrical appliances, particular requirements for heated carpets and for heating units for room heating
IEC/EN 60531:1991. Household electric thermal storage room heaters, methods for measuring performance

Maximum continuous heat output

Parameter:

P_max,c

References:

EN/IEC 60675:1995/A11:2019 Clause 16A (for electric portable, fixed heaters and underfloor heaters)
EN/IEC 60675:1995/A11:2019 Clause 16A

Parameter P_max,c corresponds to the usable power in IEC 60675.

Standby mode power consumption

Parameter:

P_sm

Reference:

EN 50564:2011 § 5.3

Corresponds to the parameter ‘power consumption in standby mode’.

F(2) and F(3)

Reference:

EN 60675:1995/A11:2019 § 17 (for electric portable, fixed heaters and underfloor heaters)

EN 60675 provides test methods for all control functions corresponding to F(2) and F(3), except for control accuracy and self-learning functionality.

Control accuracy and control to setpoint deviation

Reference:

EN 15500-1:2017 § 5.4 & § 6

Luminous and tube local space heaters

Transitional methods for parameter calculation, relating to luminous heaters and tube heaters.

Useful efficiency at nominal and minimum heat output

Parameters:

η_{th, nom}, η_{th, min}

References:

EN 416:2019 § 7.6.5 (tube local space heaters with tube segments other than strips)
EN 17175:2019 (tube local space heaters which tube segments are strips)

Nominal heat output, minimum heat output

Parameters:

P_nom, P_min

References:

EN 419:2019 (luminous local space heaters)
EN 416:2019 (tube local space heaters with tube segments other than strips)
EN 17175:2019 (tube local space heaters which tube segments are strips)

For luminous and tube local space heaters, the heat output is calculated at nominal heat or minimum output per:

heat output = Q_n * useful fuel efficiency

All values shall be based on gross calorific value of fuel.

Envelope loss factor

Parameter:

F_env

Reference:

EN 1886:2007 § 8.2.1

Use of F_env depends on class T1 to T5 as established by EN 1886.

Radiant factor (nominal and minimum)

Parameters:

RF_nom, RF_min

References:

EN 419:2019: § 7.6.3 (luminous local space heaters)
EN 416:2019 § 7.5.3 (tube local space heaters)
EN 17175:2019 (tube local space heaters in which tube segments are strips)

RF at nominal heat output corresponds to R_f in the standard.

RF at minimum heat output corresponds to R_f but measured at minimum heat output.

Calculation of shall be based on net calorific value.

Electrical power consumption at nominal heat output

Parameter:

el_max

References:

EN 416:2019 § 6.4.2
EN 419:2019 § 6.8.2
EN 17175:2019

Electrical power consumption at minimum heat output

Parameter:

el_min

References:

EN 416:2019 § 6.4.3
EN 419:2019 § 6.8.3
EN 17175:2019

Standby mode power consumption

Parameter:

P_sm

References:

EN 416:2019 § 6.4.4
EN 419:2019 § 6.8.4
EN 17175:2019
EN 50564:2011

Corresponds to power consumption in standby mode in EN 50564.

Permanent pilot flame power

Parameter:

P_pilot

Neither standard EN 416 nor EN 419, nor EN 17175 describes a method for determining a power requirement for a permanent pilot flame (ignition burner). For declaration and verification of such a power requirement the method as in EN1266:2002, § 7.3.4 shall be used.

Controls

Transitional methods for parameter calculation, relating to local space heating controls.

Off mode

Parameter:

P_o

References:

EN 15500-1:2017 § 5.3.2 & § 6.1
EN 50564:2011 § 5.3

EN 15500-1 defines the basic layout for testing controls separately from the local space heater, although it does not set out a specific method for testing off mode. A specific method for low power modes of household electrical appliances is laid down in EN 50564:2011, where the corresponding adaptations must be made to check controls.

Standby mode

Parameter:

P_sm

References:

EN 15500-1:2017 § 5.3.2 & § 6.1
EN 50564:2011 § 5.3

EN 15500-1 defines the basic layout for testing controls separately from the local space heater, although it does not set out a specific method for testing standby mode. A specific method for low power modes of household electrical appliances is laid down in EN 50564:2011, where the corresponding adaptations must be made to check controls.

Idle mode

Parameter:

P_idle

Reference:

EN 15500-1:2017 § 6.2.1

Networked standby mode

Parameter:

P_nsm

Reference:

EN 15500-1:2017 § 5.3.2 & § 6.1
EN 50564:2011 § 5.3

EN 15500-1 defines the basic layout for testing controls separately from the local space heater, although it does not set out a specific method for testing networked standby mode. A specific method for low power modes of household electrical appliances is laid down in EN 50564:2011, where the corresponding adaptations must be made to check controls.

Standby mode with display or information status

References:

EN 15500-1:2017 § 5.3.2 & § 6.1
EN 50564:2011 § 5.3

EN 15500-1 defines the basic layout for testing controls separately from the local space heater, although it does not set out a specific method for testing standby mode with display of information or status.

A specific method for low power modes of household electrical appliances is laid down in EN 50564:2011, where the corresponding adaptations must be made to check controls.

Control accuracy and control to setpoint deviation

Reference:

EN 15500-1:2017 § 5.4 & § 6.3

Question 14

Anne x G: Bibliography

Accepted Answer

Commodity codes used: Trade Tariff: look up commodity codes, duty and VAT rates

Current EU ecodesign legislation for local space heaters (2024/1103)

Current Great Britain ecodesign legislation for local space heaters (2015/1188)

How standardisation is regulated and adopted in the UK

DESNZ (2023), Home Energy Model: Future Homes Standard assessment

List of testing standards for a range of products, including energy-related products

Pending amendment to EU ecodesign regulations: Ecodesign requirements for local space heaters – amendments to Commission Regulation (EU) 2024/1103 (implementing act)

Regulation for energy labelling of local space heaters: Commission Regulation (EU) 2015/1185 of 24 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for solid fuel local space heaters (Text with EEA relevance)

Question 15

Further information

Accepted Answer

Any enquiries regarding this publication should be sent to us at localspaceheaters@energysecurity.gov.uk.

Trade Tariff: look up commodity codes, duty and VAT rates ↩
Commission Regulation (EU) 2015/1185 of 24 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for solid fuel local space heaters (Text with EEA relevance) ↩
Current ecodesign legislation for local space heaters: Commission Regulation (EU) 2015/1188 ↩
4BSI (British Standards Institution) is a member of CEN and CENELEC, who are the European bodies that develop harmonised standards. BSI is required to adopt any CEN/CENELEC standard as a UK national standard so any harmonised standard will have an equivalent UK national standard and can therefore be made into a designated standard. More information about standardisation ↩
There are many standards that are not harmonised standards but are developed by European and international standardisation bodies for other purposes. These are often used as a basis for transitional methods, usually with some modification or additional steps to make them relevant to that specific ecodesign regulation. ↩
Designated standards ↩
Table 8 in Home Energy Model: Future Homes Standard assessment: DESNZ (2023) ↩
In line with the relevant definitions at regulation 2 of The Ecodesign for Energy-Related Products Regulations 2010, a product is ‘placed on the market’ at the point when it is made available for the first time on the market of Great Britain. For example, when it is first supplied for distribution or use on the British market in the course of a commercial activity, whether in return for payment or free of charge. ↩
In line with the relevant definition at regulation 2 of The Ecodesign for Energy-Related Products Regulations 2010, a product is ‘put into service’ when it is used for the first time for its intended purpose on the market of Great Britain. For example, when it is used to provide heating comfort to a person. ↩
While awaited EU amendments propose to remove article 6 from Commission Regulation (EU) 2024/1103, this is only because it duplicates the anti-circumvention provision in Regulation (EU) 2024/1781. Given Regulation (EU) 2024/1781 is not replicated in British law we have opted to align with article 6 in our proposed SI. ↩
Ecodesign requirements for local space heaters – amendments to Commission Regulation (EU) 2024/1103 (implementing act) ↩

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Executive summary

Introduction

Proposals

Enhancing efficiency of products (Part 1)

Encouraging effective energy consumption (Part 2)

Supporting a circular economy (Part 3)

Consultation Impact

General Information

Why we are consulting

Consultation details

How to Respond

Confidentiality and data protection

Quality assurance

Product coverage and extent of regulation

Part 1: Enhancing efficiency of products

Chapter 1: Product scope and categorisation

Introduction

Product category definitions

Product categories without change

Heaters incapable of operation without control

Balanced flue

Electric portable

Electric fixed

Electric underfloor

Electric visibly glowing radiant portable

Towel rails

Power consumption

Speciality and multi-function products

Chapter 2: Calculating efficiency of products

Introduction

Efficiency calculation methodology

Testing methods

Primary energy factor

Chapter 3: performance thresholds

Introduction

Product efficiency thresholds

Nitrogen oxide emission limits

Part 2: Encouraging effective energy consumption

Chapter 4: Regulating delivery of heat

Introduction

Definition of a control

Minimum requirements on heat control

Power consumption whilst not in active use

Part 3: Supporting a circular economy

Chapter 5: Right to repair

Introduction

Spare part availability

Access to information on repair for installers

Chapter 6: Consumer protection

Introduction

Circumvention

Documentation and mandatory phrasing

Review

Alignment with the EU regulation

Equality Act 2010

Annex A: glossary

Annex B: list of consultation questions

Annex C: parameters used for SSHE calculations

Annex D: proposed formula changes

Seasonal space heating efficiency ηS

ηS,on

ηS,th

Emission efficiency ηS,RF

Radiant factor RFs

F(1), F(2) and F(3)

F(4)

F(5)

Annex E: spare part requirements

Annex F: transitional methods

Gaseous fuel local space heaters

Direct heat output

Indirect heat output

Useful efficiency at nominal heat output

Nominal heat output, minimum heat output

Electrical power consumption at nominal heat output

Electrical power consumption at minimal heat output

Electrical power consumption on standby

Emissions of nitrogen oxide

Permanent pilot flame power

Seasonal space heating efficiency η_S

η_S,on

η_S,th

Emission efficiency η_S,RF

Radiant factor RF_s